New study assesses compliance with South Africa's proposed R3337 regulations

Published January 23, 2025, by CoE-FS

In light of the South African government’s publication of a draft regulation to introduce warning labels on food packaging and restrict marketing (called R3337), researchers from and affiliated with the DSTI-NRF Centre of Excellence in Food Security (CoE-FS) have published a study, analysing on-package marketing, and “creating a baseline to evaluate compliance with the proposed R3337”.

Dr Tamryn Frank, CoE-FS grantee and researcher at the School of Public Health at the University of the Western Cape, and Professor Rina Swart, the CoE-FS’s Nutrition lead, co-authored the study, “An assessment of compliance with proposed regulations to restrict on-package marketing of packaged foods to improve nutrition in South Africa”, published 21 January 2025 in BMC Nutrition. Professor Swart and Dr Frank are joined by co-authors Safura Abdool Karim, Alice S. Khan, Morongoa G. Tlhako and Sikhumbule K. Joni.

The study can be viewed and downloaded here.

Abstract

Background
Ultra-processed products (UPPs), high in sugar, fat and sodium, contribute to increasing burdens of obesity and non-communicable diseases in South Africa (SA). Increased consumption and acceptability of UPPs is driven, in part by aggressive marketing. Front of package labelling laws, particularly warning labels (WLs) coupled with marketing restrictions, have been recommended to improve consumer awareness of unhealthy products, incentivise reformulation and underpin other interventions. The SA government published a draft regulation to introduce WLs and restrict marketing, called R3337. This study aims to analyse on-package marketing and create a baseline to evaluate compliance with the proposed R3337.

Methods
This study is an analysis of a dataset of 6768 packaged food products, collected as pictures of products in four major grocery stores in Cape Town, SA between March and July 2019. A codebook was developed based on R337. The codebook was used to identify and assess child-directed marketing (CDM) and health claims on products potentially subject to front-of-package WLs. Food packages and their nutritional information were coded and analyzed to determine whether the product would be required to carry a WL and whether the package included regulated marketing.

Results
The majority (80.16%) of products analyzed would require WLs under R3337 due to high levels of sugar, sodium, or saturated fat. CDM was prevalent, with 59.26% of products displaying some form of marketing, primarily animated characters and depictions of children. Health claims were also common, with 83% occurring on WL products.

Discussion
Using a WL system in SA could effectively target common forms of on-package marketing of unhealthy products, given the high prevalence of CDM and health claims on products likely to carry WLs. Such interventions may contribute to improving diets and reducing UPP consumption. Some forms of CDM are not regulated under R3337 and we recommend expanding the regulation to include these. This study provides a baseline which should be used for future research to evaluate R3337 when it is implemented.