"Balancing Compliance and Innovation: Using Incentive Theory

to Reform Bangladesh's Labeling Framework"

Imagine strolling into a grocer's outlet, greeted by a vast selection of food products, each vying
for our attention with its unique packaging, labeling, and branding. As defined by the Food and
Agriculture Organization (FAO), food labeling provides essential information about packaged
foods' composition, properties, and production conditions, helping consumers make informed
decisions. However, food labeling has been given short shrift in many nations, including
Bangladesh, leaving consumers flummoxed and potentially vulnerable. Statistics underscore the
gravity of the situation, indicating that incorrect labeling accounts for 40% of our
Bangladeshi product rejections in the EU and America, with roughly 30% of recalls
attributed to undisclosed allergens.1 This inadequacy is a pressing concern, especially in
Bangladesh, where regulatory authorities face severe limitations in enforcing mandatory food
standards, with a meager 12% of overall food standards deemed obligatory.2

Consequently, product rejections and recalls are rife in the country, even in standard chain retail
outlets, where only a paltry 9% of the 900 food items sold undergo proper monitoring channels.3

Legal Framework for Food Labelling in Bangladesh and their laxity

The Bangladesh Standards and Testing Institutions (BSTI) ensure that food commodities comply
with the laws and quality standards mentioned in them. Through the collaboration of BSTI
and BFSA, a comprehensive set of standards for food quality has been developed under the
Food Safety Act 2013. This Act also provides for establishing BFSA to oversee and regulate the

1
Label Review. (n.d.). SGS Bangladesh. Retrieved March 8, 2023, from https://www.sgs.com/en-bd/services/label-review

2
Unregulated products rule in Bangladesh. (n.d.). The New Age. Retrieved March 8, 2023, from
https://www.newagebd.net/article/133376/unregulated-products-rule-markets-in-bangladesh

3
Unregulated products rule in Bangladesh. (n.d.). The New Age. Retrieved March 8, 2023, from
https://www.newagebd.net/article/133376/unregulated-products-rule-markets-in-bangladesh
activities related to food production, import, processing, storage, distribution, and sale in the
country. The following laws govern the labeling criteria in Bangladesh4:

i) The Packaged Food Labelling Regulations 2017

ii) Bangladesh Standards of Weights and Measures (Commodity Packing) Rules 2007

iii) Bangladesh Import Order 2015-2018

iv) The Food Safety Act 2013.

Despite the fact that there are regulations governing food labeling, Bangladesh's packaged food
labeling laws, which are intended to offer a set of facts on things from manufacturing to delivery,
have scarcely been followed. Consumers Association of Bangladesh (CAB) conducted a survey
on packaged biscuits of 66 brands (both imported and locally produced) made by 33 companies.
The results showed that 86% did not have an expiration date, 83% did not mention weight, and
83% had higher prices being charged by the sellers. 5 In a subsequent survey undertaken by
CAB , it was discovered that 52% of the 51 brands of jam and jelly produced by 31 businesses
lacked BSTI certification marks, while 13.72% did not mention ingredients, 23.52% did not
mention date of production and date of expiry, and in 54.90% cases retail price was not
mentioned on the label. On another research, nearly half (44%) of the study's sampled goods had
more salt than was indicated on the packaging. 6 The BSTI has little control over the sale of
frozen or canned food, deep-fried snacks, or calorie-dense BBQ diets from restaurants or shops
bordering the streets of both posh and shabby neighborhoods. According to Bellal Hossain, a
nutrition and food engineering professor at Daffodil International University in the nation's

4
Review of labeling requirements in Bangladesh. (2022). S.S. Rana & Co. Retrieved March 8, 2023, from
https://ssrana.in/articles/labeling-requirements-bangladesh/

5
Consumer Rights : Where Do we stand? (n.d.). The Daily Star. Retrieved March 9, 2023, from
https://www.thedailystar.net/law/200309/01/index.htm

6
The Business standard “61% of processed foods have too much salt: Study” 28th September, 2022
capital, Bangladesh is conceivably the only country in the world where the frozen food industry
is unregulated.

By reading the Packaged Food Labeling Act 20177 there are some uncertainty and ambiguity in
the provisions such as, there are several issues with the labeling regulation. Firstly, certain
agricultural raw materials are not required to provide comprehensive nutritional information.
Secondly, there is ambiguity in some of the labeling requirements, such as the size of the font or
the use of bar codes. Thirdly, there is insufficient detail on certain labeling requirements, such as
instructions for processing or preservation. Lastly, the regulation does not provide any specific
provisions for consumers to give feedback or make complaints about inaccurate labeling.

