Key facts

A number of criticisms have been levelled at the FSA’s NP model, including from those sections of the food industry that have not welcomed tougher controls on the advertising of foods high in fat, saturated fat, salt and/or sugar (HFSS) to children. Some of these criticisms flow from a misunderstanding of the purpose of the NP model and others from a misrepresentation of how individual foods are categorised.

Specific criticisms are addressed below:

The model uses a 100g measure rather than actual portion size, so unfairly penalises foods eaten in smaller quantities
Per 100g is the approach legally required for nutritional labelling and for nutrition claims such as “low fat”. It is the internationally recognised way (used for example by the WHO and the EU) to compare products on a like-for-like basis.

The 100g/per portion issue has been discussed in detail on a number of occasions: by the expert group which advised the FSA during the development of the model, by an independently chaired academic workshop convened to scrutinise the model (in Feb 2005), by the Scientific Advisory Committee on Nutrition (SACN, in February and September 2005) and during a second independent academic workshop in February 2008. Each concluded that using a “per portion” approach would bring no significant advantages and would introduce several difficulties, most notably the variability in declared portion size for similar foods.

There is no agreed consensus on portion size within the food industry relevant to this application.

The eating behaviours of children at different age groups add an extra layer of complexity to defining commonly agreed “per portion” criteria.

The model demonises and labels as 'junk' foods that are usually seen as healthy, such as marmite, honey and raisins
The use of the term ‘junk food’ by the media and others to describe the foods that the NP model classifies as HFSS demonstrates a misunderstanding of nutritional science and how the NP model works. The FSA never uses this term.

A number of the foods identified by critics as foods that should pass the model, but do not, (e.g. olive oil) are not usually advertised to children. Ofcom’s restrictions and the application of the NP model relate only to broadcast restrictions at times when children will be watching television. They do not affect advertising at other times.

Foods are assessed on a product by product basis. Marmite, for example, while a good source of B vitamins, has a high score due to its high salt content. Honey has a high score due to high sugar levels. Raisins are subject to the advertising restrictions because of their high sugar content, but other dried fruits containing less sugar, such as apricots and figs, are not.

The model restricts many varieties of cheese amongst other things. Doesn’t this conflict with FSA dietary advice?
The NP model was developed as a tool to address the bias towards HFSS foods in the television promotion of foods to children and is not intended as a consumer-facing, dietary advice tool.

Most hard cheeses would not pass the NP model. They would be subject to restrictions because they are high in saturated fat and salt. However some low fat cheeses can still be advertised during children’s viewing times.

The FSA’s advice on dairy products remains that they are a good source of calcium and other beneficial nutrients. However, cheese provides less than 10% average calcium intake to the diets of children aged 4-14, with milk being the main contributor (source: National Diet and Nutrition Survey). The Agency also advises that dairy foods should be consumed in moderation and low or reduced fat varieties eaten where possible.

Ofcom’s analysis of cheese and cheese products’ advertising shows that in 2005, only 20% of advertisements for cheese and cheese products were shown in children’s airtime. Of these, 90% were for the highly processed varieties, cheese string and dipper products.

The model would allow the advertising of foods with minimal or low nutritional value, e.g. chicken nuggets, oven chips
The model is a scoring system, in which points are allocated on the basis of nutritional content in 100g of food, accounting for both levels of energy, saturated fat, total sugars and salt, as well protein and positive food components like fibre, fruit, vegetables and nuts. Foods are assessed on an individual basis. The score depends on the product’s recipe at the time of assessment.

For example, chicken nugget products that are made of 100% breast meat and coated in breadcrumbs may pass the model, whereas chicken nugget products containing high levels of added salt and with a batter coating may not. Similarly the score for chip products depends on the recipe, for example whether animal or vegetable fat is used, how much, and the method of preparation. Some oven chip products would be subject to advertising restrictions, others would not.

We must be realistic about what nutrient profiling sets out to achieve and recognise that it is not a one-stop shop to capture every element of dietary advice. It is about the nutritional content of a food - not about what to eat or how much, when or how often. Independent testing of the Agency’s model by scientists in the UK and internationally has shown it to be more robust than other nutrient profiling models in use elsewhere.

The NP model fails to distinguish between natural and processed sugars
The expert group that oversaw the model’s development initially gave a score for added or processed sugars, but this was later replaced with a score for total sugars to make the model easier to use. Total sugars include 'natural' sugars (e.g. from dairy products, fruit and vegetables) as well as added sugars.

The contribution of foods high in natural sugars to a balanced diet is addressed through the inclusion of criteria for protein and fruit, vegetables and nuts.

The NP model is unscientific
The Agency’s nutrient profiling model was developed in a systematic way and is based on nutrient intake criteria established by the Scientific Advisory Committee on Nutrition (SACN) and the Committee on Medical Aspects of Foods (COMA). The model was tested during its development to ensure the results were consistent with views of nutrition professionals and advice on healthy eating.

This work was overseen by an Expert Working Group comprising independent nutritionists and dietitians, as well as industry and consumer representatives. It was subject to external scrutiny, for example via a scientific workshop attended by nutrition academics and by the Scientific Advisory Committee on Nutrition (SACN).

The independent Panel carrying out the current Review of the model has agreed that the model is a scientifically robust tool, fit for its intended purpose.

Independent testing of the Agency’s model by scientists in the UK and elsewhere has shown it to be more robust than other nutrient profiling models in use elsewhere.

The FSA is lobbying for the model to be adopted by the European Commission and in non-broadcast advertisements
The purpose of the NP model is as a tool for Ofcom to use in the restriction of television advertising of HFSS to children. The FSA is not promoting the model for any other use.

The European Commission has, however, asked the European Food Safety Authority to develop a NP model to allow it to asses whether health claims being made by industry for individual foods are suitable from a nutritional point of view. The FSA has not been proposing that the NP model be used for this purpose.