STRENGTHS AND LIMITATIONS OF THIS STUDY

First comprehensive market survey covering a large number of products that investigated the prevalence of multiple food product indicators in Malaysia.

Successfully developed a systematic way of assessing the compliance of Healthier Choice Logo Malaysia and nutrition and health claims towards the local standards and their credibility as a healthy food product towards the international standard, that could be adopted by future studies.

Products sampled in this study are not representative of the whole Malaysian market and are limited in terms of food categories.

Compliance of products was not assessed against the latest guidelines which were released later after the study had been done.

Assessment of compliance and credibility of products is limited in terms of the type of food product indicators evaluated and the guidelines used.

Assumes accurate declaration of nutrient content by food companies.

Introduction

Non-communicable diseases accounted for 74% of deaths in Malaysia in 2016 and 35% of deaths caused by non-communicable disease is related to cardiovascular disease.1 Unhealthy diet is the major factor leading to cardiovascular disease.2 Food product indicators, such as those in the form of front-of-pack nutrition labelling (FOPNL) and nutrition and health claims (NHC), may be useful in directing consumers to healthier food options and improving dietary intake in terms of calories, fat, saturated fat, trans fatty acid sugar, sodium, fibre and calcium.3–8 FOPNL displays simplified, point-of-sale nutrition information, often in the form of symbols/graphics, that presents the overall nutritional value of a food product. FOPNL can be further classified into five categories: (1) nutrient-specific non-interpretative label (label that presents nutritional information for specific nutrients but does not provide guidance on the interpretation of healthfulness of the product), (2) nutrient-specific interpretative label (label that presents nutritional information for specific nutrients and provides both positive and negative graded judgement for individual nutritional contents), (3) nutrient-specific warning label (WL) (label that alerts consumers on negative nutritional contents of the product), (4) summary-indicator label (label that provides graded judgement for the overall healthfulness of the product) and (5) endorsement label (label that supports positive judgement for the overall healthfulness of the product which is supported by relevant government or non-government health or nutrition-related organisations).9 Meanwhile, NHC, in the form of text, highlights certain nutritional properties or benefits that a product may have, whether is it lower or higher in certain nutrients or how a certain nutrients or food component benefits the human body, for example, ‘low in sugar’ or ‘beta-glucan helps lower cholesterol’.10 11

FOPNL and NHC may influence the food industry to reformulate their products.12 13 Reformulated products have better nutritional qualities and may lead to the improvement of diet and health of the population.13 14 For example, a lower sodium content is found as the rating of healthy star rating (HSR) increases.15 Studies have shown that FOPNL is effective in guiding consumers to choose healthier food products.3 16 In the absence of FOPNL, consumers fail to identify the healthier product.17 Most people are willing to purchase a product that carries FOPNL even if it costs more.18 19

In an effort to improve diet quality, many countries have come up with their own FOPNL schemes (online supplemental appendix S1). Over the years, an increase in products carrying food indicators has been observed in the USA and the Netherlands.20 21 Malaysia launched the Energy Icon (EI) and Healthier Choice Logo (HCL) in April 2012 and April 2017, respectively, and the number of products carrying HCL has increased by 61.6% from April 2017 to June 2023.22 23 Southeast-Asian countries including Thailand, Indonesia and Singapore also have their version of the healthier choice label. Additionally, Singapore launched the Nutri-Grade label specifically for drinks products in December 2022.24 Other countries’ FOPNL includes Guideline Daily Amounts or Reference Intakes (GDA/RI), Multiple Traffic Light (MTL), HSR, Daily Intake Guide (DIG), Facts-up-Front (FUF), NutrInform Battery (NIB), Nutri Score (NS) and WL.25 26 It should be borne in mind that not all FOPNL are equally effective. Nutrient-specific non-interpretative label, such as the GDA/RI and NIB, might be confusing especially to those with low literacy and from low socioeconomic groups.27 Meanwhile, nutrient-specific WL such as the WL is more clear-cut for consumers to understand.28 Summary indicator label such as the NS is found to be effective at helping consumers to identify the healthier food products as compared with non-interpretative label.26 Endorsement labels such as the HCL for Malaysia were not received well among consumers who wish to restrict certain nutrients, as the label did not specify in what aspect is the product considered a healthier choice.29

