approaches

water after wastewater treatments (Lange, Scheurer, and Brauch 2012). The dearth of information on their use (both types and amounts) in the Saudi and global food supply means that it is challenging to study these questions. As part of regulation SFDA.FD 2233:2018, Saudi Arabia requires the listing of NSS and their amounts (milligrams per liter or milligrams per kilogram of the product) (GSO 2018). This will create a useful start for monitoring the presence and amount of NSS in Saudi food purchases and diets. Careful assessment of whether manufacturers or distributors are indeed complying with this regulation is greatly needed.

Deciding which food groups to include in the NPM

The criteria underpinning an NPM can be applied indiscriminately, using the same criteria, across all major foods; alternatively, they can differentiate between food categories, using a different set of criteria for different individual food groups. This allows for either comparison across different food categories or comparison within food categories (WHO 2019). As noted, the WHO EMRO NPM for restricting marketing to children has 18 food categories with different nutrients and threshold criteria, while the NPMs for the SFDA voluntary MTL and Saudi NNC NPM simply categorize products or foods versus beverages and apply the same set of nutrient thresholds. Similarly, other locations with NPMs applied for mandatory policies have used across-category criteria for solids/foods or liquids/beverages based on reconstituted values (typically only with water, which adds weight or volume but no other nutrients). If the SFDA approach of an across-category criteria is applied to mandatory policies, then implementation, monitoring, and enforcement will be much less complicated for the food and beverage industry to implement and regulatory agencies to monitor and enforce. See table 8.2 for a summary of pros and cons of these different approaches.

TABLE 8.2 Pros and cons of the category-specific and across-category approaches

CRITERIA

Category-specific criteria

PROS

• Criteria can be informed by the nutritional content of existing foods in the category. • Provides leeway for the food industry to manipulate within category (e.g., cutoff may be higher for inherently high-sodium foods—although the sodium still poses a health risk). • Numerous categories with different thresholds make it difficult for regulators to implement.

Across-category criteria • Establish consistent criteria (e.g., for all foods and beverages) • Simple to implement, not resource intensive • Limits the risk of misinterpretation or incorrect classification • Reformulation may be muted within a category if changes are needed for most of the foods in that category. • All foods are treated in the same way, regardless of their inherent nutrient composition.

CONS

Determining applicability across the food supply

From an implementation perspective, since nutrition information panels are readily available on packaged but not on fresh foods or prepared foods, it will be challenging to apply the NPM beyond packaged foods and beverages at this time. The current ability to apply the NPM only to packaged foods and beverages is in line with recommendations to limit the intake of ultraprocessed foods, which are predominately packaged. Nonetheless, this current limited scope should not prevent future efforts to consider expanding the application of NPMs to food service—for example, if reporting the relevant nutrient information becomes required. An NPM should be able to be applied to most food and beverage categories within the marketplace. The more broadly it is applied, the more public awareness is increased and the greater the success of the food policy it is underpinning (WHO 2019). Conversely, it is not advised to use the NPM for the following:

• Infant formula. Breastmilk is the gold standard for infant feeding. There are strict criteria that infant formula has to meet (WHO 2019). • Food for special medical purposes. Food for medical purposes has strict criteria and serves a special medical purpose; these foods are not appropriate to include in the NPM. • Foods that meet specific Codex Alimentarius guidelines. Foods with a package surface area of less than 10 square centimeters are exempt from mandatory food labels. As these foods do not contain nutrition information panels, which is necessary for the application of the NPM, they can be excluded from the

NPM criteria.

Choosing the values and validation of proposed NPMs

As discussed in previous sections, the most appropriate and relevant nutrient cutoffs must take into consideration that the purpose of the NPM is to underpin mandatory food policy regulation in Saudi Arabia. Thus, the NPM will use a negative approach: to discourage the consumption of foods containing high concentrations of nutrients or food components that are harmful to health. A cutoff-based, across-category model—using a “per 100 g” or “per 100 ml” base starting with packaged foods and beverages—is most appropriate for Saudi Arabia given existing labeling requirements. Nutrients or food components of concern that have been identified for inclusion in the NPM include saturated fat, trans fat, sodium, total sugar, and NSS (with calories as an option to consider including). Finally, a suitable NPM can be adapted rather than developing a new NPM.

Based on the considerations presented, there are two options for the Saudi context. The first option is to build a score-based NPM such as the one used in the United Kingdom for its marketing regulations, given that Saudi Arabia also already adapted the United Kingdom’s approach for MTL on its package fronts. As noted, the focus should be on nutrients to be discouraged. The United Kingdom’s NPM for marketing regulations include saturated fats, total sugar, sodium, and calories, with points associated with each nutrient based on its value as shown in table 8.3. Each product is thus scored to obtain a total “A” points. Food scoring four or more points, and drinks scoring one or more points, are classified as “less healthy” and are subject to the UK’s Office of Communication’s controls of advertising of “less healthy” foods to children on