16th/12/2020
The Executive Director,
Uganda National Bureau Standards (UNBS),
Standards House,
Plot 2 – 12, Bypass Link,
Bweyogerere Industrial & Business Park,
P.O. Box 6329,
Kampala, Uganda
Dear Sir,
RE: JOINT CSO’s REQUEST FOR AMMENDMENT OF EAST AFRICA STANDARDS ON NUTRITION LABELLING TO INCORPORATE WORLD HEALTH ORGANIZATION’s RECOMMENDATION ON FRONT-OF-THE PACK LABELLING AND PROMOTE HEALTHY DIETS.
We the joint Civil Society Organizations on Promotion of Healthy Diets and Prevention of Nutrition related Non-Communicable Diseases (NCDs), working through the Advocacy Working Group, write to request the Uganda National Bureau of Standards (UNBS) to review nutrition labelling standard (US EAS 803:2014) to incorporate World Health Organization (WHO) on Front-of-Pack Labeling (FOPL) of all pre-packed food and non-alcoholic beverages and also to adapt and adopt nutrient profile model for the WHO African Region – a tool for implementing WHO recommendations on the marketing of foods and non-alcoholic beverages to children (https://apps.who.int/iris/handle/10665/329956).
Uganda, Kenya, Tanzania, Bangladesh and Sri Lanka were selected by the World Health Organization (WHO) to implement the Global Regulatory Framework for Promoting Healthy Diets and Physical Activity Capacity Building Program (GLOBAL RECAP) based on their epidemiological profile among others. The program is designed to support selected countries to reduce morbidity and mortality due to NCDs by developing regulations to promote healthy diets and physical activity.
It is a constitutional duty under Human Rights Law (the right to food and the right to health) on UNBS to promote accurate, easily understandable, transparent and comprehensible information on their products. The food and beverage industry must be compelled to convey this information for the protection of the public rights to health and adequate food.
Under the Uganda National Bureau of Standards Act, UNBS has extensive powers to set and implement standards on products and services, including setting standards for the front-of-the-pack labeling for all pre-packed food and beverages.
Foods high in sugar, salt and fats, and sugar sweetened beverages are currently increasing on the Uganda market and in East Africa, yet these have a direct impact on overweight and obesity and are key contributing factors to premature morbidity and mortality due to NCDs. In this regard, WHO recommended most cost-effective interventions as in: Front-of-Pack Labeling (FOPL), reformulation of foods to contain less sugar, salt and fat, restrictions on marketing of foods and sugar sweetened non-alcoholic beverages to children. In its country review and capacity needs assessment conducted in Kampala in 6-10 May 2019, WHO found gaps in availability and implementation of the priority interventions.
We acknowledge and appreciate the harmonized EAC standards in place like the US EAS 803:2014 on Nutrition labeling – Requirements, US EAS 805: Use of nutrition and health claims – Requirements and the US EAS 38: Labeling of pre-packaged foods. However, there are no provision for the front-of the-pack labeling whereas nutrient thresholds on total fat, saturated fat, total sugars, added sugars, sodium and energy are above WHO recommendations as given under AFRO nutrient profiling model. It is against this background that we recommend that the said laws be reviewed to adopt and incorporate the front of the pack labeling and adopt AFRO nutrient profiling model in reformulation of nutrient thresholds as recommended by WHO to promote healthy diets and reduction of NCDs in Uganda and the East African region as a whole.
Front-of-package warning labeling standards are urgently needed in this regard as an important policy tool for empowering consumers to clearly and effectively identify products nutritional profiles to make informed decisions on healthier food choices consistent with provision of the Uganda constitution in objective XXII on the right to nutrition.
We would like to recommend the Color-coded system or Traffic light Front-of-Pack (FOPL) Nutrition labels which will easily help consumers identify food product content and enable them to make more informed choices. Nutrition labels can also encourage food and drink companies to improve the nutritional quality of their products.
For example see below for
Color-coded system or Traffic light labeling:
We believe that color-coded system or traffic lights are widely understood by shoppers and would be ideal in communities with many people who cannot read and those who are not food literate.
The purpose of this letter is to request for a meeting with you and your colleagues to discuss in detail the recommendations on Front-of-Pack Labeling (FOPL) and AFRO nutrient profiling model.
Thank you for your consideration of our request on this important issue.
Signed for and on behalf of,
Advocacy Working Group for Health Diets;
………………………………………………
Kabanda David
Executive Director
Centre for Food & Adequate Living Rights (CEFROHT)
0772480179
kabada.cefroht@gmail.com
Consumer Education Trust (CONSENT) Uganda.
Makerere University, Human Rights Peace Centre (HURIPEC)
Southern and Eastern Africa Trade Information and Negotiations Institute (SEATINI) Uganda
Food Rights Alliance (FRA) Uganda
Uganda Non-Communicable Diseases Alliance (UNCDA)
East African Non-Communicable Diseases Alliance (EANCDA)
Uganda Cancer Society (UCS)
Civil Society Alliance for Nutrition Uganda (CISANU)