Food product indicators may also cause confusion among consumers or induce the halo effect. Two studies suggested that the presence of FOPNL may help to reduce the cognitive bias, misinterpretation and halo effect caused by NHC.30 31 On the other hand, some studies found that FOPNL may cause confusion and mistrust among consumers when discretionary foods like snacks, bakery goods, sugar-free confectioneries and processed foods display a higher HSR rating.32 33 In the presence of NHC, consumers may perceive that the serving size for a product carrying NHC is larger, and its calorie content is lower, which may encourage overconsumption.34 Consumers may also perceive a food product carrying NHC that is inherently ‘unhealthy’ as ‘healthy’.35–39 This may lead consumers to choose an unhealthy food product.40 Some consumers remain sceptic when NHC appears on inherently unhealthy food products.41 A study done in Mongolia found only 54.2% of products bearing nutrition claims and 40.5% of products bearing health claims were deemed as ‘healthy’ after assessing the healthiness of the products with the WHO Nutrient Profile Model.42 However, this study did not evaluate the compliance of products carrying NHC towards local standards. Such a study conducted in Spain found that only 49% of products were compliant with the European Regulation No 1924/2006.43

While imported products typically require relabelling for sale in other countries, Malaysian retail environments may feature foreign FOPNL schemes like Nutri-Grade and HCS from Singapore, alongside Malaysia’s own FOPNL scheme. Due to the diverse retail environment, data regarding the prevalence of food product indicators and healthy food products are very limited. Thus, this study aimed to, first, determine the prevalence of food products carrying food product indicators categorised as FOPNL such as the HCL, MTL, HCS and so on, and those categorised as claims including NHC and other claims; second, to examine the compliance of those products carrying HCL (MY) and NHC against the local regulations; third, to assess the credibility of products carrying HCL (MY) and NHC as a healthy food product based on the World Health Organization’s Nutrient Profile Model for the Western Pacific Region (WHO NPM WPR). The findings of this study would help to encourage the refinement and enforcement of local food indicators labelling.

Materials and methodsStudy design and data collection

The study was collected at three top major supermarkets in the Klang Valley of Malaysia between February and May 2023.44 45 Data were collected by two trained dietetics interns. They visited site A (Aeon at Taman Maluri Shopping Centre) for a month during weekdays (Monday–Friday) from 10:00. to 17:00 hours and captured the front, sides and back of the food product packaging from the shelves. Data collection was then carried out at site B (Cold Storage Kuala Lumpur City Centre) for another month. At site B, only those products that have not been captured at site A were captured. Following site B, only products not captured at site A and B were captured at site C. Both sites B and C were visited during weekends (Saturday and Sunday) from 10:00 to 17:00 hours, for 4 weekends per site. The photos captured using mobile phones were uploaded to Google Drive for further extraction of details of the product information including product brand, product name, product category, type of food product indicators carried, nutrition information panel (NIP), ingredients list and whether the product is manufactured locally or imported (figure 1). When there were unclear photos or missing figures, data were obtained from the product’s website. In cases in which missing data could not be retrieved online, the researchers revisited the supermarkets to retake the photos. Information collected in the photos was then extracted for entry in Microsoft Excel. In order to increase the reliability of the data, the lead author checked the accuracy of data entry against the photos of the product’s NIP on 5% of the entries. 172 numbers were randomly generated by online number generator that corresponds to a numbered row that contains the information of a food product in the Microsoft Excel sheet. Upon verification, the percentage of accuracy was 96.5% and the incorrect entries were corrected.

Figure 1

Flow chart of study. HCL, Healthier Choice Logo; NHC, nutrition and health claims; WHO WPR NPM, World Health Organization’s Western Pacific Region’s Nutrient Profile Model

Patient and public involvement

None.

Inclusion and exclusion criteria

Three supermarkets from the list of top 10 major supermarkets in Malaysia46 were selected to collect data, which were Aeon at Taman Maluri Shopping Centre, Lotus’s Mutiara Damansara and Cold Storage Kuala Lumpur City Centre. Selection of the supermarkets was done considering the market share of the retail company, marketing positioning of the retail chain, as well as the accessibility of the supermarkets. Aeon and Lotus are 2 economic retail brands that own over 60 stores throughout Malaysia. Cold Storage is positioned as an upscale supermarket operated by Malaysia’s largest food retailer.47 48

Inclusion criteria included products listed in food product categories and subcategories classified by the Nutritional Guidelines on Nutrient Criteria for HCL Malaysia as of February 202349 (online supplemental appendix S2). Products that were unprocessed or minimally processed such as fresh produce, raw eggs, raw meat and seafood, alcohols, supplement food, special diet products for medical conditions, diet products for slimming purposes, baby formula and complementary food for babies and toddlers were excluded from this study.

