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14 September 2023
Five reasons to support draft Labelling Regulations R3337
South Africa’s Minister of Health Joe Phaahla recently granted an extension for submissions on the draft regulations relating to the Advertising and Labelling of Foodstuffs (Labelling Regulations R3337). The extension is until 21 September 2023.

Two researchers at the DSI-NRF Centre of Excellence in Food Security (CoE-FS), hosted by the University of the Western Cape (UWC) and co-hosted by the University of Pretoria, were instrumental in providing evidence to inform the proposed regulations.
Prof Rina Swart

Professor Rina Swart is a principal investigator and nutrition lead at the CoE-FS, and Dr Tamryn Frank is a former grantee of the CoE-FS. Both are based at UWC’s Faculty of Community and Health Sciences.

Along with the University of Limpopo’s Makoma Bopape and the University of Witwatersrand’s Dr Safura Abdool-Karim, they formed a research working group that developed and tested the front-of-pack warning label (FOPL).

The research working group operated with oversight and guidance from an independent advisory committee, made up of experts in nutrition, health, communication and behavioural sciences.

The brief for the research working group was to:
  • Identify nutrients of concern
  • Develop a nutrient profile model to identify packaged food products excessive in nutrients of concern
  • Develop an FOPL that will inform consumers (including those with low literacy levels) of packaged food products that contain excessive levels of nutrients of concern
  • Test the effectiveness of the FOPL among a representative sample of South Africans.
The National Department of Health’s (NDOH) Food Control department used the working group’s evidence to inform the proposed regulations on FOPL in the draft Labelling Regulations R3337.

Public health benefits

Asked what the benefits will be with the implementation of the proposed regulations, Professor Swart listed numerous advantages for public health.

Firstly, it will provide consumers with information on the manufacturer of food products, the ingredients present in each food product and information on the safety of food products, for example, best-before dates.

Secondly, said Professor Swart, the proposed FOPL warning label will appear on the front of packaged food products so that, with just a quick glance, consumers will know if the product contains excessive amounts of the nutrients of concern.

“Previously, identification of this required reading, interpreting and understanding of the nutrition information on the back of pack which is usually in very small print and uses difficult to understand scientific terminology,” said the CoE-FS nutrition lead.

The third benefit is that if products contain excessive amounts of nutrients of concern, the product may not carry health or nutrition claims. This avoids causing confusion for the consumer who must decide if the claimed health or nutrition benefits are more important than the excessive levels of nutrients of concern.

Fourth, if products contain excessive amounts of nutrients of concern, children (0-18 years) will be protected from aggressive marketing of these products.

And the fifth benefit provided by Professor Swart is that it is hoped that the regulations will also encourage producers to create food products that are not excessive in nutrients of concern and, therefore, the food supply which consumers choose from will become healthier.

Healthier food environment

Dr Frank, whose PhD research included the development of the nutrient profiling model used to underpin the FOPL and was funded by the International Development Research Centre (via the CoE-FS), echoed Professor Swart’s sentiments.

“These regulations pave the way for the government to create a healthier food environment in South Africa.”

Dr Frank added that, according to the newly published World Health Organization’s (WHO) guideline on Policies to protect children from the harmful impact of food marketing, mandatory, government-led marketing regulations are important to protect children from pervasive food marketing techniques used by the food industry.

“Food marketing is associated with increased choice and consumption of the marketed product, which are usually unhealthy products high in sugar, salt or saturated fat,” said Frank.

In addition to marketing restrictions, the warning labels will also create space for more comprehensive regulation of unhealthy foods in the future.

“For instance, foods with warning labels could be restricted in the school food environment (e.g., not sold at tuckshops, not procured for school events, not be allowed to be bought onto the school premises in lunchboxes, etc.) and restricted from other government institutions such as hospitals.

“The warning labels could also be used to identify unhealthy foods that should be taxed, such as is currently done through the Health Promotion Levy for sugary beverages in South Africa,” she said.

As per the government gazette, “interested persons are invited to submit any substantiated comments or representations on the proposed regulations, to the Director-General of Health, Private Bag X828, Pretoria, 0001 (for the attention of the Director: Food Control), by email to on or before 21 September 2023.