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From: Michael Goitzman To: Aqd&Q.Fl.stQw; Brian MiQhag.LFre.rg; :C^rj(Qia..F^naviQ.Marahaii; QiiIia.BJ.ier.iy.; Dar.ignff.Hiay.gg; ,Hajne...Bflwgrs, Ciivej]trx hisidi.KQg.g£.ai..PJj.v.aL'.a; Jg.aQil.gr.A.a.rj.Ragi.anrj.; jggsi.Qa.Bangy,; JgnathaiiRigf,; jQggfftLQMcau.g; Kais iiYin; •Kathg.riag..£rj.sr.^; Kathjg.e.Q.Bj.aak; Maia.n.Qa.varvg.Qr..Qfti.c.g.; Mggy..CMg.as; [email protected]).; BpJJaer.t.-Q.Hsttsr.; BQ.Q.eiL.Ear.i; wo.uie.Lysrmgyj.gn Subject: FW: PLEASE TAKE NOTE: SRA Top Issues - Policy Briefs Date: Sunday, May 08, 2016 5:35:38 PM Attachments: SflArjalicyls^esJ^ From: Wamwari Waichungo Sent: Saturday, May 07, 2016 11:15 PM To: SRA Personnel <[email protected]> Cc: Ed Hays <[email protected]>; Dennis Ryan <[email protected]>; Michael Goitzman <[email protected]>; Jonathan Rief <[email protected]>; Robert Earl <[email protected]￾cola.com>; Paivi Julkunen <[email protected]>; Thomas Stoupis <[email protected]> Subject: PLEASE TAKE NOTE: SRA Top Issues - Policy Briefs Dear SRA Community, I hope this message finds you well. To ensure that we further our knowledge, and develop appropriate strategies regarding to the Top SRA Issues, we have once again leveraged Sancroft to prepare regulatory and policy briefs. In addition to the information provided in the previous briefs, we have expanded the materials to include the competitive landscape among major food and beverage manufacturers, retailers, and food service companies. The updated SRA Top Policy Issue briefs cover (attached): Caffeine Caramel colors/4-MEI Colors Crop protection residues Flavors GMOs/biotechnology Labeling Packaging/BPA Preservatives Sugars, LNCS, and Sweetness Each topic has an Executive Summary and key pressures Heat Map. Each summary covers global regulatory and policy pressures, along with information about external stakeholder actions and the competitive landscape. The briefs are now available on the SRA Portal at SRA Top Policy Issues. To complement the SRA Top Policy Issue Briefs, please refer to the Ql PAC Public Policy Landscape Scorecard and Heat Maps, covering Tax, Environment, and Health pressures. The information can Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

be found on the SRA Portal under PAC Public Policy Scorecard. If you have any questions regarding the briefs, the upcoming webinars and further updates, please reach out to the Project Lead Robert 'Bob' Earl. Regards, Wamwari Waichungo, PhD Vice President T: (404)676-8017 M: (404)709-0274 %.:.- Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

A|jllS i&UiO ypOall? g*T^,a> To #|ftlfficiC ? Global Sc'pntitic . \„.--«^ %..-*• I4#' ana <oguialor>*Aitairs Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Issues • BPA • CROP PROTECTION CHEMICALS • FRONT OF PACK LABELING • GENETICALLY MODIFIED ORGANISMS • INGREDIENTS o CAFFEINE o CARAMEL o COLORS o FLAVORS o PRESERVATIVES • SUGAR, LNCS, SWEETNESS Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

BPAin Packaging Regional and Competitive Landscape Brief April 2016 Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Political and regulatory action and trends Bisphenol A (BPA) is a chemical used to make plastics which is often used in food and drink storage containers, particularly the protective coatings and linings for food and drinks cans. Extremely small amounts of BPA can transfer from packaging into food and drinks. The health effects of over exposure to BPA include physical changes to the brain or breast, behavioral alterations, prostate cancer and early sexual maturation in females. Late in 2014 the US Food and Drug Administration's (FDA) BPAsafety assessment concluded that current approved uses of BPAin food containers and packaging are safe. In January 2015, the European Food Safety Authority's (EFSA) re-evaluation of BPA exposure and toxicity drew a similar conclusion; that BPA poses no health risk to consumers of any age group at current exposure levels. Despite this finding EFSA, based on new data and a refined methodology, reduced the tolerable daily intake (TDI) of BPA from 50mg per kg of body weight per day to 4mg per kg of body weight per day. BPA is subject to a Specific Migration Limit of 0.6 mg/kg. Upon these changes EFSA communicated that even the highest estimates for dietary exposure and for exposure from a combination of sources are three to five times lower than the new TDI. Following the assessment in January 2015, the European Commission is expected to propose new regulations on BPA in 2016 due to uncertainty and inefficiencies associated with individual member states having different laws. The Commission will explore the five following options which were included in the Commissions' road map of possible risk management measures1 : 1. No changes to policy. 2. Lowering the Specific Migration Limit in plastic food contact materials. 3. Lowering the Specific Migration Limit in plastic food contact materials and introducing measures in coatings and varnishes. 4. Lowering the Specific Migration Limit in plastic food contact materials, other food contact materials and introducing measures in coatings and varnishes. 5. A ban of BPAin food contact materials at the EU level. Options 2-5 would result in a level playing field being created across Europe, with a blanket ban on BPA seen as unlikely as it would not reflect the scientific advice from EFSA.2 In February 2016 an official from the Commission's food safety directorate suggested at an event held by the European Parliament's Environment Committee (Envi) that they would be choosing an option that would set a union-wide specific migration limit (SML) for BPA in coatings and varnishes, based on the tolerable daily intake (TDI) level.3 This has been met with positive reactions by trade bodies such as PlasticsEurope and FoodDrinkEurope. Globally there are examples where countries have stricter legislation on the presence of BPA, the most extreme example is in France where a law prohibits the use of BPAin all packaging, containers and utensils intended to come into direct contact with food from January 2015. Prior to this law France had banned BPAin food contact materials intended for use by children up to the age of three. However, the French Constitutional Council ruled that it was unconstitutional 1 https://ww\v. food, gov.uk/enfofcement/regiilation/europeleg/euupdates/ec-fegulation-bpa-foo 2 http://www.foodqualitynews.com/ Regulation -and -safety/ Five-option s-proposed-to-regulate-bispSienol-A-in-packaging 3 https://chemicalwatch.com/45083/industry-welcomes-bpa-migration-limit-for-coatings-varnishes Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

for the nation to ban the manufacture and export of BPA-based food contact materials out of France and as a result the part of the current law concerning production and export of these products has been repealed with immediate effect.4 Countries that have enacted legislation banning BPA from materials that come into contact with baby food and drink include all members of the EU, Canada, Japan, Australia and New Zealand. In March 2015 the BPA in Food Packaging Right to Know Act was introduced in California. If passed it would required all food containers made with BPA to carry a warning label. The Bill is yet to make any further progress beyond its introduction. Campaign, Consumer, Competitor insights The Environmental Working Group (EWG) is one of the most high profile campaigners on the issue of BPA in packaging. They have made policy recommendations to the FDA and EFSA that include determining a safe level of exposure that takes into consideration the evidence of BPA's toxicity at low doses and recommend permissible levels for BPA in canned foods should be no greater than one part per billion, which is far lower than current recommended levels. EWG is also supporting the new legislation on BPA in California and pushing for Congress to act quickly and pass the act. Breast Cancer Charities are calling for stricter legislation and want BPA to be removed from all food contact materials.56 This proposal is supported by ChemTrust, who believe the European Commission's regulations should recognize the need for a consolidated approach to getting endocrine disrupting chemicals (EDCs), e.g. BPA, out of all food packaging materials, not just plastics.7 On the other hand the Food and Drink Federation (FDF) welcomes the ECroadmap, and expects it "will lead to science-based proportionate risk management and improved harmonisation" which will tackle their concerns around conflicting legislation in EU member states.8 Denmark, Belgium, Sweden and France, currently have national legislation in place to ban or restrict BPA. In a small Canadian study recently published in Environmental Health Perspectives, researchers evaluated the impact of switching to a fresh foods diet from one that includes packaged foods. The results suggested that urine levels of BPA fell by 66% when the study participants consumed a fresh foods diet, confirming the researchers'hypothesis that dietary intake is a major source of BPA exposure.9 The American Chemistry Council (ACC) is taking a different position and is commissioning advertisements titled "Listen to the Science: Experts Say BPA is Safe" aiming to share authoritative statements about BPA safety with consumers and manufacturers.10 4 http://www.prw.com/article/20150918/PRW/309189975/fratice-takes-potentialTirst-step-tomiting-bisphen 5 http://www.breastcanceruk.org.uk/our-campaigns/no-more-bpa/ 6 http://www.carstocurebreastcancer.org/news/cans-not-cancer/ 7 http://www.chemtrust.org.uk/bpa-roadmap-food-contact/ 8 https://chemicalwatch.com/43955/industry-and-ngos-clash-over-bpa-migration-limit-proposal 9 http://www.badgut.org/information-centre/a-z-digestive-topics/the-facts-behind-the-buzz-over-bpa/ 10 https://www.americanchemistry.com/Media/PressReleasesTranscripts/ACC-news-releases/American-Chemistry-Council-Highlights-EFSA-FDA-Conclusions-on-BPA-Safety-to￾Consumers-Stakeholders.html Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