Assessment of compliance towards HCL Malaysia

Compliance of products carrying HCL Malaysia was assessed based on their adherence towards the nutrient criteria, statement requirement and validity of certification. There are no specific recipes that a product must follow in order to qualify for the HCL application. The validity of certification of the products bearing HCL Malaysia was assessed according to the certification status on the official website for HCL Malaysia.50 Statement compliance was assessed based on the presence of a statement indicating that the product is only a healthier option when compared with products of the same category, on products other than fresh milk and drinking/mineral water, as per stated in the Nutritional Guidelines on Nutrient Criteria for HCL as of February 2023.49 Nutrient compliance of the products carrying HCL Malaysia was also assessed against the aforementioned guideline.49 All target nutrients are listed in online supplemental table S1 under HCL (MY). However, the respective target nutrients vary for each subcategory. For example, percentage of wholegrains is targeted for plain meal/oatmeal and breakfast cereal products; probiotic is only targeted for fermented or cultured milk products. Apart from adhering to the thresholds for key nutrients, the products are also required to meet the minimum thresholds for additional nutrients. Additional nutrients are mandatory to be declared in the NIP.51 Thus, if a required nutrient is not declared on the product, it is taken as incorrect in this study. According to the total number of nutrient requirements for each food category, a product was rated ‘5’ or ‘excellent’ in terms of nutrient compliance if 100% of the nutrients required were met; ‘4’ or ‘good’ for 75%–99%; ‘3’ or ‘moderate’ for 50%–74%; ‘2’ or ‘weak’ for 25%–49% and ‘1’ or ‘very weak’ for 0%–24%. For example, if the nutritional guideline requires 10 nutrients to be met for a product, and an assessment of the nutrition information of the product meets the minimum or maximum value for all 10 nutrients (100%), the product will be rated as ‘excellent’ compliance; if only 8 out of 10 nutrients meets the requirements (80%), the product will be rated as ‘good’ compliance in terms of nutrient compliance. A compliant product bearing HCL, for instance, would have a ‘compared within [product category] only’, declared all the required nutrients and adhere to the thresholds of both nutrients to limit and nutrients to encourage, as well as having a valid certification listed on the official HCL website.

Assessment of compliance towards NHC

For products bearing NHC, compliance was evaluated using a points system by referring to the Guide to Nutrition Labelling and Claims as at December 2010.52 Compliance for NHC is defined as adherence towards the nutrient criteria and other conditions required by the local regulation. With regard to the assessment of each type of nutrition claim (online supplemental appendices S3–S7), the assessment was done sequentially. When the product is given ‘0’ point for the particular aspect or step, the product will not be assessed further for the next aspect and its total points will be the sum of the points scored from the first aspect until the aspect it stops at. According to the guideline, only nutrition claims were allowed and nutrition claims under its definition comprised nutrient content claims, nutrient comparative claims, nutrient function claims and other function claims (function claims), as well as claims for enrichment, fortification or other similar words of similar meaning (enrichment claims). Additionally, the ‘nutritious’ claim was also included in the guideline. However, some guidelines such as the ones by the CODEX Alimentarius and European Commission classified nutrient function claims and other function claims under ‘health claims’.53 54 In order to be consistent, the umbrella term ‘nutrition claims’ in this study covers nutrient content claims, nutrient comparative claims, enrichment claims and ‘nutritious’ claims; while function claims would be classified under ‘health claims’. Although reduction of disease risk claim is allowed by the CODEX Alimentarius53 and other countries’ guidelines,55 56 it is classified as a ‘prohibited’ claim under the Malaysian guideline (online supplemental appendices S8 and S9).

Nutrient content claims, nutrient comparative claims and claims for enrichment, fortification or other similar words of similar meaning, that claimed on nutrients not covered in the guideline and have the claimed nutrient declared, such as potassium, chromium and chloride were classified as unregulated claims. In the case in which the claimed nutrient was not declared although it was not covered in the guideline, zero points would be given to the nutrient compliance aspect. When a product made a general claim, for example, ‘high in/ enriched with seven vitamins and minerals’, the product would be rated excellent if seven out of seven (100%) vitamins and minerals (excluding sodium) met the requirements to be claimed as ‘high in’ or ‘enriched with’. In cases in which there were vitamins or minerals not covered by the Malaysian guideline, for example, out of the seven vitamins and minerals, two were potassium and chromium, then, the nutrient content claim for potassium and chromium would be shifted to ‘unregulated claims’, and the percentage nutrient compliance would be assessed out of five nutrients. The product would be rated as ‘excellent’ if five out of five nutrient requirements were adhered to, although the claim stated seven vitamins and minerals.

