When selecting different types of prepackaged foods, consumers require clear and accurate product information on the labelling, such as the nutrient content, food ingredients, expiry date, and allergenic substances, etc. However, the Consumer Council’s recent survey on 55 prepackaged food samples revealed various legibility issues on most labelling. The smallest English and/or Chinese font sizes of close to 90% (48 samples) of the samples were smaller than the minimum font size recommended by the Centre for Food Safety’s (CFS) “Trade Guidelines on Preparation of Legible Food Label” (“Trade Guidelines”). Some of the samples’ font size was so small that even individuals with normal eyesight might require a magnifying glass to clearly read it. Besides, the product labels of some samples had other issues that made it hard for consumers to read, such as poor contrast between the background and text colours, unclear print, insufficient spacing, or a reflective printing surface. The Council urges the industry to pay heed to the clarity and legibility of labels, and evaluate whether the food labels are easy to read from a user’s perspective, so as to safeguard consumer rights.
Posing as regular consumers, Council staff randomly sourced 55 samples of prepackaged foods for survey between May to June 2022, including 5 bakery/cereals, 4 butter/cheese, 3 soy products, 4 chilled/frozen foods, 3 milk/plant-based milk, 8 drinks/instant beverages, 5 biscuits, 7 snacks, 5 instant noodles, 4 canned foods, and 7 oil/sauces. Referencing the Trade Guidelines and from a consumer’s perspective, the clarity and legibility of 3 labelling items were assessed, including the nutrition label, list of ingredients, and information on allergenic substances.
48 Samples with English and/or Chinese Font Height Less than Trade Guidelines
Worst-performing Sample Was Only 0.3mm in Height
Amongst the 55 surveyed samples, only 7 had its smallest font size that complied with the recommended height of the Trade Guidelines, while the smallest English letter and/or Chinese character height of all remaining 48 samples were smaller than recommended.
Out of the 17 smaller package sized samples (i.e. total surface area less than 400cm2, same applies to the below) with English and Chinese bilingual labelling, when the font size of the 2 (if food allergen information is not included) or 3 labelled items were measured, only 2 samples had font sizes that completely complied with the Trade Guidelines’ recommended requirements (a minimum height of 0.8mm for English letters and 1.8mm for Chinese characters). The smallest English and/or Chinese font sizes of the remaining 15 samples were smaller than the Guidelines’ recommendations, a situation that was more prevalent in the font size of nutrition labels. For the lists of ingredients and allergen information, the English text performed better while the Chinese character height for 12 samples was less than recommended. A case worth noting was 1 sample of rice noodles with a smaller package size, which had measured English and Chinese font heights of 0.3mm and 0.5mm respectively, less than half of the minimum font height recommended by the Trade Guidelines.
Of the 16 larger package sized samples (i.e. total surface area of 400cm2 or above, same applies to the below) with English and Chinese bilingual labelling, only 3 samples had measured font sizes that completely complied with the Trade Guidelines’ requirement (recommended height same as the smaller package size above). Amongst the remaining 13 samples, a greater ratio of incompliance was found in the font height on nutrition labels (English and/or Chinese) being smaller than recommended. For the lists of ingredients and information on allergenic substances, more cases (10 samples) were related to the Chinese text failing to meet the Guidelines’ recommended font height. In this category, the smallest English and Chinese font heights of 3 labelling items on 1 instant noodles sample were only 0.5mm and 1.0mm respectively, a rather large discrepancy with the Guidelines’ requirement.
Besides, all 15 samples of larger package size with only English labelling were found with their smallest font height less than the Guidelines’ recommendation (i.e. 1.2mm). Amongst the measured text items on the labels, only the lists of ingredients of 2 samples complied with the minimum font height recommended in the Guidelines. In this category, the smallest English font height of 1 oats drink sample was only 0.5mm, less than half of the minimum height for English letters recommended in the Guidelines. Additionally, the print of this sample’s label was of poor quality with blurry text.