In February 2016 the UK's Secretary of State received a question on why the UK was yet to adopt similar policy to Canada in banning BPA from food and drinks contact materials. They responded that the Food Standards Agency (FSA) and EFSA's views are that BPA is safe and does not represent a risk to consumers of any age group. As the UK's food safety advisors, they have continued with this view as well.11 Some companies are starting to commit to BPA free packaging. However, an EWG study found less than one-third of the 252 brands surveyed use BPA-free cans for all products. Of those companies questioned, 43% gave "ambiguous or incomplete" answers to EWG queries. In 2010, Green Century Fund released a report that includes a scorecard that gives 26 major brands a grade for their BPA policies.12 The chemicals often used to replace BPA are Bisphenol S and F, BPS and BPF. Arecent study by the National Academy of Sciences suggests that these compounds whilst less susceptible to transfer to food are likely to cause similar health problems to BPA if leaching does occur. A new study publish in Endocrinology in 2016 reinforces this finding with researchers finding that BPS, like BPA, altered nerve cell development, changed the activity level of genes involved in developing the reproductive system, and could be associated with premature birth.13 11 http://www.parliament.uk/ business/ publications/ written -question s-answers-statements/ written -question/Commons/2016-0 2-01/250 78 12 http://greencentury.st.agmg.wpengiiie.com/wp-content/uploads/2013/05/bpafeport2010.pdf 13 http://arstechnica.co.Uk/scieace./2016/02/the-pfoblem-with-bpa-fre.e-alte.rnatives-afe-just-as-tfoi.ibling/ Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

I BisohenoIA(BPA) I -Canada hoo BRA rrom creed s rev i ; ;- . ^fferJdJJefJIIijO^ Food and Agriculture Organization y* LO establishing a "safe" exposure level for BRA due to a lack of data.. *Er|v!rom foe ad less than 1/3 jranKirigpranasrormetrbRM ipoMaes. concluded thai BRA poses no health risk daily intake. •Ail sitLilM!Il&slIll)lsv^ legislation banning BRA \.'Oa 016 The EMJFO^^ =aoemer:t measures »pj'g^ojf a i strife? 3>3 onsvi'"-. tn«-> ; \.:, x.-\.- 3 :iiXi'> C si' S 5--S'X*-*>"f-XV.>X'.X ! O^f S Av!\3>¥ X •MlllS. j \3«il«K3i ! ! , i'SlvS S jjwVtit^K ) ! U \A/!!^«\ J expos tins 10 PeMisHOuoji &.000 aao oevekaye ^nf'Smnkie ho no I nose a a^-oha oek Oet hnv::e 3..: 3"333 :3 i\."*; -..3 $i_ s : 1_>: |: 3 1 1 :| X\"3 3.3.": : 3lS^. > 3.3 3x5'.. 3...X333 :3 " 3l :3A.> I 1 p^fg^Hsd 8? ¥ 3 \»*t%rf-* 3\-3xS 3 Hion/ bevere Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Crop Protection Chemicals Regional and Competitive Landscape Brief April 2016 Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Background Crop protection chemicals are used to manage insects, diseases and other pests (e.g. weeds) that can damage agricultural crops; reducing quality and/or productivity. Some of the crops used as beverage ingredients (including juices, oils and pulp) may contain trace residue levels. As a result, the nature and potential magnitude of such residues is of primary importance to the Company. Fortunately, the use of crop protection chemicals is highly regulated by various health and safety agencies around the world. These agencies conduct extensive scientific data reviews and are responsible for the establishment of crop protection chemical regulations that protect the health of farmers, consumers and the environment. TCCC relies upon the expertise of these regulatory agencies to establish residue limits on treated crops. These values, commonly known as Maximum Residue Limits (MRLs) serve as the basis for regulatory compliance in food trade and production. TCCC maintains an extensive and robust testing network to ensure that these regulatory levels are not exceeded. While stringent regulations are in place to protect the public and the environment, increased academic and special interest group activity in this area has undermined public perception regarding the need for, and potential risks from, this technology. In general, there is a level of misunderstanding in the general public as to what constitutes hazard and risk, with regards to crop protection chemicals. As one recent example, the World Health Organization (WHO) agency, The International Agency for Research on Cancer (IARC) - assembled 17 experts to assess five pesticides during a meeting at IARC headquarters in Lyon, France in March 2015. The panel concluded that two of the chemicals were "possible" (class 2B) carcinogens and three were "probable" (class 2A) carcinogens.1 ' 2 Glyphosate, a chemical widely used as an herbicide, was one of the chemicals designated as "a probable human carcinogen" based on a hazard-based approach to potential risk, looking at worker exposure. Multiple national and international regulatory authorities have concluded that glyphosate exposures through the diet do not constitute a cancer risk or any other significant health risk. Glyphosate is a key ingredient in the herbicide most popularly known under the 'Roundup' brand developed and produced by Monsanto, but also marketed as other brands by Syngenta, BASF, Bayer, Dupont, Dow Agrosciences, Athanor, and Nidera, among others. Worldwide sales of glyphosate herbicides are about $6bn a year. The IARC report emphasized that 750 products used in agriculture, forestry and domestic gardening contain glyphosate, the use of which has increased significantly with the development of GM glyphosate-resistant crop varieties. IARC has no regulatory role and its decisions do not lead directly to bans or marketing restrictions. However, anti-GMO campaigners have used the findings to put pressure on regulators to ban products containing the chemical and some governments are already moving to reevaluate the chemical. This report on glyphosate and other chemicals is driving debate in the US, and globally, on crop protection chemicals. The Monsanto response was to stress how scientific data did not support IARC's conclusions and called on WHO to hold an urgent meeting to explain the findings. "We don't know how IARC could reach a conclusion that is such a dramatic departure from the conclusion reached by all regulatory agencies around the globe," said Philip Miller, Monsanto's vice-president of global regulatory affairs.2 The U.S. Environmental Protection Agency (EPA) currently assigns glyphosate to the lowest category E, indicating glyphosate does not pose a cancer risk to humans.s German authorities recently confirmed the safety of glyphosate after finding there 1 http://www.thelancet.com/journals/lanonc/article/Pi1S1470-2045%2815%2970134-8/fulltext 2 http://www.theguardian.com/environment/2015/mar/21/rounclup-cancer-who-glyphosate￾3 http://www.epa.gov/ingredients-used-pesticide-proclucts/glyphosate Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

is no link between glyphosate exposure and cancer. These decisions are based on an extensive set of data, including multiple chronic/carcinogenicity studies. While the overwhelming evidence supports a non-cancer conclusion, only l of 900 agents previously reviewed by IARC has received such a rating. It is important to note that unlike regulatory reviews that take a comprehensive look at all available data, including studies conducted according to EPA guidelines and under Good Laboratory Practice (GLP) for registration, IARC makes its conclusion on a limited review of published studies. Common products that have also been placed in the IARC 2B category include cell phones, coffee, and pickled vegetables. Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

