Table 3

Governance of FOP nutrition labelling regulation

Label, Jurisdiction (Year endorsed)Initiated byStakeholder engagementNutrient criteria developed byAdministrationMonitoringGovernment-supported evaluation/ReviewReview of nutrient criteriaEnforcement strategies
Nordic Keyhole
Sweden (1989); Denmark And Norway (2009), Lithuania (2013)
Government, Swedish Food Standards Agency with reference to Nordic Nutrition RecommendationsGovernment (varies by jurisdiction)Consumer use, Uptake (industry self-report), compliance, reformulationGovernment led evaluation, timeline and framework varies by jurisdictionYes, criteria reviewed five times since 1989Varies by jurisdiction, includes publicity (Denmark), legal remedies under trademark and food law (Sweden)
High Salt Warning Label
Finland (1993)
Government, multisectoral engagementGovernment (Ministry of Social Affairs and Health)Reported, detail not availableBroader cardiovascular initiative evaluated, reformulation reportedThresholds lowered in 2009, extended to unpackaged equivalents 2016Audits
Protective Food Logo
Slovenia (1993)
Civil society (Slovenian Heart Foundation)Independent experts from Society of Cardiovascular HealthCivil society (Slovenian Heart Foundation)
Healthier Choice Symbol
Singapore (1998)
GovernmentGovernment, developed with industry to promote feasibilityGovernment (Health Promotion Board)Consumer use, register of products usingGovernment led evaluation resulted in revisions in 2015Yes, criteria updated on rolling basisLicensing, audits, publicity, legal remedies under trademark, removal of approval to use
Finland (2000)
Civil society (Finnish Heart Association and Finnish Diabetic Association)Food industry and consumer groups consulted, endorsed by Ministry of Social Affairs and HealthIndependent experts, input from government Food Safety Authority and reference to national dietary guidelinesCivil societyConsumer use, uptakeRegular update by independent expert groupAudits
Nigeria (2005)
Civil society (Nigerian Heart Foundation)Civil society, approved by National Agency for Food and Drug AdministrationCivil society, later joined Choices ProgrammeNow subject to Choices Programme updatesLicensing by Nigerian Heart Foundation
Traffic Light System
UK (2006)
GovernmentPublic consultationGovernmentGovernment (Food Standards Agency)Uptake (industry self-reported)
Choices Programme
Poland (2008), Czech Republic (2011)
IndustryMultistakeholder collaborationIndependent expert group separate of industry collaborators for this processMultistakeholder committeeVaries by jurisdiction, Consumer use, reformulationReviewed every 3–4 years by independent expert committeeLicensing
Guideline Daily Amount
Thailand (2011)
GovernmentLegislative processN/AGovernment (Food and Drug Administration)Consumer use, uptakeGovernment, positive results publishedN/A
Traffic Light Labels
South Korea (2011)
GovernmentLegislative processGovernment, Minister delegated authority to set thresholdsGovernment (Ministry for Food and Drug Safety)Legal remedies under implementing act, including fines
Reference Intakes
European Union (2011)
GovernmentLegislative process, public consultation,N/AN/A
Guideline Daily Amount
Malaysia (2012)
IndustryWas initiative of International Food and Beverage Alliance, endorsed by governmentN/AGovernment (Ministry of Health)
Guideline Daily Amount
Philippines (2013)
GovernmentN/AGovernment (Food and Drug Administration)Licensing
Traffic Light Labels
Ecuador (2014)
GovernmentLegislative processGovernment, adapted from UK traffic lights but adapted to Ecuadorian intakeGovernment (Ministry of Public Health)Consumer use
Guideline Daily Amount
Mexico (2014)
GovernmentLegislative process, lack of transparency in consultation noted as concern by civil societyN/AGovernment (Mexican Federal Commission of Sanitary Risk Prevention)N/A
Mexico (2014)
GovernmentDeveloped by International Food and Beverage Alliance, not publicly availableGovernment (Mexican Federal Commission of Sanitary Risk Prevention)Licensing
Health Star Rating System
Australia (2014), New Zealand (2014)
GovernmentMultistakeholder collaboration with industry, public health, consumer involvement; public consultationMultistakeholder committee, including industry, public health, consumer groupsMultistakeholder committee, has authority to manage complaintsFramework available: includes consumer use, uptake, reformulation, compliance. Two year monitoring report and data fed into 5 year review.Formal 5 year review led by government-appointed independent consultant, public consultationYes, focus of formal 5 year reviewAudits, written requests for amendments, complaint handling mechanism, listing on HSR website