How the label law should be reformed & the scope of Incentive theory

Incentive theory is a captivating psychological and behavioral construct that posits that external
rewards and incentives can spur individuals to action.

How the food labelling law in our country can be reformed: 1. A scoring system based on
nutritional value could be implemented to empower consumers to make informed food choices.
Such a system would assign a score to each food product, reflecting its nutritional value and
indicating whether it contains excessive amounts of sugar or unhealthy fats or is high in protein,
fiber, and other vital nutrients. This system would provide a quick and easy way for consumers
to determine which products are most beneficial for their health and well-being.

2. Besides the scoring system, a comprehensive star based system could be introduced to
enhance the labeling laws further. This system would consider various food production and
handling factors, including the manufacturing process, storage conditions, and compliance with
all relevant laws and regulations. Food products that meet all the requirements and standards
would receive an 5 star , signifying the highest level of quality and safety.

3. To encourage compliance with nutritional standards and regulations, incentive theory

could be integrated into food labeling laws. Manufacturers that produce high-quality, law-

7
USDA Foreign Agricultural Service. (2019, October 30). Bangladesh - Bangladesh issues packaged food labelling act 2017.
https://www.fas.usda.gov/data/bangladesh-bangladesh-issues-packaged-food-labelling-act-2017
compliant foods could receive tax cuts and other incentives, motivating them to improve their
production processes and supply chains, resulting in healthier and safer food options for
consumers. Moreover, export tax cuts for law-compliant foods could bolster the reputation of a
nation's food industry and promote the export of quality food products

Several countries have implemented a system to illustrate the nutritional values of packaged
foods. In Australia and New Zealand, the Health Star Rating system is used, which assigns a
rating from 0.5 to 5 stars based on the overall nutritional profile of the product. 8 The system was
implemented to help consumers make informed food choices and improve public health
outcomes. France uses the Nutri-Score system, which uses a color-coded scale ranging from A
(green) to E (red) to indicate the overall nutritional quality of packaged foods.9

Conclusion

Using incentive theory can provide a fresh perspective on reforming the labeling framework in
Bangladesh by incorporating rewards and penalties to motivate compliance. A comprehensive
and standardized food labeling system based on nutritional value and effective enforcement can
go a long way in safeguarding public health and promoting transparency in the food industry.
The government and industry players must take the lead in investing resources and attention in
this crucial area to ensure consumer health and well-being.

8
Australian Government Department of Health. (2022, February 3). Have your say on Health Star Rating system.
https://www.health.gov.au/news/have-your-say-on-health-star-rating-system

9
Santé Publique France. (n.d.). Nutri-Score : un logo sur la qualité nutritionnelle des produits.
https://www.santepubliquefrance.fr/recherche/#search=Nutri-Score%20:%20un%20logo%20sur%20la%20qualit
%C3%A9%20nutritionnelle%20des%20produits.
References

1.Organization (FAO). (2019). Food labeling: Information for consumers.

http://www.fao.org/food-labelling/en/

2.Consumer Association of Bangladesh (CAB). (n.d.). Campaign on food safety.

https://www.consumerbd.org/

3.The Bangladesh Standards and Testing Institutions (BSTI). (n.d.). http://bsti.gov.bd/

4.Bangladesh Food Safety Authority (BFSA). (n.d.). https://www.bfsa.gov.bd/

5.The Food Safety Act 2013. https://bangladeshbiosafety.org/bangladesh-doc/food-safety-act-

2013-eng/

6. Packaged Food Labelling Regulations 2017.

https://apps.fas.usda.gov/newgainapi/api/Report/DownloadReportByFileName?
fileName=Bangladesh%20issues%20Packaged%20Food%20Labelling%20Act
%202017_Dhaka_Bangladesh_03-04-2021

7. Hussain, M. A., & Rahman, M. (2020). Food labeling issues in Bangladesh: Consumer
perspectives. European Journal of Nutrition & Food Safety, 12(4), 1-14

8. Supti, Afsana. (2019). Food Adulteration in Bangladesh: A Legal Analysis.

10.1080/13657300802679186>.
9. A. Noman Mohammad Atahar. Ali, and Food safety and public health issues in Bangladesh: a
regulatory (2013) 8 (1) European Food and Feed Law Review 31-40.

10. Why Bangladesh should introduce a food waste law

https://publisher.tbsnews.net/thoughts/why-bangladesh-should-introduce-food-waste-law-600318