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The Regional Landscape North America In September 2015, California's Environmental Protection Agency (Cal/EPA) announced its intention to list glyphosate as a carcinogenic chemical under its Proposition 65, which requires the state to publish a list of chemicals known to cause cancer, birth defects, or other reproductive harm.4 Sales of the product are not restricted by the Cal/EPA listing, but adding glyphosate to the Prop 65 list means that businesses will be required to provide a "clear and reasonable" health warning on Roundup and other glyphosate products. In response, Monsanto filed a lawsuit in California against the Office of Environmental Health Hazard Assessment (OEHHA) in June 2015 seeking to prevent glyphosate from being added to the state's list of known carcinogens.s Also in California, in April 2015 a lawsuit (Case No: BC 578 942) was filed in Los Angeles County, California against biotechnology giant Monsanto. It alleges that Monsanto is guilty of false advertising by claiming that glyphosate, the active ingredient in their best-selling herbicide, Roundup, "targets an enzyme only found in plants and not in humans or animals." The lawsuit attests that the enzyme in question is in fact found in microbiota that reside within human intestinal tracts - thus contradicting Monsanto's claim.6 In February 2016, the Food and Drug Administration (FDA) announced that it will begin testing foods for residue of glyphosate. This move is significant since historically the FDA has shied against such trials on the premise that glyphosate testing was "very cost- and labor-intensive to implement in FDA field labs".? In Canada, opposition critics in Newfoundland and Labrador have enquired why the provincial government continues to aerial spray glyphosate. Meanwhile, Health Canada is considering new risk reduction measures for the chemical. 4 http://oehha.ca.gov/prop6s/CRNR notices/admin listing/intent to list/0Q04isLCset27.html 5http://www.reuters.com/article/us-usa-monsanto-glyphosate-idUSKCNoU^ 6 http://www.globalresearch.ca/monsanto-sued-for-deliberate-falsification-to-conceal-t^ 7 http://www.medicaldaily.com/fda-monsanto-roundup-chemicals-food-a74sQi Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Latin America Prompted by the WHO decision to classify glyphosate as a "probable carcinogen" and acting on President Juan Manuel Santos' recommendation, on May 14, 2015, Co lorn bia's National Drug Council banned aerial spraying of glyphosate.8 The procedure had taken place for over 20 years as part of the Colombian government's anti-cocoa fumigation campaign. In Brazil, the country's public prosecutor has written to the National Health Surveillance Agency (ANVISA) asking it to urgently re-evaluate their position on glyphosate.0 The letter was written with an expectation that the agency will ban the herbicide. Across South America, campaign groups and academics have seized upon the WHO findings and are calling for a ban on glyphosate. Prominent voices include the Federation of Health Professionals of Argentina and the Latin American Pesticide Action Network (a strong opponent of crop protection chemical use, in general). Europe The European Crop Protection Association supports the herbicide, saying the WHO report contradicted "the world's most robust and stringent regulatory systems — namely the European Union and the United States — in which crop protection products have undergone extensive reviews based on multi-year testing" and were not found to pose a cancer risk to humans.10 In September 2015, a key committee in the European Parliam ent, the Committee on the Environment, Public Health and Food Safety [ENVI], rejected a proposal to halt an extension in the use of Roundup.11 The Committee voted against the objection raised by the ENVI Rapporteur Katefina Konecna (a member of the Nordic Green Left faction), who tried to block the extension of the marketing of glyphosate until June 2016. According to a Commission spokesman, "Extending the approval period by six months will give EFSA [the European Food Safety Agency] time to finalize its scientific conclusions on glyphosate. On the renewal of the authorization, the Commission, in consultation with Member States, will take appropriate risk management action following the publication of the EFSA opinion". As part of the legal process required to renew authorization of its use in Europe, a peer review of glyphosate was undertaken. The re-assessment of glyphosate by EFSA, published in November 2015, concluded that glyphosate is unlikely to be genotoxic (i.e. damaging to DNA) or to pose a carcinogenic threat to humans.12 Glyphosate was therefore not proposed to be classified as carcinogenic under the EU regulation for classification, labeling and packaging of chemical substances. All Member State experts but one agreed that neither the epidemiological data (i.e. on humans) nor the evidence from animal studies demonstrated causality between exposure to glyphosate and the development of cancer in humans. However, EFSA did propose new safety measures to tighten the control of glyphosate residues in foodjs A peer review expert group made up of EFSA scientists and representatives from risk assessment bodies in EU Member States set an acute 8 http://www.newsweek.com/colombia-end-coca-farm-glyphosate-sprayings-a671aQ 9 http://www.globalresearch.ca/brazils-public-prosecutor-wants-to-ban-monsantos-chemicals-following-recent-glyphosate-cancer-link/s44Q440 10 http://www.politico.eu/article/bid-to-stop-monsanto-weedkiller-clears-eu-panel-roundup-gmo/ 11 http://www.globalresearch.ca/monsanto-sued-for-deliberate-falsification-to-conceal-that-glyphosate-roundup-is-harmful-to-humans-and-animals/5450548 12 http://www.agriland.ie/farming-news/glyphosate-unlikely-to-pose-carcinogenic-hazard-to-humans/ « http://www.ifst.org/food-safety/news/glyphosate-efsa-updates-toxicological-profile Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

reference dose (ARfD) for glyphosate of 0.5 mg per kg of body weight, the first time such an exposure threshold has been applied to the substance.^ EFSA will use the new toxicological values during its review of the maximum residue levels for glyphosate in food, which will be carried out in cooperation with Member States in 2016. The conclusion will additionally be used by the European Commission in deciding whether or not to keep glyphosate on the EU list of approved active substances, and by EU Member States to re-assess the safety of pesticide products containing glyphosate that are used in their territories".^ The ruling by EFSA has proved controversial and their re-assessment was widely criticised, in particular by Professor Christopher Porter, one of the scientists who contributed to the report on glyphosate by IARC.16 In an unusual step, 96 prominent experts, including almost the whole IARC team, called for the EFSA decision to be disregarded.1 ? This is largely owing to the claim EFSA's ruling was based on "secret, non peer-reviewed, industry-funded studies".18 More recently, it has been reported by the UK newspaper The Guardian (who claim to have had visibility of a draft implementing law) that the "European Commission is poised to renew the license for glyphosate".^ However, four EU member states, Italy, France, Sweden, and the Netherlands have delayed the vote on the 15 year relicense of glyphosate at a meeting in Brussels on 7 March 2016. If no new proposal on glyphosate usage is adopted, the licence for glyphosate will expire in June 2016.20 The Guardian has played an active role in discussions around use of this herbicide. In April 2015 they called for ccities in the UK to stop using glyphosate to control weeds in parks and along verges. Civil society has also campaigned strongly against the use of glyphosate, with a prominent role being played by Greenpeace and the Soil Association.21 Despite government officials declaring it safe to use, some retail outlets in Europe have taken glyphosate off their shelves. As of September 30, 2015 more than 350 'toom Baumarkt DIY' stores belonging to the Revisionsverband der Westkauf-Genossenschaften Group [REWE] in Germ any removed any product containing the chemical. France has announced a ban on over the counter sales from garden centers and in the UK. Pesticides Action Network, a British anti-pesticides campaign group, wrote to garden centers including B&Q, Notcutts, Homebase and Dobbies asking them to withdraw glyphosate products from sales as well. In the Netherlands, a ban on the non-commercial use of glyphosate took effect from the end of 2015 (this excludes agricultural use).22 In 2003, Denmark took an early stance and enforced legal restrictions on the spraying of glyphosate.2 3 In February 2016 Segolene Royal, France's minister of ecology, sustainable development and energy, called for ANSES—France's food, environment and health agency—to withdraw authorizations on herbicides containing glyphosate mixed with the adjuvant tallow amine.2 4 !4 http://wWW.efsa.eUrOpa.eu/en/preSS/neWS/i5ili2 !5 http://wWW.efsa.eUrOpa.eu/sites/default/files/43O2_glyphoSate_COmplementary.pdf 16 http://www.efsa.europa.eu/en/press/news/160113 J 7 http://wWW.thegUardian.COm/envirOnment/2Ol6/feb/24/weedkiller-glyphoSate-COntrOVersial-eUrOpean-COmmission-planS-relicenSe l8http://www.theecologist.org/News/news_round_up/2987279/another_i5_years_eu_set_to_relicense_glyphosate.html J 9 http://www.theguardian.com/environment/2016/feb/24/weedkiller-glyphosate-controversial-european-commission-plans-relicense 20 http://www.theguardian.com/environment/2016/mar/08/eu-vote-on-controversial-weedkiller-licence-postponed-glyphosate 21http://act.greenpeace.org/ea-action/action?ea.client.id=i844Sz:ea.campaign.id=37624 22 http://www.collective-evolution.com/2015/05/30/why-the-netherlands-just-banned-monsantos-glyphosate-based-herbicides/ 2 s http://www.lobbywatch.org/archive2.asp?arcid= 1424 2 4 http://truth-out.org/buzzflash/commentary/french-ecology-minister-calls-for-ban-on-glyphosate-formulations Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Eurasia and Africa In South Africa, the Department of Agriculture is determining whether glyphosate, contained within about too locally used pesticides should be regulated. According to a departmental spokesperson, "The Department of Agriculture, Forestry and Fisheries takes the IARC's findings very seriously and will examine the data and assessment done for the IARC classification and determine whether any regulatory action is necessary." Asia Pacific Provinces in China have recently conducted risk reviews of four pesticide products - acephate, carbosulfan, dimethoate, and thiodicarb - in response to a request by the Chinese Institute for the Control of Agrochemicals, Ministry of Agriculture. Among other things, the initiative aims to establish the safety risks associated with the pesticides. In a rare example of a lawsuit by private citizens against the Chinese government, three Chinese citizens are taking China's Ministry of Agriculture to court in a bid to make public a toxicology report supporting the approval of Monsanto's weed killer, Roundup, 27 years ago. Remaining in China, through an open letter, ten European non-profit groups have asked the Chinese people to take action to help clean up the world food supply. The action was inspired by the recent WHO IARC report. In New Zealand, Tauranga City Council has moved to phase out the use of glyphosate in parks and reserves through trialing a mixture of pine oil and fatty acids as an alternative weed killer. Upon his election, Sri Lankan President, Maithripala Sirisena, announced a ban on the importation of glyphosate.2 s 2 5http://www.globalresearch.ca/sri-lankas-president-bans-glyphosate-nationwide-to-protect-the-health-of-t^ Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Front of Pack Labeling Executive Summary April 2016 Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Global In Decemember 2015 the World Health Organisation's (WHO) Department of Nutrition for Health and Development, jointly with the WHO Regional Office for Europe held a technical meeting to review the available evidence and compile various country experiences and lessons learned in order to develop guiding principles and a guidance framework for implementing "front-of-pack" (FOP) labeling. The main objectives of the meeting were to: • review the types of front-of-pack labeling systems that are currently being implemented or proposed and identify their benefits and limitations • review and assess the evidence on the effectiveness of different types of front-of-pack labeling systems • review case studies of countries with experience in implementing front-of-pack labeling • identify issues and considerations for the design and implementation of front-of-pack labeling systems in order to develop guiding principles and a guidance framework for implementing front-of-pack labeling The expected outcome of the meeting is to develop guiding principles and a guidance framework to be provided to countries in implementing FOP labeling systems.1 Organized by the non-profit Center for Science in the Public Interest (CSPI) in Washington, DC, The World Public Health Nutrition Association, World Obesity Federation, Consumers International, and health groups from around the globe wrote to Coca-Cola CEO Muhtar Kent and PepsiCo CEO Indra Nooyi. The letter was also sent to the companies'major institutional investors for their consideration at Coca-Cola's annual meeting on April 27 and PepsiCo's meeting on May 4. The letter called for the companies to exercise its social responsibility to the global community by: • Acknowledging that heavy consumption of its full-calorie soft drinks contributes to obesity and other health problems; • Adopting and enforcing a policy of not marketing sugar drinks to children so that it covers children 16 and under and lowering the action level for children in audiences from 35 percent to 25 percent; • Reducing container sizes (for instance, no container larger than 1.5 liters, with smaller containers reduced in size); • Including a notice on SSB containers disclosing the adverse health effects that consumption of the drinks may cause; • Reducing the calorie content of SSBs to no more than 40 calories per 355 ml (12 ounces); • Ceasing your company's opposition to governmental measures, such as beverage taxes, warning labels, and marketing restrictions, aimed at reducing the harm from sugar drinks; • Discontinue advertising and indirect promotions (such as sponsorships that feature brand names) of full-calorie beverages, but rather promote unsweetened beverages. 1 http://www.who.int/nutrition/events/2015 meeting nutrition labeling diet 9tolldec/en/ Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

