The Noakes Foundation comments: 

FOODSTUFFS, COSMETICS, AND DISINFECTANTS ACT, 1972 (ACT No.54 OF 1972)

REGULATIONS RELATING TO THE LABELLING AND ADVERTISING OF FOODSTUFFS

Recently the Department of Health has Gazetted a document for public comment. This document aims to make changes to the way food items are labeled in South Africa. These proposed changes, called the Regulations Relating to the Labelling and Advertising of Foodstuffs, seek to enhance transparency and promote healthier dietary choices for consumers. One of the proposed changes is to include warning labels for products high in added sugar, saturated fat, and sodium (salt) that exceed the nutrient cut-off values. 

As The Noakes Foundation, we welcome the opportunity to contribute our comments and insights on the proposed changes to food labeling in South Africa. We believe that clear and informative food labeling is crucial in supporting this goal and improving public health.

Since 2016, The Noakes Foundation and Eat Better South Africa! have been at the forefront of advocating for proper food labeling. Their collaborative effort led to the launch of Eat Better SA’s Sugar Barometer. This idea was borne off the back of the sugar tax debate and the discussion around whether such a strategy would realistically lead to a reduction in obesity rates. The Noakes Foundation realized that it’s not the cost of sugar that’s the problem, the real issue boils down to the fact that most people are unaware of the hidden sugar contents in food and are still unsure of how to read food labels. The purpose of the Sugar Barometer was for children and illiterate people to be able to identify the number of teaspoons of sugar a product contains, equipping them to make an educated decision on whether to purchase the item or not. Transparent and accurate labeling provides crucial information about the content and quality of food products, enabling people to understand what they are consuming and its potential impact on their health. By advocating for clear labeling, The Noakes Foundation aims to combat the rising rates of obesity, type 2 diabetes, and other diet-related health issues by promoting healthier food choices and fostering a society that values conscious eating.

Research into commonly consumed foods revealed shocking amounts of hidden sugar, found in sauces, sandwiches, cereals, and more, contributing to the country’s rising obesity and type 2 diabetes rates. Jayne Bullen (COO of The Noakes Foundation, MD of Nutrition Network, Co-founder of Eat Better SA), emphasizes “Conscious eating means understanding everything about the food we consume, from its origin and growth process to the treatment of the plants or animals, and the use of pesticides or medicine.”

The following are our comments on the new proposed food labeling policy.

Endorsement of Sugar Warnings:

Excessive sugar consumption has been linked to numerous detrimental health effects, making the inclusion of warning labels for high sugar content on food products an important measure. By raising awareness among consumers about the potential risks associated with sugar, we can significantly contribute to promoting healthier dietary choices and reducing the prevalence of various health conditions and diseases.

One of the foremost health concerns related to excessive sugar intake is Type 2 Diabetes. Excessive sugar consumption plays a pivotal role in the development and progression of this disease. The regular consumption of sugary foods and beverages leads to insulin resistance, a condition in which the body’s cells become less responsive to the hormone insulin. This impairs glucose metabolism and may eventually lead to the development of Type 2 Diabetes and its major complications. However, by adopting healthier eating habits and reducing carbohydrate and sugar intake, individuals can effectively manage and prevent the complications associated with Type 2 Diabetes, improving their overall health.

In addition to Type 2 Diabetes, consuming foods, and beverages high in added sugars can contribute to weight gain and obesity. Sugary products are often high in calories and low in nutritional value, leading to an imbalance in energy intake. Over time, this can lead to an unhealthy weight and increase the risk of obesity-related complications.

Furthermore, excessive sugar consumption has been associated with an increased risk of cardiovascular diseases. Diets that are high in added sugars can elevate blood pressure, raise triglyceride levels, and promote inflammation, all of which are significant risk factors for heart disease, stroke, and other cardiovascular conditions. By reducing sugar intake, individuals can potentially lower their risk of developing these life-threatening conditions.

Sugar also plays a major role in dental problems, contributing significantly to tooth decay and cavities. When we consume sugary foods and drinks, the bacteria in our mouths produce acids that attack the enamel of our teeth, leading to dental decay. This is especially concerning for children and individuals who frequently consume sugary snacks or beverages.

Moreover, high sugar intake, especially in the form of fructose, can contribute to the development of non-alcoholic fatty liver disease (NAFLD). Excessive sugar consumption leads to the accumulation of fat in the liver, which can impair liver function and increase the risk of liver inflammation, scarring, and even liver failure in severe cases.

