Letter to UNBS on FOPL Standard

16th December 2020

The Executive Director,
Uganda National Bureau of Standards (UNBS),
Standards House,
Plot 2–12, Bypass Link,
Bweyogerere Industrial & Business Park,
P.O. Box 6329,
Kampala, Uganda.

Dear Sir,

RE: JOINT CSOs REQUEST FOR AMENDMENT OF EAST AFRICA STANDARDS ON NUTRITION LABELLING TO INCORPORATE WHO RECOMMENDATIONS ON FRONT-OF-PACK LABELLING AND PROMOTE HEALTHY DIETS

We, the undersigned Civil Society Organizations (CSOs) working under the Advocacy Working Group for the Promotion of Healthy Diets and Prevention of Nutrition-Related Non-Communicable Diseases (NCDs), hereby request the Uganda National Bureau of Standards (UNBS) to review the existing nutrition labelling standard (US EAS 803:2014) to incorporate the World Health Organization (WHO) recommendations on Front-of-Pack Labelling (FOPL) for all pre-packaged foods and non-alcoholic beverages. Additionally, we urge the adoption of the Nutrient Profile Model for the WHO African Region—a tool designed to implement WHO guidelines on the marketing of foods and non-alcoholic beverages to children (https://apps.who.int/iris/handle/10665/329956).

Uganda, alongside Kenya, Tanzania, Bangladesh, and Sri Lanka, was selected by WHO to participate in the Global Regulatory Framework for Promoting Healthy Diets and Physical Activity Capacity Building Program (GLOBAL RECAP) due to its epidemiological profile. This initiative aims to support member states in reducing NCD-related morbidity and mortality by strengthening regulations on healthy diets and physical activity.

Under Human Rights Law (encompassing the right to food and the right to health), UNBS bears a constitutional obligation to ensure accurate, transparent, and easily understandable product information. The food and beverage industry must be held accountable for providing such information to safeguard public health and nutritional rights.

Pursuant to the Uganda National Bureau of Standards Act, UNBS possesses the authority to establish and enforce product standards, including mandatory Front-of-Pack Labelling (FOPL) for pre-packaged foods and beverages.

The Ugandan and East African markets are increasingly saturated with products high in sugar, salt, and fats—key contributors to overweight, obesity, and NCD-related premature deaths. In response, WHO has endorsed Front-of-Pack Labelling (FOPL), food reformulation (reducing sugar, salt, and fat content), and restrictions on marketing unhealthy foods to children as cost-effective interventions. A WHO capacity needs assessment (conducted in Kampala, 6–10 May 2019) identified significant gaps in implementing these measures.

While we acknowledge the existing harmonized EAC standards (e.g., US EAS 803:2014 on Nutrition Labelling, US EAS 805 on Nutrition and Health Claims, and US EAS 38 on Pre-packaged Food Labelling), we note the absence of FOPL provisions and the failure to align nutrient thresholds (for total fat, saturated fat, sugars, sodium, and energy) with WHO’s AFRO Nutrient Profiling Model. We therefore urge a review of these standards to incorporate FOPL and adopt WHO-recommended nutrient thresholds to promote healthier diets and reduce NCD prevalence in Uganda and the wider East African region.

Front-of-Pack Warning Labels are an urgent necessity—a vital policy tool to empower consumers in identifying nutritional profiles and making informed dietary choices, in line with Uganda’s Constitution (Objective XXII) on the right to nutrition.

We specifically recommend the Color-Coded (Traffic Light) FOPL System, which enables consumers—including those with low literacy—to quickly assess product healthiness. Such labelling also incentivizes manufacturers to improve nutritional quality.

We believe this system is intuitive and accessible, particularly for communities with limited literacy or food literacy.

We kindly request a meeting with your office to discuss these recommendations in detail. Your prompt attention to this matter will significantly advance public health objectives.

Thank you for your consideration.

………………………………………
Kabanda David
Executive Director,
Centre for Food & Adequate Living Rights (CEFROHT)
Tel: 0772480179 | Email: kabanda.cefroht@gmail.com

Endorsed by:

• 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)