For function statements for nutrient function claims and other function claims, each function statement was considered as one claim. If a product made a grouped nutrient function claim, for example, ‘calcium, vitamin A and magnesium help maintain strong bones’, zero points would be given to the function statement aspect as vitamin A has no permitted function claims in terms of bone health and secondary function to support bone health such as calcium absorption or phosphorus utilisation, according to the Malaysian guideline. If a product made a grouped claim, for example, ‘calcium and vitamin D for bone health’, one point would be given to the function statement aspect as the permitted function for vitamin D stated in the guideline was a secondary function that promotes bone formation (vitamin D helps the body use calcium and phosphorus). For a function statement that was considered logical but not covered in the guidelines, for example, ‘dietary fibre supports digestive health’, the function claim would be classified as an ‘unregulated claim’. For a function statement that is irrational or cannot be substantiated, for example, ‘X helps discharge toxins’, the claim would be classified as ‘prohibited claim’ as stated in the guideline.

After assessing the compliance for each claim of a product, overall NHC compliance of the product was obtained by averaging the sum of the ratings over the total number of nutrition claims claimed by the product. Average value of 5 is classified as ‘excellent’ overall nutrition claims compliance; average value of 4–4.9 is classified as ‘good’; 3–3.9 as ‘moderate’; 2–2.9 as ‘weak’ and 1–1.9 as ‘very weak’. For example, if a product has two nutrient content claims rated ‘5’ (excellent) and ‘4’ (good), the overall nutrition claims compliance of the product would be 4.5 which means good overall compliance.

Summary of classification of food product indicators included in this study

Food product indicators in this study included three subcategories, namely FOPNL, NHC and other claims.

As introduced earlier, FOPNL could be further classified as nutrient-specific non-interpretative label, nutrient-specific interpretative label, summary indicator label, endorsement label and nutrient-specific WL. Nutrient-specific non-interpretative labels in this study included GDA/RI (Europe and Thailand), EI, FUF, DIG and industry’s own non-interpretative labels. Industry’s own non-interpretative labels highlighted specific nutrient content of the products on the front-of-pack in grammage but did not compare the value to any reference intakes. (figure 2) Meanwhile, nutrient-specific interpretative label included in this study was MTL. HSR and NG were two summary indicator labels included in this study. Endorsement labels covered in this study included HCL of Malaysia, Indonesia and Thailand, HCS of Singapore, American Heart Association-endorsed, Portugal Foundation of Cardiology-endorsed, Australian Heart Foundation-endorsed and Sugar Wise, Of these labels, only GDA/RI of Thailand and NG (on beverages rated C and below) are mandatory.

Figure 2

Example of industry’s own nutrient-specific non-interpretative label.

NHC in this study included nutrient content claims (claims stating that a product is high or low in specific nutrients), nutrient comparative claims (claims stating that a product is higher or lower in specific nutrients than another product), claims for enrichment, fortification or other similar words of similar meaning (claims stating that a product is fortified, added or enriched with certain nutrients), ‘nutritious’ claims (claims stating that a product provides energy, protein, minerals and vitamins), nutrient function and other function claims (claims stating that a product contains certain nutrients that is beneficial to the physiology of body) (online supplemental appendix S8).52

Other claims in this study comprised ‘low in X’ health claims, environmental claims, unregulated claims, puffery or vague claims, ingredient claims and prohibited claims. ‘Low in X’ health claims are claims that state a product is low in certain nutrient, such as cholesterol, saturated fat or sodium, which reduced consumption of that nutrient benefits the physiology of the human body. Environmental claims are those claims relating to the term genetically modified organism. Unregulated claims cover those nutrients not stated in the local regulations used in this study, for nutrient content and nutrient function claims. Puffery or vague claims are unclear claims such as ‘calorie killer’. Ingredient claims are claims that state the addition or non-addition of certain substances in the production of the product, such as ‘no added salt’. Prohibited claims under the local regulation,52 include claims stating that any particular food will provide an adequate source of all essential nutrients; claims implying that a balanced diet or a combination of a variety of foods cannot supply adequate amounts of all nutrients; claims that cannot be substantiated; claims suggesting that a food can prevent, alleviate, treat or cure a disease, disorder or other physiological function; claims that cause the consumer to doubt the safety of similar food; claims that arouse or exploit fear in the consumer and disease risk reduction claim. For example, ‘the fruit, which is effective in discharging the harmful substances from the body, accelerates the blood flow as well and this ensures the skin seems smooth and healthy’ is a prohibited claim. More examples can be found in online supplemental appendix S9.

