Designers have not been consulted on European food labelling proposals, and consumers could well lose out as a result, argues Emily Pacey
Since overlooking the design industry during its recent consultation on food labelling, the Food Standards Agency has started a game of ‘pass the buck’ that promises to punish both designers and consumers.
The European Union-wide consultation paper in question – from the European Commission – is called Proposal For a New Regulation on the Provision of Food Information to Consumers. It contains several design-related recommendations. These include introducing minimum 3mm-high lettering and high-contrast graphics for front-of-pack guideline daily amounts (DW 24 April).
Despite sending the document to hundreds of food retailers, manufacturers and other stakeholders, the FSA failed to include design on its original stakeholder list, and continues to downplay the industry’s interest in the issue.
In a recent statement, the quango said, ‘The FSA has consulted widely with those [parties] we are aware have an interest in food labelling. To inform their responses, we expect that food companies would consult with their designers for an input into proposed changes on labels, such as the minimum font size.’
By maintaining its position in this way, the FSA is failing to quell designers’ frustration on the issue.
‘When are we going to be invited to the table and treated as adults by the FSA?’ protests Doug James, managing director of Honey Creative, which has just finished working on Tesco’s convenience food range. ‘I am frustrated and disappointed that we have not been considered as a stakeholder.’
Design Council chief executive David Kester argues that, ‘Design plays a central role in all aspects of packaging, whether [relating to] product presentation and protection, consumer information or environmental impact.’
But while it agrees that design is a stakeholder in food labelling, the Design Council is not willing to shoulder any blame for design’s apparent low profile with the FSA, or take responsibility for future consulting on such documents.
The FSA claims that a significant proportion of those who receive its consultations have registered to be sent papers that interest them. The Advertising Association did register, and received this paper.
‘Unlike the Advertising Association, we are not an industry-representative body. We don’t have the resources to engage in issues such as food labelling,’ says a Design Council spokesman.
‘We focus on delivering national strategic programmes to promote the use of design, rather than lobbying or representing on specific narrow issues involving designers. This job is ably done by the Design Business Association,’ adds the spokesman.
Perhaps not ably enough, since the DBA was not registered to receive the paper, either. Chief executive Deborah Dawton was unavailable for comment at the time of going to press.
The Design Council is stepping in to offer its services as a go-between, however.
Some designers believe that there could be a deeper problem with the way that design is perceived by the FSA.
‘The implication of not involving experts in food branding and design is that we may not have a “neutral” hat on. This is a rather narrow-minded and bureaucratic mindset,’ says Pearlfisher creative partner Jonathan Ford.
The FSA reveals its suspicion of design when a spokesman argues, ‘You wouldn’t necessarily consult designers, [but] you would do market research to discover what consumers find easy to read and understand.’
In an attempt to find a path through this debate, James observes that, ‘In fact, we are in a fairly unique position, as consumers of the food labelling system and also as creative problem-solvers who can add value to existing ideas.’
The consultation closed on 2 May, but there is an air of optimism about what can be achieved after the fact.
Mark Frost, creative director at BR&Me – the consultancy behind the ‘wheel of health’ traffic-light system on Sainsbury’s own-brand food packs – says, ‘Food labelling is important, and needs to be standardised across all products, including non-supermarket ranges. Eventually, any new rule becomes part of the design system. As a designer, you live with that information and quickly learn to assimilate it into your practice.’
Perhaps thinking about Honey’s future relationship with Tesco, James says, ‘The best way we can make a difference is to work with the brands and influence the positioning, clarity and size of the GDA information. That is always about putting the consumer first.’
Ultimately, the FSA and design are fighting for the same values of clarity, simplicity and ease of use, but until there is mutual recognition of this, consumers and design will continue to suffer.
The consultation results will be published in July.
Reactions to the European Commission’s Proposal For a New Regulation on the Provision of Food Information to Consumers:
• The suggestion that text conveying nutritional information should be a minimum of 3mm high would have an enormous effect. From a design point of view, I would advise against that.
Mark Frost, Creative director, BR&Me
• What a fantastic opportunity to create an information graphics icon, a classic that will live on food packs for years to come.
Jon Davies, Managing director, Holmes & Marchant
• To exclude design experts is a decision that could lead to a camel of a solution that will be a bitch to work with.
Jonathan Ford, Creative partner, Pearlfisher
• After the furore over the ‘traffic-light system’, this feels like a disaster waiting to happen. Keep it simple, think of the consumer and consult a designer.
John Morris, Managing director, Design Bridge