Binnie Poponne
Nutrition Division
Food Standards Agency
Room 808c Aviation House
125 Kingswav
London WC2B 6NH

Dear Binnie

Waitrose welcome the opportunity to comment on the proposed target levels of salt in key food categories issued on the 1st August 2005. We are fully supportive of helping the Government achieve the average population salt intake of 6g day by 2010. To that effect Waitrose put in place a 5 year programme for salt reduction across own label products which was instigated in 2004. Waitrose have made good progress in the last 18 months and in some categories we are near to achieving the FSA target ahead of 2010. We have agreed to report annually to the FSA regarding progress.

Your consultation specifically requests comments on the following:

Categories and sub categories

In general the sub category targets are useful and help to differentiate between recipe variants. For example pizza (9) with higher salt toppings (9.1) and sandwiches (12) with higher salt fillings (12.1) have higher targets. The sub category targets for ready meals (7) recipe variants are also helpful. However for baked beans (6) and baked with accompaniments (6.2) the target is the same which is probably not achievable given that accompaniments are likely to be sausages, cheese or meat balls. Therefore we would urge for a elevated target for this sub category. Whilst there are clear differences between biscuits (15), sweet & savoury there is no target differentiator between filled (15.3/15.4) and unfilled (15.1/15/3) and therefore it would make sense to group these together. In fact should sweet biscuits (15.3) actually read (15.2).

The targets for take away, meat based (28), fish based (29) and vegetable based (30) dishes appear to be much lower than those set for ready meals (7), despite including reference to ready meals. Therefore, I would recommend merging under the ready meal category (7).

It would make sense to class pastries (11.3) and fruit pies (11.4) as one category as the have the same target. Croissants are listed under morning goods (2.3 ) and under pastries (11.3) with different targets, clearly morning goods (2.3) is the healthier place.

Under processed puddings (19.1) cheese cake requires a higher target to take account of the cream cheese and it may be better to give this a sub category under fresh cheese (4.4). In fact categorising all puddings together is problematic as there is wide recipe variation so you may wish to consider a sub category for this group.

If flans are excluded under Quiche (20.1) where are they identified? Would this category not suffice?

The meat products (1) and the associated sub categories are now well defined and we welcome the raised targets for ham and cured meats (1.2) cooked uncured meats (1.5) and bacon (1.1).

Whilst in general Waitrose welcome the clarity on some categories and the more realistic targets, we had hoped that this consultation might result in fewer categories to enable more targeted focus whereas in reality it has resulted in more categories/sub categories than the original salt model.

Maximum and average targets

The approach on maximum targets for some categories and average targets for other categories is welcomed and seems sensible especially in categories such as breakfast cereals (3), ready rneals (7) and pizzas (9) where individual recipes can bring wide variation. Clarification on why butter (5.1) are set to a average whereas margarines and spreads (5.2) are set to a maximum would be welcomed especially in the light of the need to reduce saturated fat levels in the UK population. The concept of setting maximum targets when you have agreed to averages seems unnecessary as an average value takes account of total number with a range of values.

Additional costs

The Waitrose 5 year programme has been developed to keep costs to a minimum especially with respect to new packaging generation. The situation does arise where salt reductions have been actioned for specific categories but where we continue to use existing packaging to keep cost for suppliers and customers to a minimum, this effectively means that we over declare sodium be it on a relatively small percentage of lines. Where we undertake successive reductions in fast moving categories such as chilled ready meals the generation of new packaging can be problematic and equally the case on slower moving lines such as biscuits where we may only originate packing on an infrequent basis. Waitrose focus remains on ensuring that all packaging is accurate and meets current legislation requirements.

Self reporting and monitoring

Self reporting remains the best way to inform both the customer and the Agency about the progress made on salt reduction. This allows us to communicate with our customers as and when we feel appropriate and to tailor the overall salt reduction programme to meet business needs. Independent surveys are a reasonable way to establish salt va!ues at a specific point in time but can never reflect the work that may have been undertaken behind the scenes.

Whilst we can appreciate that the FSA may favour an industry agreed way of reporting many organisations have their own internal monitoring systems and it would be best if the FSA are willing to accept a variety of self reporting methods. Average salt values might best he reflected as number of lines with minimum and maximum values i.e. range.

Interim population targets

Waitrose have fully adopted the voluntary use of Guideline Daily Amounts on packs e.g. 6g/day salt for adults. The introduction of an interim population target could lead to consumer confusion and as such we would not support this approach. However, the process of monitoring population averages and intakes is important as a key indicator of progress and ultimately success. This type of monitoring would need to he conducted by the Government and is perhaps best drawn from the National Diet and Nutrition Survey, the Health Survey for England (and equivalent reports for Wales, Scotland and Northern Ireland) and the combined National Food Survey and Food Expenditure Survey.

We look forward to the final targets being published on the completion of this consultation and trust that our comments are noted.

Yours sincerely

Moira Howie
Nutrition Manager
Cc Mary Vizoso - Head of Food Technology

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