Assessment of credibility as a healthy food product

In this study, credibility is defined as the healthiness of a food product classified by the percentage of nutrients that meet the thresholds for nutrients criteria of the WHO NPM WPR. The nutrient content of the subsample (products bearing HCL and/or NHC) were compared against nutrient criteria of the WHO NPM WPR for total fat, saturated fat, total sugars, added sugars, non-sugar sweetener, sodium and energy,57 in which all or 100% nutrients criteria met are deemed absolutely credible as a healthy food; 75%–99% as ‘credible’; 50%–74% as ‘somewhat credible’; 25%–49% as ‘less credible’ and 0%–24% as ‘not at all credible’. Unlike the HCL Malaysia model, the WHO model excludes the following inherently unhealthy food products categories (category 1—chocolate and sugar confectionery, energy bars and sweet toppings and desserts; category 2—cakes, sweet biscuits and pastries and sweet bakery products and category 4c—energy drinks, tea and coffee). Moreover, HCL Malaysia only indicates that a product is healthier within its category only.51 Thus, it would be more sensible to apply the WHO model in determining the credibility of food product as a healthy food.

Statistical analyses

Data were analysed by using SPSS V.26.0. Descriptive analysis was done to determine the total number and percentages of food products carrying each type of food product indicator, as well as the total number and percentages of compliant food product indicators and the total number and percentages of credible healthy food products.

ResultsFood product indicator

A total of 3428 products were studied, with slightly more than half of them (53%, n=1809) carried at least one type of food product indicator (single or multiple FOPNL, single or multiple NHC, single or multiple ‘other claims’, or combination between FOPNL, NHC and ‘other claims’) (table 1). Top product categories with some form of indicators were cereal, cereal products and flour confection (18%), beverages (14%) and dairy and dairy products (10%). A total of 962 products (28%) were found to carry at least one FOPNL; 1101 products (32%) carried at least one type of NHC; 542 products (16%) carried at least one type of ‘other claims’ (table not shown).

Table 1

Number and percentages of food products having indicator according to food categories

Prevalence of FOPNL and HCL Malaysia’s compliance

The most prevalent type of FOPNL carried by the products was EI, with 487 products carrying it (14%), followed by GDA/RI of both Europe and Thailand origin (7%, n=230) (online supplemental appendix S10). Only 4% products had HCL logo (n=138). With regard to the compliance of products bearing the HCL Malaysia label to the local guidelines,49 almost half of the products carrying HCL Malaysia had excellent nutrient compliance (48%, n=66), followed by moderate nutrient compliance (28%, n=39) and good nutrient compliance (15%, n=21). A total of 9% of the products (n=12) had poor and very poor compliance (table 2).

Table 2

Compliance of food products

The majority of the products complied in terms of statement compliance (99%, n=136). In terms of validity of the certification, more than half of the products were listed on the official website of HCL Malaysia and had valid certification (67%, n=93); 4 out of 138 products (3.0%) were listed on the website but had its certification expired less than 3 months dated back from February 2023; 32 products (23%) had its certification expired more than 3 months dated back from February 2023. Further, 9 products (7%) could not be found on the website and were classified as non-valid in terms of validity of HCL certification (table not shown).

NHC’s prevalence and compliance

Out of 1101 products (32%) that carried at least one NHC, 1070 products (31%) carried at least one nutrition claim and 179 products (5%) carried at least one health claim. Nutrient content claim was the most prevalent type of claim, with 992 products carrying it (29%) (online supplemental appendix S11).

Assessment against the local guideline showed that close to half of the products had excellent overall NHC compliance (47%, n=522), followed by good overall NHC compliance (32%, n=352) and moderate overall NHC compliance (9%, n=95) (table 2). In total, nutrient content claims recorded a total number of 2234 claims; nutrient comparative claims recorded a total number of 151 claims; nutrient function claims or other function claims recorded a total number of 541 claims; claims for enrichment, fortification or other similar words of similar meaning recorded a total of 27 claims and ‘nutritious’ claims recorded a total of 15 claims. More than half of nutrient content claims had excellent compliance (62%, n=1383), followed by good compliance (29%, n=647). On the other hand, a higher proportion of nutrient comparative claims only had moderate compliance (35%, n=53), followed by very poor compliance (31%, n=46). A very high percentage of excellent compliance (88%, n=475) was observed among nutrient function claims or other function claims. Slightly more than half of the claims for enrichment, fortification or other similar words of similar meaning, had excellent compliance (56%, n=15), followed by good compliance (30%, n=8). The majority of the ‘nutritious’ claims had excellent compliance too (87%, n=13) and the rest had moderate compliance (13%, n=2) (online supplemental appendix S12).