Font Size of Most Samples Appraised As Being Too Small
Many Samples Found with Poor Print Quality and Insufficient Contrast
This survey comprised 2 parts. Apart from measuring the font sizes on the food labels, 15 male and female respondents were invited to assess the legibility of the labelling information of the 55 samples. The respondents, aged between 20 to 61 years old or above and all with normal eyesight, were split into 5 assessment panels (“panels”) based on their age, and invited to complete the assessment from a consumer’s perspective based on the 5 key elements set out in the “Trade Guidelines”, including the font size, contrast between the background and text colours, print quality, text spacing, and whether the printing surface was reflective. According to the results of the panel assessments, apart from 1 sample, the remaining 54 samples each had room for improvement in different areas of legibility as opined by panel members. Most members were unsatisfied with the font size on the labels. The panels opined that the labelling font sizes of 90% (50 samples) of the samples were too small, of which 3 samples were rated as unsatisfactory by over half of the panel members. 1 sample which was measured with the smallest English and Chinese font sizes was unanimously rated by all 15 members as unsatisfactory and hard to read.
Of the 20 samples rated as poor print quality, blurry, blotched or faded text, more were affixed labels (13 samples). Taking an oats drink sample with a larger package size for instance, the smallest English letter height of its affixed label was only 0.5mm, smaller than the recommended 1.2mm. Apart from 8 members opining that its label font size was too small, another 11 members also expressed that the print quality was poor and the text was blurry.
19 surveyed samples were opined by the panels as having insufficient contrast, more were samples with original labels (17 samples). 2 of such samples were rated as unsatisfactory by 10 and 11 members respectively, including a sample of bread which had white text printed against a yellow background, and a sample of soybean rolls which was printed with brown text on a black background, making it hard to read the text.
Furthermore, 16 samples were rated as having insufficient spacing between the lines of text, or having overly dense fonts, which affected the legibility. Another item rated by members as unsatisfactory was the reflective issue of the labels. 4 surveyed samples had a reflective packaging surface or text, including 1 canned soft drinks sample, which despite having font sizes that complied with the requirements, had insufficient contrast between its text and background colours. Additionally, the surface of the can was reflective, all of which affected the legibility of the labelled information. Besides, a certain sample in the survey was designed with the labelled text surrounding the four sides of the packaging, increasing the difficulty for consumers to read the label’s content. Traders should promptly improve.
Products with Larger Package Size Failed to Increase the Legibility by Fully Utilising the Space
Amongst the 55 samples, 22 (40%) were of smaller package size, while 33 (60%) were of larger package size, yet the legibility of the labels did not significantly improve with larger packaging. Many of these larger-sized samples were imported foods, amongst which 20 had labels intended for local use affixed on top of the original label. However, the survey revealed that some samples did not fully utilise the space on the packaging to provide larger, clearer labelling information, as the affixed labels and their font sizes were still relatively small, making it hard to read the information. Taking 1 sample with a larger total surface area (greater than 2,000cm2) as an example, the area of its affixed label was only around 22cm2, in which the width of the nutrition label was even smaller than a 10-cent Hong Kong Dollar coin, while the smallest English letter (found in the nutrient content) was only 0.8mm in height, smaller than the 1.2mm recommended.
In this survey, the samples were given an overall rating of maximum 5 points after measurement of the font size and the panel assessment. Out of the 55 samples, only 4 received a rating of 4 points or more, while 18 samples were rated 3.5 or 3 points. 33 samples (60%) were only rated 2.5 or less, of which 7 samples only received a rating of 1.5 points or below, including labels only presented in English, and those with English and Chinese bilingual labelling in the smaller and larger package size categories, the legibility of which was disappointing.
It is a fundamental consumer right to receive accurate product information. Traders have the responsibility to provide clear food label information to allow consumers to make informed choices. The Council urges the food industry to promptly review the legibility of food labels. When designing food labels, traders should be mindful of their legibility, and be more considerate of consumers, especially senior citizens with poorer vision and individuals concerned about health-related information. Food labels with larger fonts and clear printing should be provided as far as practicable, so as to help consumers receive relevant product information.
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