Great Italian Food Trade examined the labels of historic Galatine candies, inferring their deceptiveness in the claim of equivalence between the ingredient milk powder and fresh pasteurized milk, as well as in the reference to ‘only natural ingredients. The issue is framed within the framework of so-called milk sounding, and has been submitted to the IAP (Institute for Advertising Self-Discipline).
Galatines bear the designation ‘milk powder tablets. The amount of this ingredient-according to the label-varies between 40 percent (basic version, Milk), 39 percent (Strawberry Galatine) and 33 percent (Chocolate Galatine). Nevertheless, in defiance of all mathematical rules, in all three cases an equivalence of the different amounts of milk powder ‘to 80 percent fresh pasteurized milk’ is boasted on the front of the label. (1)
It is arduous to understand the composition of the candies, in the face of the ‘80% milk’ label, with particular regard to nutritional and quantitative profiles. How is it possible that quotas of milk powder that vary by more than 20 percent (between the basic product and the chocolate product) are matched only by an 80 percent equivalence of fresh milk? And to which fresh milk-whether whole, semi-skimmed or skimmed-would the equivalence refer?
Equivalence to fresh milk?
From a nutritional point of view, even if one were to assume that the milk intake of the candies actually corresponded to 80% fresh ‘skimmed’ pasteurized milk only (thus 80g per 100g of product), the total carbohydrate and related sugars provided by the ingredient ‘milk’ to Galatines would have to be 4.2 g per 100 g. (2) In contrast, the nutrition statement for Galatine Latte reports values of 78g of carbohydrates per 100g of product, including 69g of sugars. Thus, the nature of the product is quite different from what is represented.
‘Marketing communication must avoid any statement or representation that is likely to mislead consumers, including by omissions, ambiguities, or exaggerations that are not overtly hyperbolic, especially with regard to the characteristics and effects of the product’
(Advertising Self-Discipline Code, Article 2)
Paradoxically, following the manufacturer’s directions to the letter, 2 packages of Galatine Latte would be equivalent to the 200 ml of milk that the Ministry of Health recommends consuming every day (!). It’s just a pity that 2 packages of candies contribute more than 120g of sugar, which is more than 130% of the daily intake recommended (90g) by the European legislator, on the recommendation of Efsa. (3) already mentioned several times the consumer would bring to their average diet (about 2000kcal).
This is a deceptive, misleading, and miseducational communication, on par with that in which a glass of fruit juice is compared to the consumption of fruit and vegetable rations recommended in nutritional guidelines. With a detrimental effect especially in those segments of the population that-because of their young or late age-have the greatest need for unambiguous and consistent news about what diet to follow.
Good and natural ingredients?
In spite of the promised prevalence of milk (80 percent, or four out of five parts), the significant ingredients in Galatine Latte-over 55 percent-are sugar and glucose syrup. Which by the way can hardly be qualified as‘good and natural ingredients,’ of which it is also boasted on the back of the package. It is indeed well known that the technology required to transform beet into sucrose requires chemical and physical processes of a certain complexity, far removed from the concept of ‘naturalness’. (4)
‘Natural means a product that exists or is composed of naturally occurring ingredients, derived by traditional processes or otherwise minimally processed i.e. without human intervention, chemical or extraction processes, additives or flavoring substances added’
(Food Standards Agency, UK)
Responsibility
EU Regulation 1169/11 – On consumer information on food products – prescribes that ”Food information is accurate, clear and easily understood by the consumer‘ e ‘do not mislead, in particular: a) as to the characteristics of the food and, in particular, the nature, identity, properties, composition, quantity,(…)’ or ‘b) by attributing to the food effects or properties that it does not possess‘ (…). (5)
The Consumer Code (6) and the Code of Advertising Self-Discipline (7) in turn establish criteria of fairness, completeness and clarity to which commercial communication must be held. With special attention to food products, and the ways in which various news items-mandatory and voluntary-are represented figuratively. With the specific intent of assessing the effect of the overall information on the average consumer.
‘Cloetta’s vision is to become the most admired company (…) especially for the responsible way we relate to the world around us. All Cloetta employees share responsibility for behavior toward our customers, consumers, owners, suppliers and co-workers. We, as a company, must always act by showing that we deserve the trust and appreciation of our stakeholders.’
(The words of CEO Bengt Baron, Cloetta, Code of Conduct)
Deceptive advertising to be eliminated
Great Italian Food Trade decided to report this case to the Advertising Self-Discipline Institute, whose intervention effectiveness has already been highlighted. (8) With the aim of having the above commercial information, the serious misleadingness of which precisely is inferred, cease as soon as possible.
Galatine is a historic Italian brand, registered back in 1956 by Polenghi Lombardo S.p.A., which later sold it to Sperlari (now of the Swedish Cloetta group). A valuable candy from a symbolic point of view above all, as it is promoted by recalling the value of milk rather than being proposed as a substitute for it. And that is how it must return, putting aside misleading and diseducational messages.
In defiance of the criteria of social responsibility stated by Cloetta (owner of the Sperlari brand and the candies in question), which ‘is committed to adopting communication that (…) enables consumers to make informed purchases and, in particular, recognizes that children possess a more limited capacity to evaluate advertising information.’ In characteristic Scandinaviangreenwashing style.
Dario Dongo
Notes
(1)‘Fresh pasteurized milk’ is defined as milk which arrives raw at the packing plant and which, having undergone a single heat treatment there within 48 hours of milking, is present for consumption;
(a) negative alkaline phosphatase test.
(b) an undenatured soluble serum protein content of not less than 14 percent of total protein;
(c) positive peroxidase test. (…)’ (Law 3.5.89 No. 169, Regulation of the processing and marketing of cow’s drinking milk)
(2) Source: food composition tables published by the CREA Food and Nutrition Research Center.
(3) See reg. EU 1169/11, Food Information Regulation, Annex XIII
(4) concept of ‘natural ingredient’ is explained accurately in the Food Standards Agency (UK) Guidelines, at https://www.food.gov.uk/northern-ireland/niregulation/niguidancenotes/fresh-pure-natural-ni
(5) Reg. EU 1169/11, Article 7. This regulation is unfortunately still lacking in Italy in the form of an appropriate penalty regulation https://www.greatitalianfoodtrade.it/etichette/impunità-e-negligenza-il-governo-italiano-omette-le-sanzioni-sul-reg-ue-1169-11. Although the most serious violations may already garner the attention of the criminal judiciary
(6) Legislative Decree. 6.9.05, n. 206
(7) Advertising Self-Discipline Code, Articles 2 and 15.
(8) See eBook ‘The Label’ (Dario Dongo, il Fatto Alimentare, Milan, 2011)
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