Other claims

Prohibited claim was the least prevalent type of ‘other claim’ observed (0.1%, n=5), while ingredient claim was the most prevalent type of ‘other claim’ observed (7%, n=231) (online supplemental appendix S11).

Credibility as a healthy food product

Of the 1809 products which carried some form of food product indicators, those that carried HCL Malaysia, or NHC, or both (64%, n=1156; HCL Malaysia only: 3%, n=55; NHC only: 56%, n=1018; both: 5%, n=83) were analysed for their credibility as a healthy food product as compared with the WHO NPM WPR standard. Only 13% of the products was absolutely credible as a healthy food product (n=147). The majority of the products were not credible as a healthy food product at all (36%, n=418), followed by somewhat credible products (33%, n=383) (table 3). Within the products that carried HCL Malaysia (may or may not carry NHC), 17% of them were identified as absolute credible healthy food product (n=23). Meanwhile, within the products that carried NHC (may or may not carry HCL), 13% of them were identified as absolute credible healthy food product (n=143) (table not shown).

Table 3

Credibility as a healthy food product

Discussion

This study shows that approximately half of the products (53%) sold in the supermarkets in Klang Valley of Malaysia, which is the centre of Malaysia, carried at least one type of food product indicator. This rate is similar to the findings of a study from Canada which recorded 49% of products displaying any type of nutrition and other claims from nutrient content claims, health claims, disease risk reduction claims, structure/function claims and FOPNL under the term ‘general health claims’.58 More than a quarter (28%) of the products in the Malaysian supermarkets carried at least one FOPNL. This finding is slightly higher than the findings of a study done in Belgrade, Serbia (19%)59 and Canada (20%).58 Only 3%, 1% and 7% of the products carried the HSR, MTL and GDA/RI labels, which were much lower as compared with their country-of-origin studies.33 60 61

The overall prevalence of food products carrying the HCL Malaysia label was low (4%), with the majority being locally produced (99%). This shows that the voluntary uptake of HCL Malaysia is not yet satisfactory despite 6 years of its launch, as compared with other countries’ FOPNL schemes that have been well received. Australia’s HSR label was found on 40.7% of food products in 2019, which was almost 10-fold that of the HCL Malaysia.62 Singapore’s HCS also recorded a total of 28% products in 2020, close to sevenfold more the Malaysia’s HCL.63 This result urges that efforts need to be made to encourage the local food industry to reformulate their products and apply for the HCL. In this study, HCL compliance is defined as the adherence of food products to the guideline’s requirements in terms of statement, nutrient criteria and certification. Low compliance means that the product does not adhere to either one or more of the conditions, resulting in misuse of the logo. This study found that although the statement compliance was high among the products, only almost half of them had excellent nutrient compliance. Moreover, most products in the cereal, cereal products and flour confection category, convenience food category, dairy and dairy products category and fish and fish products category had only moderate nutrient compliance. At the moment, random checking on companies whose products fail to meet the criteria will be investigated and may be disqualified from the programme. Companies that fail to comply with the HCL certification guidelines may receive a written warning or even legal action and may be banned from any new application for the HCL logo for 2 years.51 It is suggested that tighter enforcement and regulation should be performed on the products of these categories to ensure higher compliance standards. It is also suggested that a food analysis be performed occasionally on certified products to ensure that they always meet the nutritional standards. As the food industry is primarily responsible for the enforcement and conformation of products towards the standards, food companies should be more aware to abide by the standards and produce credible food products.3 This is especially crucial when the presence of HCL would positively influence the buying decisions of consumers.19

With regard to NHC, more than a quarter of the products analysed (32%) carried at least one type of NHC. This result is similar to a study from the UK (32%)64 and a study from the Kingdom of Saudi Arabia (KSA) (29%)65; higher than the findings of a 5-country European study (26%)66; but lower than the Canadian study (49%)58 and a study from Brazil (41%).67 It should be aware that some of these studies included the disease risk reduction claims which were classified as ‘prohibited claims’ under our study. Nutrition claims were found on 31% of the products and only 5% of the products had health claims. The prevalence of nutrition claims in this study is similar to the rates in the UK (29%)63 and slightly higher than a study from South Africa (20%)68 and the Brazilian study (29%)67 but lower than another study from Brazil (51%),69 while the prevalence of health claims is much lower than the UK study (15%)64 and the first Brazilian study (22%).67 This could be due to the study from Brazil included claims for special diets such as gluten-free and dairy-free, claims for ‘natural’ and general health claims such as ‘nutritious’, disease risk reduction claims and function claims under ‘health claims’. In this study, the highest prevalence was noted for nutrient content claims in which 29% of products carried at least one nutrient content claims. However, this rate is much lower than the findings of the Canadian study (43%)58 and a South African study (68%).70 This rate is also lower than a previous study done in Singapore which found the prevalence of nutrient content claims among Malaysia-made products is 40%, but the rate for function claims in this study (5%) corresponds with the outcome of the Singaporean study (7%).71