x - s s v ; ^-kN -Xso |::::::::::::::| si «fiw OXl"1 O^XJX \ ^ w PPHCI H^.;^ om\p, m« m iwmtm'i %'r»Vw\f \>\^J«« x-$"'-^-"1 '-"*" *^'- so^ "un^^e v •••»« >V S \** \! *v. I I P r^smip Iks", 20 0 m P^Fcp pskmss",^ &&ngMftl P FOP1 fes^m Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

North America There is no mandatory FOP labeling legislated in the U.S., yet companies are beginning to apply fact-based FOP labeling as part of the Clear on Calories (American Beverage Association), Facts Up Front Grocery Manufacturers Association (GMA) and Food Marketing Institute (FMI) program. Members of the Canadian Beverage Association adopted a Clear on Calories program that is similar to the United States'program.2 Political & Regulatory Action • The U.S. Food and Drug Administration (FDA) has proposed regulations that would require food labels to declare the quantity of "Added Sugars" in addition to "Total Sugars" and establish a 50 g/d Daily Value for "added sugars". Final regulations are anticipated in 2016. Changes to the U.S. Nutrition Facts Panel to indicate the "added sugar" in packaged foods and a Daily Reference Value (DRV) have been vaunted, but it remains contested exactly how the Nutrition Facts Panel will be altered to reflect these changes.3 To date the food industry has raised three main objections: o The public won't know what to make of the information on added sugar; o The science suggesting that added sugars should be limited is not conclusive; o Almost all packaged foods labels already list added sugars.4 • In New York, the Sugar-Sweetened Beverages Safety Warning Act would make it a requirement for those drinks to carry a warning stating: "Drinking beverages with added sugar contributes to obesity, diabetes, and tooth decay." The legislation is currently pending in the state Assembly. 26 scientists and researchers have come out in support of this legislation saying that the legislation follows the recommendations and science of the recently released Dietary Guidelines for Americans (DGA) that calls for limiting consumption of sugary drinks.5 • In California, the sugar-sweetened beverages safety warning act (SB 203), which would have required that warning labels are placed on sugary drink containers, failed by one vote in the Senate Health Committee on April 29, 2015. After being considered again in January 2016 the Bill yet again failed to move out of the Senate Health Committee.6 This is all despite widespread support from voters. Afield poll carried out in January 2016 found nearly four out of five registered voters polled (78 percent) support required warning labels to be printed on sugary drinks, up from 74 percent two years ago.7 • In Hawaii Senator Gabbard introduced Senate Bill 1270 which would require safety warning labels on all sugar sweetened beverages sold in Hawaii. This legislation died in committee in February 2015.8 • In June 2015 Canada released its new Nutrition Facts panels for consultation. The proposal included a "% daily value" label for sugar. The new panel will not make the distinction between "added" sugar and natural sugars as is being proposed by the U.S. FDA. The added sugars declaration in nutrition labeling was dropped after an initial consultation. The newly proposed regulations would require grouping all "sugars" together in the ingredient declaration on food labels (e.g., "sugars (sugar, high fructose corn syrup, honey, molasses)"). There is no current Canadian government 2 http:// www.canadianbeverage.ca/nutrition/calories/ 3 hitP-7/w/*w_.W^^^ 4 http://www.bloombergview.com/articles/2016-01-14/add-a-little-sugar-to-nutrition-labels 5 https://www.cspinet.org/new/201602181.html 6 http://civileats.com/2016/01/14/california-soda-warning-label-bill-dies-as-research-suggests-efficacy/ 7 http://www.publichealthadvocacy.org/resources/warninglabel/January%20Field%20Poll SSB.pdf http:/ / www.kickthecan .info/ legislative-campaign s Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

