In December 2023, CARICOM member states voted a second time at the Caricom Regional Organization for Standards and Quality (CROSQ) on the Draft Regional Standard for the Labeling of Prepackaged Foods. The proposed standard in question contains a proposal to adopt the High-In Octagonal Warning Label (OWL) as the recognized Front of Package Nutritional Label (FOPNL) for the region. Over the past 5 years, the private sector organizations throughout the region have been at odds with public health organizations on the effectiveness of the OWL and its suitability as an appropriate standard for a region that imports a significant portion of the goods it consumes from countries that do not produce goods with the OWL. At the December 2023 voting, the Draft Standard failed to garner the 75% of votes in favor for the standard to be adopted, making it the second time the Standard failed to meet the requirement for adoption. 

More than Just a Labeling Issue

The Draft Standard itself contains requirements relating to several aspects of pre-packaged food labels such as the name of the food, net weight, list of ingredients and country of origin. Annex E of the draft sets out the OWL as the option for the regional FOPNL standard. The OWL is a labeling variant that contains a black octagon typically with the wording “High In” followed by the nutrient found to be in excess. It is mandatory in countries like  Mexico or Chile and you would notice that most products on store shelves have the OWL on their prepackaged foods. 

It is Annex E that has caused the years of debates between the regional private sector and advocates for the OWL. Advocates for the OWL believe it to be the best FOPNL option for the region and rely heavily on studies in Brazil, Mexico and Chile that demonstrate its effectiveness in informing consumers to make healthier choices. The regional private sector has argued that requiring the OWL to be present on all prepackaged goods could introduce additional costs for consumers of these goods, since labels on imported products would have to be placed by the distributors in the Member State. The reason behind this lies in fact that CARICOM imports upwards of 80% of the goods that the region consumes and larger manufacturers would not be willing to adjust their labeling to cater for the small Caribbean market. Instead, the regional private sector has advocated for the adoption and recognition of multiple FOPNL schemes that are most commonly found on goods originating from the US or EU in addition to the OWL. Using this approach, the region could then focus on educating populations on how to interpret the labels without risking inflationary pressures through using one FOPNL model. 

In 2022, a Caribbean Impact Assessment commissioned by the Caribbean Private Sector Organization (CPSO) found that the OWL was not the best performing FOPNL model when tested against other models found in the region such as the Facts Up Front from the United States or the Traffic Light originating from the UK. To date, this is the only regional study conducted on FOPNL and the study has been peer reviewed and published in the medical journal, BMJ. Advocates of the OWL vehemently attacked the study’s credibility, citing conflict of interest and suggested that the peer reviewed study was flawed. 

What Happens Now?

While the debates on the effectiveness of the OWL continue on, CARICOM Member States decided in December 2023 that it is not the FOPNL model it wished to adopt as the regional standard. This left the Technical Committee at CROSQ to decide on the next steps for FOPNL in the Caribbean. The technical committee submitted two options for Member States to consider, one of which is to remove the FOPNL proposal from the draft standard and allow the standard to be adopted and implemented. A separate project would then be undertaken to draft a regional policy for combating non-communicable diseases (NCDs) and a FOPNL model can be chosen via an inclusive, evidence based approach. It was decided among the regional private sector that the option outlined above would be the most sustainable way forward for the region and Member States were given until March 26th to send feedback on the preferred option. 

For now, the FOPNL saga takes a pause until the region puts together a comprehensive plan to address NCDs in the region. The battle against NCDs is a priority for the regional private sector and choosing an effective model is a key element of the plan, but consumer education and promoting the production of healthier options are equally important. The future of CARICOM in reducing NCD levels rests in its ability to adopt a comprehensive strategy that matches the specific circumstances of the region and to have the buy-in of all stakeholders.