NHC compliance in this study is defined as the adherence of food products towards the nutrient criteria and other conditions required by the local regulation. Food companies with products of low NHC compliance mean that they failed to abide by the regulations and misused the claims, which will incur fine, imprisonment or both. The main reason for non-compliance among nutrient content claims and function claims in this study is the nutrient does not meet the minimum standards or is not declared. Nearly 90% of the function claims have excellent compliance which is much higher than the rate observed in Mongolia (2%).42 Only 16% of the nutrient comparative claims had excellent compliance. This rate of compliance was lower than the rate of the South African study which recorded 100% compliance among nutrient comparative claims.70 The main reason for non-compliance for nutrient comparative claims in this study was the full details of the comparison were not given, which was required by the local standards. The compliance of nutrition claims is 48%, which was rather similar to a Spanish study (49%)43 but higher than the rate observed in Mongolia (34%)42 and an Australian study done among ultra-processed foods only (18%).60 As for the overall NHC compliance per product aspect, close to half of the products (47%) have excellent overall compliance. This rate is higher than the rate observed in a study from Belgrade, Serbia (32%).59 Less than a quarter of the products (21%) had very poor to moderate overall compliance. Attention should be given to the fats and oils category and soup, sauces and recipe mixes category as more than 60% of the products in these categories had poor overall compliance. Food companies producing food products of these categories should be more conscientious and meticulous regarding the use of NHC. At the moment, enforcement of NHC in Malaysia at the reported level is based on complaints only, while at the analytical level is based on random chemical analysis.72 Local authorities could strengthen the enforcement of these products by doing regular monitoring regarding the proper and accurate use of NHC.

The prevalence of absolutely credible healthy food among the products which carried the Malaysia’s HCL, or NHC, or both, as compared with the WHO NPM WPR standard was low (13%) in this study. This rate is similar to a study from Argentina in which only 10% of the products evaluated against the WHO Regional Office for Europe Nutrient Profile (WHOE) and Pan American Health Organization Nutrient Profile Model (PAHO NPM) were very healthy,73 and similar to a German study when evaluated against the UK Ofcom model (12%) but lower when evaluated against the Food Standard Australia and New Zealand Nutrient Profiling Scoring Criterion (FSANZ NPSC) (20%).74 It is also lower than a Slovenian study against FSANZ NPSC (68%) or WHOE (33%).75

This study found that products that bore NHC had low levels of credibility as healthy food product (13%). This rate was slightly higher than the Brazilian study (9%),69 and the Argentina study when compared with the WHOE NPM (9%) but similar rates were observed in the Argentina study when compared with the PAHO NPM.73 However, this rate is significantly lower than the rates of KSA (53%),63 the UK (59%),76 Australia (70%),77 New Zealand (71%)78 and Canada (58%).79 As introduced earlier, several studies have shown that NHC has the tendency of causing positivity bias or ‘health halo’ which may mislead consumers.34–39 This study supports that NHC does not necessarily guarantee that a food product is healthy.

This study also found that products that carried HCL Malaysia had low levels of credibility as healthy food product (17%). As introduced earlier, some studies found that FOPNL is effective at mitigating the positivity bias induced by NHC.30 31 However, few studies pointed out that some FOPNL might still confuse consumers, when they appear on foods that were believed to be unhealthy inherently.32 33 This is a relevant phenomenon observed in this study. First, HCL Malaysia is allowed to be displayed on food products of the following categories which were disqualified by the WHO standard: (1) cakes, biscuits, pastries and bakery products and (2) energy drinks, tea and coffee. Second, sugar-sweetened beverages and processed food such as instant noodles are granted to carry the HCL Malaysia under more lenient requirements as compared with the WHO standard (HCL Malaysia does not limit the use of non-sugar sweetener and added sugar, WHO NPM WPR prohibits the use of non-sugar sweetener and added sugar; WHO NPM WPR has stricter thresholds for fat and sodium content of instant noodles). Moreover, half of Malaysian consumers found the HCL Malaysia confusing and difficult to understand, despite the majority of respondents having a tertiary education. Three-quarters of them believed that products bearing the HCL Malaysia were healthier choices across all food product categories. Only when provided with the statement ‘compared within (product) category only’ were majority of the respondents able to correctly interpret the logo.80 This study highlights that having HCL Malaysia does not indicate the overall healthiness of the food product, but signifies that the product is only a better choice within its specific food category. This calls for future actions to enhance Malaysian consumers’ understanding of the HCL Malaysia and to revise the HCL Malaysia guidelines to better align with the WHO NPM WPR to improve the credibility of products carrying HCL Malaysia as healthy food products.