proposal for FOP labeling. Revision to Canadian nutrition labeling regulations was anticipated to be finalized by 2017, but the new government s review of all regulations could delay implementation further, and "added sugars" could return in a revised proposal. Campaign Activity and Research • A study on over 2,000 parents examining the effects of warning labels on purchasing decisions found that significantly fewer parents (40%) chose a SSB for their children when the packaging contained a message along the lines of "Drinking beverages with added sugar(s) contributes to obesity, diabetes, and tooth decay" compared to when no message was present.910 Latin America Chile, Mexico, Ecuador and Peru introduced varying formats of mandatory labeling. Chile published "High In [calories, fat, salt, sugar]" labeling December 2013. Anew "Excessive in" icon was planned which would apply to approximately 60% of TCCC products in 2015. In Mexico, calories and sugar content had to be displayed per serving and per container. Ecuador opted for traffic light labeling and Peru adopted fact based labeling: "High in [Sat Fat] [Sugar] [Salt]: Avoid excessive consumption". Brazil, Colombia, Argentina and Costa Rica enacted voluntary FOP schemes, whilst in Venezuela there is a proposal for sugar-sweetened beverages to have a health warning on their labels. Political & Regulatory Action • In June 2015, Chile approved regulatory norms defining limits for calories (275 calories/lOOg or 70 calories/ lOOmL), and sugar (lOg/lOOg or 5g/ lOOmL) content.11 All foods that exceed these limits will have a FOP black and white warning message inside a stop sign that reads "HIGH IN" followed by CAFORIES, SUGAR etc., alongside the words - "Ministry of Health". Size requirements for the symbol on beverage labels/packages are onerous (7.5% up to 50% of front panel space). The regulation is anticipated to affect 50% of TCCC's portfolio in Chile. Warning messages are scheduled to take effect 1 July 2016. • Brazil is exploring a UK-style FOP color-coded approach (the industry has submitted a non-color coded approach to counter). • The Ministry of Health (MoH) in Ecuador has presented a proposal for Food Advertising and Promotion Regulation, which will require that some foods/beverages carry the statement, "Product high in [fat/sat fat/sugar/salt]" depending on nutrient composition. Government has already adopted requirements for color-coded labeling. Regulations apply to full sugar soft drinks, teas, nectars and drinks with low fruit content. 9 http://healthyeatingresearch.org/research/the-influence-of-sugar-sweetened-beverage-health-warning-labels-on-parents-choices/ 10 http://pediatrics.aappublications.org/content/early/2016/01/ 13/peds.2015-3185 11 And also saturated fat (4g/ lOOg or 3g/ lOOmL), and sodium (400mg/ lOOg or lOOmg/ lOOmL) Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

The Venezuelan Ministry of Health issued a new regulation about the labeling of sugar-sweetened beverages (SSB). The labels must include one of three warnings: o "Consumption of SSDs increases the risk of diabetes, heart problems, heart attack, cancer, osteoporosis, and tooth decay and erosion"; o "SSDs contain high levels of phosphoric acid that have been associated with kidney stones and other renal problems"; o "Consumption of SSDs contributes to obesity". The warning statement must rotate every 6 months and it must be sized between 15-20% of the label area. The implementation of this labeling regulation has been postponed indefinitely. In Peru a regulation for a "high in sugar" label is under consideration and it is likely that the label will be color coded. In February 2016, the Pan American Health Organization (PAHO) Nutrient Profile Model (NPM) was published. 12 The aim of the model is to be used as a tool in the design and implementation of strategies relating to the prevention and control of overweight/obesity and improving healthful diets. PAHO recommends governments throughout the Americas use the NPM in policymaking, with broad application to: marketing restrictions, school foods & beverages, FOP "warning" labels, taxation, agriculture subsidies, and food assistance programs. The NPM defines "processed" and "ultra-processed" foods and beverages, and exempts unprocessed and minimally processed foods (100% fruit juice, plain waters). All "cola, soda, and other soft drinks; sweetened juices and energy drinks" are defined as "ultra-processed." 100% fruit or vegetable juice are defined as "minimally processed" and exempt; as well as "culinary ingredients" including sugar and honey. "Excessive in free sugars" is defined as > 10% energy from "free sugars" - almost all caloric beverages will be excessive in free sugars. "Excessive in other sweeteners" is defined as "Any amount of other sweeteners." "Excessive in sodium" is defined as ">1 mg of sodium per 1 kcal" and would apply to caloric sports drinks. The energy- and ingredient-based standards in the PAHO NPM are the strictest globally proposed standards for foods and beverages to date. Competitor and Peer Activity In response to the possible evaluation of nutritional information systems in Colombia, TCCC in partnership with Kellogg's, Nestle and Kraft, has joined with ILSI Nor-Andean to develop a strategy that demonstrates the benefits of fact-based GDA/FOP labeling, versus alternative approaches. In Costa Rica manufacturers are applying a fact based FOP system on a voluntary basis. Through the Codex Coordinating Committee for Latin America (CCLAC), Costa Rica is calling for a guideline that will standardize FOP labeling in order to reduce barriers to trade.13 12http://iris.paho.org/xmlui/bitstream/handle/123456789/18621/9789275118733 eng.pdf?sequence=8&isAllowed=v 13 Coca Cola FOP tracker Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Europe FOP nutrition labeling had been applied on a voluntary basis. The 'better for you' approach had proven the most popular, with the Netherlands, Finland, Norway, Denmark, Sweden, Iceland, Belgium, the Czech Republic, Poland and Slovenia using it. The UK has implemented a combination of color coding and GDA (now called Reference Intakes [RI]) for its voluntary scheme. Political & Regulatory Action • In Norway, Denmark, Sweden and Iceland the "nordic keyhole" voluntary labeling scheme of, new, stricter requirements came into force 1 March 2015, with a transition period until 1 September 2016 for products adhering to the old requirements. Keyhole products will need to contain less salt, sugar and saturated fat. The Keyhole labeling system has been criticized by the Norwegian Medical Association, as they believe in some cases it is directly misleading. The Norwegian Consumer Council would prefer to see labeling that identifies unhealthy rather than healthy products.14 • The new EU Regulation No 1169/2011 on the provision of food information to consumers entered into application on 13 December 2014. The obligation to provide nutrition information will apply from 13 December 2016.15 • France's new health law, which includes the creation of a uniform, voluntary FOP food nutritional labeling system, passed in the National Assembly. The public health bill was adopted on December 17th. As planned it introduces the project of a voluntary nutritional labeling scheme, after conducting consumers 'in store' test of various schemes, including the UK color-coded GDA. The consumer test should start in March, results expecting by end of 2016.16 Campaign Activity and Research • In the UK there has been no concrete developments, although campaigners from the Local Government Association (LGA), which represents over 370 councils in England and Wales, have argued that fizzy drinks and fruit juices containing up to 12 teaspoons of sugar should carry a health warning. • The University of Birmingham argued that food labels currently used, "can be confusing" and questioned the efficacy of traffic light labeling.17 There is an ongoing debate about the type of food labeling that will best resonate with consumers with the Royal Society for Public Health suggesting that labeling should include new measures which show how much exercise is needed to burn calories.1819 A popular idea with both campaigners and 14 http://www.eurofoodlaw.com/labeling/norways-keyhole-food-labeling-scheme-misleading--l.htm 15 http://ec.europa.eu/food/safety/labeling nutrition/labeling legislation/index en.htm 16 Coca Cola Regulatory Update J an 2016 17 http://dx.doi.org/ 10.1362/ 147539215X14267608004087 18 http://www.fratinivergano.eu/en/issue-number-2-29th-ianuary-2016/ 19 http://www.theguardian.com/lifeandstvle/2016/ian/15/link-calories-minutes-exercise-food-health-bodv-royal-societv-packaging Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

