Confectionery Conversation: can suppliers beat regulators to the punch?

By Charlotte Turner |

Confect Conversation web slideIn the fourth edition of this year’s Confectionery Conversation – a monthly column which shines a spotlight on the confectionery category, sponsored by Mars Wrigley International Travel Retail – Charlotte Turner presents an update on HFSS regulation and DFWC’s new code of conduct.

*This column appeared in the April issue of TRBusinesss.

As DFWC confirmed to TRBusiness, it is currently working on a Self-Regulatory Code of Conduct for the Sale of Confectionery, Chocolate and Biscuit Products in Duty Free & Travel Retail.

TRBusiness understands that while it is not specifically a code relating to HFSS (foods high in fat, sugar or salt), it does incorporate communication to the consumer through packaging, labelling etc.

“It is evolving, but remains a work in progress,” a DFWC spokesperson told TRBusiness earlier this year. “The code will call for adoption by brands and retailers as well as their external advertising, marketing and public relations consultants.”


The DFWC (led by President Sarah Branquinho) is currently working on a Self-Regulatory Code of Conduct for the Sale of Confectionery, Chocolate and Biscuit Products in Duty Free & Travel Retail.

However, Covid-19 has somewhat scuppered DFWC’s plans to get the code published imminently. “Given the current crises I am unable to tell you when the code is likely to be published,” added the spokesperson.

Why is the DFWC working with connected TR stakeholders to bring a in a new Code of Conduct for confectionery? One supplier puts it succinctly to TRBusiness.

“Countries are increasingly regulating how consumers should be informed about foods, especially HFSS foods. The travel retail industry should realise that it is in a race to come up with a way to provide information to travellers before regulators beat us to it.”

The problem remains that there isn’t one sole regulator, worldwide. For many global manufacturers there could be over a hundred, depending on the number of countries that a company operates in.

If we look at advertising as an example, according to WHO the UK has banned HFSS product advertisements in children’s media (and other media where children make up 24%).

However, in Spain there are two different self-regulation schemes in place where the marketing of unhealthy foods aimed at children under 15 on the Internet is banned, while in other media the age limit is 12.


Ireland has implemented a voluntary code of practice to limit the promotion and marketing of HFSS foods with a social media provision, preventing companies from targeting those under 15.

These three examples all refer to HFSS advertising within Europe, yet contain subtle differences.

One supplier asks: “Will we see archaic domestic labelling regulations about information on-pack being followed in a channel that we know serves an international audience of largely English speaking, digitally-savvy travellers?”

“That doesn’t make sense. Or is there another, even more pointless scenario in which playing by all the different rules of all these domestic markets is going to become too complex to handle for confectionery in travel retail? And then what?”

The same supplier iterates a sense of urgency that the travel retail industry is alone in this challenge, and that it is running out of time.

“We should join forces and come up with a unique solution for the travel retail industry: one that is global, and digital, based on a QR code, because that is what consumers are comfortable with; more so than we realise.”


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