This study is the first comprehensive market survey covering a large number of products that investigated the prevalence of multiple food product indicators in the Malaysian market. This study has also successfully developed a systematic way of assessing the compliance of HCL Malaysia and NHC towards the local standard their credibility as a healthy food product towards the international standards, which could be adopted by future studies. However, it has several limitations. First, the compliance of products was evaluated against the older guidelines (February 2023 version for HCL Malaysia; 2010 version for local NHC guidelines). After the study had been done in June 2023, the Malaysian government released the newest guidelines for HCL Malaysia (September 2023 version) and for NHC guidelines (2023 version) later in the year. The latest guidelines include thresholds or requirements for nutrients such as alpha-linoleic acid, gangliosides and gluten for nutrient content claims and fatty acids for fortification claims, in which we have classified gluten claims and omega-3 fatty acid claims as ‘special diet claims’ and ‘unregulated claims’, respectively, in this study. Moreover, thresholds for minerals such as copper, selenium, manganese and molybdenum have been included.72 However, these nutrients were unlikely to be presented on the products investigated in this study. It is important to note that the latest local NHC guidelines have stricter thresholds for nutrient content claims, which may suggest even lower percentage of compliance if compared with the latest guidelines. As for the differences between the February and September 2023 version of the local HCL guidelines, there were no difference in terms of nutrient thresholds, but new food category (filled flatbread) was added to the latter. No filled flatbread was sampled in this study.81 Second, the products sampled in this study are not representative of the whole Malaysian market due to convenience sampling that focused on supermarkets in the Klang Valley. Third, the sample size for food products is limited in terms of food categories as products such as frozen processed foods, snacks and chips; chocolate and sugar confectionery were not included in this study. Fourth, this study only investigated the compliance of products carrying HCL Malaysia and NHC towards the local guidelines. This affected the size of the subsample analysed in assessing the credibility of products as healthy food products because products carrying food indicators other than HCL Malaysia and NHC were not assessed for their compliance towards other regulations and credibility against the WHO WPR NPM. Some unregulated claims may be covered in other countries’ NHC guidelines. Fifth, the assessment of compliance and credibility of all products in this study is solely based on the declaration of nutrient content in NIP by the food companies and relies on the food companies’ integrity to provide credible nutrition information. However, a study based in Malaysia noted that 34% of food products have nutrition information that is not credible.82 Therefore, it is recommended to perform chemical analyses to increase the accuracy of the results. The sample size for supermarkets and food products should be increased and expanded so that they are representative of the Malaysian market. Future research could also be done to assess the compliance and credibility of other products displaying other types of food indicators.

Conclusion

In conclusion, this study highlighted that half of the products surveyed had some form of food product indicators. However, voluntary application of the local standard, that is, HCL Malaysia label was low among food industries. Only half of the products with HCL had excellent nutrient compliance and only half of the products displayed NHC had excellent compliance. Only 13% of the subsample (those with HCL Malaysia and/or NHC) were defined as healthy food products by the WHO standard. It is of utmost importance for both food companies and government authorities to ensure the highest standard of compliance towards the standards and their credibility as a healthy food product to minimise the possible consequences of the halo effect and to alleviate the burden of NCD in Malaysia.

Data availability statement

All data relevant to the study are included in the article or uploaded as online supplemental information. All shareable data relevant to the study are included in the article or uploaded as online supplemental information. Further raw data are not available for sharing.

Ethics statementsPatient consent for publication

Not applicable.

Ethics approval

This study was approved by the Research Ethics Committee, The National University of Malaysia (UKM PP1/111/8/JEP-2022-062).

Acknowledgments

We would like to thank the management team of Aeon Taman Maluri, Cold Storage KLCC and Lotus’s Mutiara Damansara who allowed the researchers to perform data collection at their premises. The authors would also like to extend their sincere appreciation to ChatGPT for its contribution to improving the language of this manuscript.