public health advocates, particularly some in the Health Select Committee is an approach where the number of teaspoons of sugar in the product is shown on the label.20 • A study conducted at Oxford University found that packaged food manufacturers participating in voluntary adoption of FOP labeling introduce more innovative and nutritionally better products compared to non-participating companies.21 • A study has concluded that the graded 5-Color Nutrition Label is considered by French consumers as easy to identify, simple and rapid to understand. The authors believe this type of label is likely to present advantages in real shopping situations where choices are usually made quickly and is more suitable than Multiple Traffic Lights and Guideline Daily Amounts labels.22 Competitor and Peer Activity • The Belgian Federation for Commerce and Services is considering whether to use FOP labeling on 'own label' products in major supermarkets. It has not yet decided whether to launch a FOP labels.23 • French retailers have unveiled their own 'simplified' nutrition label. In their version they have removed the red traffic light that they cast as discriminatory against certain foods. Working with Federation des Enterprises du Commerce et de la Distribution - Carrefour, Auchan and Casino have all gotten behind the four color version that aims to support French consumer in making better choices.24 An algorithm is used to calculate the nutritional value of the product, which then results in the colour of a symbol. These colours, in turn, represent different indicators of how frequently the food in question may be consumed.25 20 http://diabetes-appg.co.uk/2015/ 10/20/iamie-oliver-attends-appg-for-diabetes-meeting-calls-on-government-to-be-brave-for-childrens-health/ 21 http:// www.choicesprogramme.or g/ news-updates/ news 22 http://www.idfdairynutrition.org/ListPage.php?siteID=260&ID=335&specialHeaderID=325 23 http://www.babymilkaction.org/wp-content/uploads/2015/12/EUFOODPOLICYissuel8DecemberM.pdf 24 http://www.foodanddrinkeurope.com/Retail/French-retailers-unveil-alternative-nutrition-label 25 http://www.fratinivergano.eu/en/issue-number-21-20th-november-2015/ Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Asia Pacific Fact-based schemes are in place in the Philippines, Malaysia26 and Indonesia. Australia has developed a Health Star Rating system with a nutrient component for constituents including sugars. New Zealand had indicated it will also implement the Health Star Rating system. South Korea was the first SE Asian country to reject color coded labeling. Thailand applied a voluntary statement "Not low-energy product". Singapore has implemented a voluntary Healthier Choice Symbol and Hong Kong, Macau, Cambodia and Japan have implemented other voluntary fact￾based systems. In response to the clear inconsistency in the region, the ASEAN regional initiative was working to develop regionally consistent non￾pejorative FOP labeling guidelines. Political & Regulatory Action • In Thailand there are ongoing discussions between the FDA, Nutrition Institute and Choices International with a view to using the Healthier Choices interpretive symbol. The Thai food industry is developing an alternative food industry position. The GDA type labeling scheme was introduced in 2011 and is mandatory for five priority snack food groups.27 • In Singapore a refreshed Healthier Choice Symbol, based on revised nutrient guidelines, will take effect from September 2015 and existing products with the current HCS logo will have to be depleted by 1 January 2018. Products carrying the current HCS will need to re-apply to carry the revised symbol. Low- and nO-calorie sweeteners no longer disqualify beverages from using the logo. • In New Zealand at the Labour party's annual conference the deputy leader outlined new policy that would require FOP labeling based around the number of teaspoons of sugar in a product.28 Campaign Activity and Research • One research study concluded that the Health Star Rating System adopted in Australia and New Zealand is more suitable to label beverages than the Traffic Light System and % Daily Intake label based on better utility, applicability and ease of identifying healthier choices; but more research and evaluation is needed.29 26 http://www.slideshare.net/Adrienna/status-of-fops-in-the-asian-region2015 27 http://www.slideshare.net/Adrienna/status-of-fops-in-the-asian-region2015 28 http://www.stuff.co.nz/national/politics/73794665/Labour-to-set-timetable-for-firms-to-cut-sugar-in-food 29 http:// www.readcube.com/ articles/ 10.1111%2F 1747- 0080.12257?r3 referer=wol&tracking action=preview click&show checkout=l&purchase referrer=onlinelibrary.wiley.com&purchase site license= LI CENSE DENIED Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Eurasia, Africa and Middle East Labeling regulation in South Africa established rules for voluntary FOP labeling. There is a traffic light requirement and nutrients to be included per serving: energy (in kJ), total sugar, fat, sat fat, total sodium and salt equivalent. There will also be a traffic light color coding requirement. A Russian bill was in the process of being developed, which sought to force manufacturers to display warnings on HFSS packaging. The consensus was that international politicking was taking place, with the initiative targeted at large fast-food international food chains such as McDonald's and Burger King. To date the bill has not come into law. Across the Middle East, Eurasia and Africa manufacturers are adopting voluntary fact based FOP labeling schemes. There is evidence of this occurring in Georgia, Uzbekistan, Azerbaijan, Kyrgyzstan, Kazakhstan, Tajikistan, Armenia, Turkmenistan, Bahrain, Oman, Iraq, Iran, Jordan, Lebanon, Qatar, Saudi Arabia, Syria, UAE, Belarus, Ukraine, China, Turkey, Egypt, Morocco, and Mozambique. 3 0 Political & Regulatory Action • The South African government is working on nutrient profiling for foods and beverages; discussions continue on color-coded labeling. Major revisions to food labeling regulations, including nutrition and FOP labeling is being finalized. • In Israel, FOP GDAs are currently allowed until the government decides on a tablet approach. Color coded labeling is one option which is of interest to the Ministry of Health. 30 Coca-Cola FOP Tracker 2014 Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Appendix i^Wii^^^^^^i.:.^:.:.^:.:.^ iflW^HI^^^^^^^ iHHHHHiHiH ^ AHHIHHif c i^^pyw^^^^^^i.c-^^ North America US Canada • Clear on Calories and Facts up Front Schemes • • The Canadian Beverage Association has adopted a Clear on Calories program • State law proposed in New York to require sugary sodas to carry a health warning + Hawaii • Nutritional facts panels out for consultation %M$IBJM$$mmmmmmmmm i^l^HI^W^^^^^^ ^ d^^y^ra^^^^^^^ ggi^^^^mH^^^M^ ^l^P^l^^^^^^^^ Latin America PAHO 11^^^^=^^=^^=^^= ^ siil; ^ slle^ ^ st?;i^ • High in [calories, fat, sugar and salt] approved in 2015 • Amount of calories and sugar present (sugar as calories and a % of recommended daily intake) • Calorie declaration per serving and per container • "High in [Sat Fat] [Sugar] [Salt]: Avoid excessive consumption". • In February 20 16 the Pan America Health Organization Nutrient Profile Model was published • Traffic light labeling for fat, salt and sugar • Color-coded label expresses "sugar". Final • Consideration of traffic light labeling • Proposal to label products high in sugar etc • New high in sugar label under consideration + possible color coding Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

iiMi^Mi^^mmmmimmmmm ^^^M^^^^^^^^^^^m •^MMMBMMBM&Bmmmmm® •^MMB^^MMM^M^MB^m d^Hip^ii^^^^^^^^^^ Latin America Brazil Colombia Costa Rica Argentina Beverages with >8.1 g sugar/100 ml would bear the warning • Manufacturers are applying a fact based FOP system on a voluntary basis • Manufacturers are applying a fact based FOP system on a voluntary basis • Manufacturers are applying a fact based FOP system on a voluntary basis regulation on labeling style yet to be published Traffic lighting system proposed Through the Codex Coordinating Committee for Latin America (CCLAC), it calls for the Codex Committee on Food Labeling (CCFL) to develop a guideline on FOP labeling based on sound science. Likely for 2015. ^MBB^mmmmmmmmmmmm di^^y^^^^^^^^^^^^ d^Hrt^M^a^^^^^^^ '^MiW^^M§MM^§MW^%^ d^^^^il^^^^^^^^^^ Europe France UK Netherlands Finland • GDA • GDA • "Choices logo" distinguishes healthier products based on fats, sugars, salt and fiber • Heart logo applies to products low in fat, salt, • Color Coding • New proposed voluntary FOP labeling included in Health Law Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

iiMi^Mi^^mmmmimmmmm ^^^M^^^^^^^^^^^m •^MMMBMMBM&Bmmmmm® •^MMB^^MMM^^MM^B^ iMMIM^^mmmmmmmmmmm Europe ^H^^^^^^^^^^^^ $lliiie;J&^^ cholesterol sugars and fiber • "Nordic Keyhole" scheme • "Choices logo". See Netherlands • Slovenian Heart Foundation logo based on content of fats, sugars, cholesterol, sodium, fiber and energy • New criteria of Nordic Keyhole being adopted • Traffic light labeling under consideration but little progress ^^^^^^^^^^^^^ ^ y^w^^^^^^^^^^ ^H^y^^^^^^^^^ ^^^^H^W^^^^k ^^^^^^^^^^^^^ ^ ^B^^aM^I^^^I^ ^ w $ ^ ^S^^^^^^^^^^^^ ^ iisiHi^^^^^^^^^ ^ ^1^^^^^^^^^^^ ^ iiii^iii^ ^ ssE|ppT,^?Eilfaasitiai*sssss sli&fc&&^^ • Nutrients, including salt, per serving • Energy per serving in calories and % of GDA • GDA- Coordinated through GCCFBA Alliance • Health logo - "Weqaya" • Traffic light color coding Considering color coded labeling • Bill being developed which forces fact based labeling of HFSS products • Government is working on a regulatory approach - considering color coding • National Action Plan advocates traffic light labeling Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

iiMi^Mi^^mmmmimmmmm ^^^M^^^^^^^^^^^m •^MMMBMMBM&Bmmmmm® •^MMB^^MMM^^MM^B^ iMMIM^^mmmmmmmmmmm Eurasia and Africa Qatar, Saudi Arabia, Syria, UAE Georgia, Kyrgyzstan, Azerbaijan, Uzbekistan, Kazkhstan, Tajikistan, Armenia, Turkmen is' Belarus, Ukraine, Turkey, India, Mozambique' • Manufacturers are applying a fact based FOP system on a voluntary basis $$8M^$^^^^^^^^m ¥:::»::¥:¥:¥:¥:¥^ «m&mm®&Mtemmmmmmm® WSftWSSSW^^ WSj^WSiWSWS^ m^s^^s^^^Mi^^^^^^^mm^^i^Mmi^^m^^m^^m W^¥:¥:W:W:W^ Mgffikffl&Mffl&mmmmmmmgm Asia Pacific Philippines Australia Thailand Malaysia • Mandatory FOP calories information was launched in early 2013 • Health Star Rating system adopted in 2014. Voluntary for five years reviewed in two. Fists nutrient components and gives a star rating. Beverages only provide energy(kJ) • AFGC Daily Intake Fabel also lists nutrients • GDAwith calories and %NRV • Voluntary energy label requires amount per serving and percent of daily value • Voluntary Wise Eat" seal considers fat, sugar, sodium and fiber • Voluntary for beverages with disclosure "not low energy product" • Government considering implementing a symbol Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