Therefore, endorsing the inclusion of warning labels for high sugar content on food products is a step towards promoting healthier food choices, as this will help individuals make informed decisions and choose healthier options, and overall reduce the negative health impacts associated with excessive sugar consumption.

Support of Saturated Fat Warnings should be reconsidered: 

The view on saturated fat and its alleged negative health effects has been a topic of debate in the field of nutrition. Over the years, some studies and research have challenged the traditional view, suggesting that the support for saturated fat warnings should be reconsidered. These studies emphasize the importance of updating nutritional guidelines to align with current scientific understanding.

Several studies, meta-analyses, and systematic reviews have found no significant association between saturated fat intake and increased risk of cardiovascular disease (CVD) or mortality (6). Specifically, a higher saturated fat intake was not associated with an increased risk of CVD, stroke, or mortality (7).

Many researchers argue that older studies that implicated saturated fat as a major contributor to CVD were limited in their design and failed to consider confounding factors. A re-evaluation of these studies suggests that factors such as trans fats, refined carbohydrates, and overall dietary patterns may have influenced the observed associations (7). Furthermore, previous research on the effect of saturated fat on CVD health have been biased due to researchers’ personal dietary choices, therefore limiting the research in other dietary strategies. This negatively affected the comprehensive understanding of the impact of saturated fat on overall health.

While the research is ongoing, nutritional guidelines should regularly be updated as new research emerges, aiming to provide the most accurate and up-to-date recommendations for public health.  This will provide individuals with a balanced understanding of saturated fat and its potential impact on health.

Discussion on Sodium Warnings: 

The proposal for sodium warnings on food products is important, however, it requires evidence-based discussion and collaboration with the scientific community. While excessive sodium intake has been linked to health issues, like high blood pressure and cardiovascular disease, it is worth noting that no current evidence suggests that eating a low-salt diet is healthy. In fact, research suggests that a low-salt diet may increase levels of insulin resistance and promote sugar cravings (9). 

Therefore, establishing accurate guidelines and thresholds for sodium demands involving experts in nutrition, public health, and related fields to help evaluate existing evidence, identify knowledge gaps, and develop recommendations.

Furthermore, efforts should focus on reducing sodium in processed foods and tailoring warnings to specific groups to consider individual variability and dietary patterns.

Conclusion:

As we submit these comments, we believe that a collaborative approach, involving the scientific community, policymakers, and stakeholders, will lead to effective and impactful food labeling regulations in South Africa. We look forward to engaging further in discussions and are eager to hear from stakeholders, including policymakers, to collectively create a positive impact on the health of our nation. 

References:

1. Malik, V. S., Popkin, B. M., Bray, G. A., Després, J. P., Willett, W. C., & Hu, F. B. (2010). Sugar-sweetened beverages and risk of metabolic syndrome and type 2 diabetes: a meta-analysis. Diabetes Care, 33(11), 2477-2483.
2. Johnson, R. K., Appel, L. J., Brands, M., Howard, B. V., Lefevre, M., Lustig, R. H., … & Wylie-Rosett, J. (2009). Dietary sugars intake and cardiovascular health: a scientific statement from the American Heart Association. Circulation, 120(11), 1011-1020.
3. Stanhope, K. L., Schwarz, J. M., & Havel, P. J. (2013). Adverse metabolic effects of dietary fructose: results from the recent epidemiological, clinical, and mechanistic studies. Current Opinion in Lipidology, 24(3), 198-206.
4. Moynihan, P., & Petersen, P. E. (2004). Diet, nutrition, and the prevention of dental diseases. Public Health Nutrition, 7(1a), 201-226.
5. Lustig, R. H., Schmidt, L. A., & Brindis, C. D. (2012). Public health: The toxic truth about sugar. Nature, 482(7383), 27-29.
6. Siri-Tarino, P. W., et al. (2010). Meta-analysis of prospective cohort studies evaluating the association of saturated fat with cardiovascular disease. The American Journal of Clinical Nutrition, 91(3), 535-546.
7. Dehghan, M., et al. (2017). Association of dairy intake with cardiovascular disease and mortality in 21 countries from five continents (PURE): a prospective cohort study. The Lancet, 392(10161), 2288-2297.
8. Harcombe, Z., et al. (2017). Evidence from randomised controlled trials did not support the introduction of dietary fat guidelines in 1977 and 1983: a systematic review and meta-analysis. Open Heart, 4(2), e000196.
9. Noakes, T.,Sboros, M. (2017). Lore of Nutrition: Challenging Conventional Dietary Beliefs. Penguin Random House South Africa.