Stop Sign Labels
Chile (2015)
Government, multisectoral engagementLegislative process, public consultation, strategic media engagementGovernment, independent experts, tested against data from US Department of Agriculture DatabaseGovernment (Ministry of Health)Consumer use, reformulation, uptake, complianceFormal evaluation in cooperation with academics, includes changes in product purchases and dietary intakesProgressively lowering thresholds built into legislationAudits prioritising school foods
Traffic Light Labels
Iran (2015)
GovernmentLegislative process, consultation with technical committee including food industry and nutrition representativesGovernment (Food and Drug Administration)UptakeWritten requests for amendments, withhold marketing permission
Weqaya Logo
United Arab Emirates (2015)
GovernmentGovernment led public consultationGovernment, thresholds derived from Nordic KeyholeGovernment (Health Authority, Food Control Authority, Quality and Conformity Council)Licensing, audits
Healthy Living Guarantee
Croatia (2015)
GovernmentGovernmentGovernment (Croatian Institute of Public Health)Government evaluation as part of broader Healthy Living strategyLicensing
Traffic Light Labels
Sri Lanka (2016 drinks, 2019 food)
GovernmentLegislative process, public consultationIndependent experts, drawing on other country experiencesGovernment (Ministry of Health)Reformulation, salesGeneral sanctions available under Food Act
Healthier Choices Logo
Thailand (2016)
GovernmentMultistakeholder, developed with agreement of industry, academics and public sectorAdapted from Choices Programme criteria developed by independent expertsGovernment (owned by Thai Food and Drug Administration, use managed by Nutrition Promotion Foundation)UptakeLicensing, unauthorised use can face jail sentences and fines
Red Warning Labels
Israel (2017)
GovernmentLegislative process, multistakeholder committee with open meetings and publicly available recordings, public consultationGovernment, independent expertsGovernmentPlanned, no detail availablePlanned, stated to include sales dataProgressively lowering thresholds built into legislation
Green Signpost
Israel (2017)
GovernmentMultistakeholder committee with open meetings and publicly available recordings, public consultationGovernment, independent experts, adapted from Nordic KeyholeGovernment
Stop Sign Labels
Peru (2017)
GovernmentLegislative processGovernmentProgressively lowering thresholds built into legislationFines
France (2017), Spain (2018), Belgium (2019)
GovernmentFormal process directed by government under Health Law, public consultation,Government, French High Council of Public Health commissioned to affirmGovernment (Santé Publique France)Consumer Use, Uptake (industry must register use on government website), ReformulationGovernment-supported, conducted after 3 years, conducted by Observatory of Nutritional Food Quality.Planned to review as part of evaluation frameworkWritten requests for action, suspending or revoking right to use logo, legal action to protect trademark misuse
Healthier Choice Logo
Malaysia (2017)
GovernmentMultistakeholder collaboration, input from Choices ProgrammeAdapted from Choices Programme developed by independent expert groupGovernment (Ministry of Health)Uptake (list of products available on government website)Criteria reviewed ‘from time to time’Licensing, audits, withdrawal of approval, other legal remedies
Healthier Choice Symbol
Brunei (2017)
GovernmentGovernment, adapted from Singapore’s Healthier Choice Logo and WHO criteriaGovernment (Ministry of Health)Uptake, surveillance of labels in supermarketsLicensing, written requests for amendment
Stop Sign Labels
Uruguay (2018)
Government, multisectoral engagementLegislative process, international expert input, public consultationGovernment, modifying the Pan American Health Organisation Nutrient Profile ModelGovernment (Ministry of Public Health)Stated but detail not availableLegal remedies under Law of Public Health
Good Food Logo
Zambia (2018)
MultistakeholderMultistakeholder with experts from government, nutritionists, academics, scientists with input from private sectorGovernment
  • Notes: Blank cells indicate no relevant information was identified; N/A indicates metric not applicable for example, non-interpretive labels do not employ nutrient criteria.

  • FOP, front-of-pack.