iiMi^Mi^^mmmmimmmmm ^^^M^^^^^^^^^^^m •^MMMBMMBM&Bmmmmm® •^MMB^^MMM^^MM^B^ d^^ip^ii^^^^^^^^^^ Asia Pacific China South Korea New Zealand Singapore Indonesia Hong Kong, Macau, Cambodia Japan • Manufacturers are applying a fact based FOP system on a voluntary basis • Implement Australian Star Rating system. • Government requires that information for four nutrients appear on the FOP: energy, fat, sat. fat, sodium • Manufacturers are applying a fact based FOP system on a voluntary basis • "Food4Life" label divides food into "Everyday and "Sometimes" • "Healthier Choice" symbol- appliers to products lower in fat, sodium and sugar (updated) • Special Act on Safety Control of Children's Dietary Life recommends Color Codes labeling for sugars, fat and sodium similar to Singapore's "Healthy Choice" symbol • Considering a mandatory traffic light scheme and a mandatory reference daily intake label • Government considering amending labeling to include "added sugars" • Developing new guidelines for FOP GDA and to introduce voluntary GDAs for energy, fat, sodium and sugar • Warning labels for fat, salt and sugar are under consideration - for packaged food and fast food Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Genetically Modified Organisms and Food Biotechnology RAcnfiTiSH £snfi i fiTTiT'iAt'itiiJA T ^HHQPSITI A Rnp f VtlJLv/JLJLC4LJL C&JLJL\JL \y\/lllL/vLIL l V V< JLiCil l vlOi^CAL/ ^ Ullv l C_2 JT IT April 2016 Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

The Global Setting According to the World Health Organization (WHO): "GM foods currently available on the international market have passed safety assessments and are not likely to present risks for human health. In addition, no effects on human health have been shown as a result of the consumption of such foods by the general population in the countries where they have been approved. Continuous application of safety assessments based on the Codex Alimentarius principles and, where appropriate, adequate post market monitoring, should form the basis for ensuring the safety of GM foods".1 Codex developed principles for the human health risk analysis of Genetically Modified (GM) foods in 2003. Codex principles do not have a binding effect on national legislation, but are referred to specifically in the Agreement on the Application of Sanitary and Phytosanitary Measures of the World Trade Organization (SPS Agreement), and WTO Members are encouraged to harmonize national standards with Codex standards. The Cartagena Protocol on Biosafety, an environmental treaty legally binding for its Parties which took effect in 2003, regulates transboundary movements of Living Modified Organisms (LMOs).2 GM foods are within the scope of the Protocol only if they contain LMOs that are capable of transferring or replicating genetic material. The cornerstone of the Protocol is a requirement that exporters seek consent from importers before the first shipment of LMOs intended for release into the environment. 1 http://www.who.int/foodsafety/areas_work/food-technology/faq-genetically-modified-food/en/ 2 https://bch.cbd.int/protocol Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

C^QSds; I rf's.^ r {=1?3 1 Bobvs^; MOY'S /r^l^ i Russia: Ca^ntr I A0?i . ^Ij,,: ^ ,Vr-S? SOU^'s ^fnca. ?* \"\ ^ * \*%fc*t %sA -. *.A "7 : B ' -> * :51 S:Ji i 1 ^• :'^?:?:^^^V^-i— ^V*.-1 :^HP*: ^; $v\ 1-yN;:|\t<:'* •*"*• peat' s III! Ps^'YiS; Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

The Regional Landscape North America Political & Regulatory Action 2015 saw key developments in the United States, the world's largest producer of GMO crops. The Safe and Accurate Food Labeling Act of 2015 (HR 1599), sponsored by Representative Mike Pompeo, passed in the US House of Representatives in July, with strong bipartisan support. The legislation hopes to create a uniform, national system governing the premarket review and labeling of genetically engineered foods. It would also establish a national, voluntary framework for the labeling of foods either containing or not containing genetically engineered ingredients. It would therefore pre￾empt states from crafting their own laws mandating GMO labeling of products.3 On February 19 2016, Senate Agriculture Chairman Pat Roberts of Kansas introduced a similar bill to H.R. 1599, known as the National Food Labeling Proposal. The draft legislation would amend the Agricultural Marketing Act of 1946 by requiring the US Agriculture Department to set a national voluntary GMO labeling standard. It also requires the USDA to set up an education campaign providing "science-based information" to "address consumer acceptance of agricultural biotechnology".4 So far, Ve rm o n t is the only state to require the labels, which will take effect in July 2016 if it survives a legal challenge from the food industry. Maine and Connecticut have also passed laws requiring the labeling, but those measures don't take effect unless neighboring states follow suit. The country's largest food companies say GM foods are safe and that labeling would be misleading. They say a patchwork of laws around the country would be expensive for companies and confusing for consumers. Those supporting a move to mandatory labeling of GMOs see the introduction of the Bill seeking to amend the Agricultural Marketing Act as a clear attempt effort to subvert the July 1 deadline when Vermont's new law requiring mandatory labeling of foods containing GM ingredients goes into effect. In January 2016, Agriculture Secretary Tom Vilsack's reps met twice with activists and industry representatives on GMO labeling. The aim was to see if they could find a compromise about labeling food processed with genetic engineering but no compromise could be found, and it's unlikely there will be a third meeting. The two sides will continue to square off in Federal Court, in Congress, and State-by-State. In November 2015, the Food and Drug Administration approved the production and sale of the first GM salmon for human consumption. This marks a development from the USA's embrace of GM crops to the beginnings of a large domestic industry in GM livestocks 3 https://www.congress.gov/bill/114th-congress/house-bill/1599 4 http://www.naturalproductsinsider.com/blogs/insider-law/2016/02/senate-ag-chairman-roberts-introduces-dark-act.aspx 5 http://www.fda.gov/F0rC0nsumers/C0nsumerUpdates/ucm472487.htm Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

In Canada in July 2015, health officials stated that they could allow low levels of GM ingredients in imported food under proposed guidelines if modified ingredients are cultivated in countries that it considers safe. Campaign and Consumer Insights There has been a large scale response to the Senate's attempt to amend the Agricultural Marketing Act. The Grocery Manufacturers Association (GMA) thanked Senator Roberts for introducing the proposal, calling it the "common sense solution [that] will provide consumers with more information about ingredients in their food and beverage products and prevent a patchwork of confusing and costly state labeling mandates".6 The Environmental Working Group issued a statement condemning the proposed legislation, claiming it would "rob Americans of their right to know what's in their food and how it's grown." In March 2016, the Senate did not advance the bill also known as the "Denying Americans the Right to Know (DARK) Act" proposed by Senator Roberts. Many Senators feel that negotiations must continue around the contents of the bill and that anything less than "mandatory on-package labelling is unacceptable".? In February 2016 more than 1,600 scientists from a range of institutions in the USA and internationally signed a letter that claimed that public doubts about GM food crops may be hindering advances in agriculture and global food efficiency. In an open letter orchestrated by the Donald Danforth Plant Science Center in St. Louis and sent to the journal 'Science', the six authors argue that GM techniques are "an effective tool for advancing food security and reducing the negative environmental impacts of agriculture".8 Iowa State University has just been given the green light to conduct human trials on GM bananas with enhanced levels of Vitamin A. Participants will be paid $900 to participate in the trial and it is hoped that it may pave the way to a means for tackling vitamin A deficiency in developing countries.0 In 2015, following Freedom of Information Act (FOIA) requests from the US Right to Know (USRTK) group to numerous pro-GMO university researchers, it was revealed that Monsanto had paid an American university a $25,000 US dollar unrestricted grant, yet linked this payment directly to Dr Kevin Folta, Chairman of the Horticultural Sciences Department at the University of Florida. The Monsanto grant was one of several funding sources for science communications training. In February 2016, the state of Washington's Attorney General launched a lawsuit seeking $14 million from the Grocery Manufacturers Association (GMA), alleging GMA created an "elaborate scheme" to secretly fund a multimillion dollar campaign to kill a GMO food labelling initiative. It is claimed that private companies including, PepsiCo, TCCC, General Mills and Nestle donated funds intended to prevent proper food labeling.10 On 4 February 2016, more than two dozen people testified at a hearing on US House Bill 4122, which would repeal the 2013 legislation prohibiting local governments from regulating crops or seeds. The Bill seeks to restore local control over GM crops.11 The Legislative Committee was told that Oregon farmers are suffering real financial losses because of contamination from nearby genetically engineered crops. 6 http://www.gmaonline.org/news-events/newsroom/gma-calls-on-senate-to-act-quickly-on-roberts￾7 http://ecowatch.com/2016/03/16/senate-rejects-dark-act-gmo-labeling/ 8 http://www.foodbusinessnews.net/ articles/news_home/Regulatow_News/20i6/02/More_than_i6oo_sign_petition_o.aspx?ID=%7BiA9C78AD-888o-45B5-9862- 72DE82E937CA%7D 9 http://www.foodandwaterwatch.org/insight/iowa-state-university-goes-bananas-over-gmos 10 http://organicconnectmag.com/project/gmo-labeling-opposition-sued-washington-state-laundering-campaign-funds/ 11 http://www.capitalpress.com/Oregon/20160204/oregon-seed-pre-emption-law-challenged-in-legislature Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Monsanto has recently released a statement to the effect that they support efforts to label GMOs despite reports that say the chemical company is trying to block legislation. Federal lobby disclosure forms from big food and biotechnology companies and their trade groups opposed to mandatory GMO labeling reveal a surge in lobbying expenditures during the first half of 2015 in the U.S., according to an analysis by Environmental Working Group (EWG). The U.S. Department of Agriculture's Animal and Plant Health Inspection Service (APHIS) said the GM cotton and soybean plants are granted "non-regulated" status. Monsanto is still waiting for final approval from the Environmental Protection Agency for the herbicide it designed to be used with the crops. Sales of organic foods certified by the U.S. as free of synthetic chemicals or genetic engineering reached $35.9 billion in 2014, an 11% increase over 2013 and about 5.1% of U.S. grocery spending - according to U.S. Department of Agriculture (USDA) and trade association data. In Canada, teen Rachel Parent, has been the face for the GMO labelling battle in Canada. While passionate to this cause, she is daughter of Wayne Parent, a strong voice against GMOs, and founder of Canada's largest natural and organic purveyor, Nutrition House. A Consumers' Association of Canada - Decima Poll shows close to 90 percent of Canadians want mandatory GMO labeling.12 Latin America Political & Regulatory Action Brazil is the second largest genetically modified organism (GMO) crop producer behind the USA and the hectarage of GMO crops in the country is the fastest growing in the world. Labeling is required on products that contain more than 1% of GM materials. A 2012 court case in Brazil upheld the law requiring Nestle to label products containing more than 1% of GM materials. Law No. 11,105 defines the concept of a GMO, establishes authorization procedures for GMO research, and establishes rules for the production and marketing of GMOs.^ In January 2016 six companies were fined, including Nestle, PepsiCo and Mexican bakery Bimbo, with individual fines ranging from $277,400 to more than $1 million, for a total of roughly $3 million.^ In El Salvador, mandatory labeling of some GM foods would be required, but the law lacks implementation and enforcement provisions. In 2015, the country's farmers, working with non-GM seeds, outperformed Monsanto's biotech seed with record crop yields, enabling them to prevent Monsanto from supplying the country with its seeds.^ 12 http://www.manufacturing.net/news/20i5/07/canada-could-ok-low4evels-gmos-food-imports J 3 https://www.loc.gov/law/help/restrictions-on-gmos/brazil.php J 4 http://www.ibtimes.com/gmo-labeling-requirements-brazil-fines-nestle-pepsico-failing-disclose-genetically-2259921 J 5 http://gain.fas.usda.gov/Recent%20GAIN%20Publications/Agricultural%20Biotechnology%20Annual_San%20Salvador_El%20Salvador_6-23-2015.pdf Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

A number of countries in South America such as Venezuela, Peru, and Ecuador have totally banned the import and growth of GMOs.16 In 2015 Peru's Government published a scale of fines for those caught growing, selling, and transporting GMOs, with the highest penalty reaching $1.22 million after the ban had been criticized for not having clear deterrent and not being proactively enforced.1 ? In Venezuela lawmakers approved a new law in December 2015 that will impose even stricter regulations on hybrid seeds and ban transgenic seed research.18 Bolivia restricts the use of transgenic seeds, or GMOs, to just one variety of soybean resistant to the non-selective herbicide glyphosate. There is a movement from farmers within the country to regulate and allow the use of further types of GMO in order to promote competitiveness with other MERCOSUR countries.10 In Chile, all GM seeds grown in the country are exclusively for export.20 In November 2015 the Mexican Supreme Court blocked a move that would have allowed the cultivation of GMO soya in two of its states.21 Campaign and Consumer Insights In Mexico, in January 2015, the Mexican Chapter of the Permanent Peoples' Tribunal called on the Mexican Government to ban GM maize. The ruling warns that GM maize threatens to contaminate Mexico's roughly 60 native corn varieties. The tribunal spent three years gathering evidence from a number of organizations to support their claim. This included groups such as the Union of Scientists with Social Commitment who criticized the lack of transparency in the current process the government used to award the rights to plant GM maize. In October 2015, Monsanto claimed that it planned to double its sale of GM crops in Mexico. The company was seeking five permits to grow GMO corn in five areas in the north of the country claiming that the bioengineered crop is a ticket out of poverty for small farmers since it results in higher yields and profits. In November 2015 a federal judge upheld the provisional suspension that prohibits pertinent federal agencies from processing and granting the privilege of sowing or releasing into Mexico's ecosystem any transgenic maize.22 In January 2016, there was a large amount of publicity surrounding a potential link between Monsanto and Oxitec's GM mosquito program which has been operating across Brazil. The high level of publicity surrounding this claim is likely to have damaged the public opinion of GMOs in Brazil. Further, media incorrectly reported links between insecticides use to control mosquitos and microcephaly seen in infants born from mothers infected with the Zika virus. On March 31, 2016, the WHO and US Centers for Disease Control and Prevention (CDC) released statements that there is now scientific consensus that the Zika virus is linked to microcephaly, not chemicals used in mosquito abatement or GM mosquitos. Argentina is the third largest grower of biotech crops in the world, after the United States and Brazil. There is no specific regulation in Argentina in reference to labeling biotech products. In the province of Cordoba a resistance camp has managed to suspend construction of a new Monsanto GMO seed plant since the local council approved it in 2013. In February 2016 protest were sparked by news of the impending eviction of the resistance 16 http://www.scidev.net/global/biotechnology/news/ecuador-new-constitution-bans-gmo-and-biotechn !7 http://blogs.blouinnews.com/blouinbeatbusiness/2015/03/19/is-perus-ban-on-gmos-misguided/ 18 https://www.globalpolicy.org/component/content/article/221/46944.html J 9 http://www.telesurtv.net/english/news/Bolivia-Fails-to-Reach-an-Agreement-Over-GMO-Use-20150423-0035.html 20 https://translegalllc.wordpress.com/2013/09/05/genetically-modified-organisms-in-chile/ 21 http://naturalsociety.com/federal-judge-upholds-mexican-gm-ban-after-over-100-appeals-by-biotech/ 22 http://naturalsociety.com/federal-judge-upholds-mexican-gm-ban-after-over-100-appeals-by-biotech/ Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

camp. The negative feelings towards Monsanto are a result of perceived dangers of the widespread use of toxic chemicals in the production of GM crops for export.^ Public opinion in Argentina appears to be increasingly moving against GMOs. MAPO, the Argentine Movement for Organic Production (MAPO for its initials in Spanish), is the largest organic NGO in Argentina registered as a non-profit organization. It gathers all entities, people, companies or NGOs which are somehow involved with organic production, or otherwise makes contacts and agreements with small organizations in the interior of the country having to do with this activity. 24 In February 2015 the Peruvian Association of Consumers and Users criticized the government for not properly implementing mandatory labeling of certain ingredients in food, such as GMOs. Europe Political & Regulatory Action In February 2016 MEPs approved three separate objections to GMOs being authorized in the EU without Member State support. The MEPs claim that the European Commission should not authorize Glyphosate-tolerant GM soybeans in food and feed. They noted that glyphosate, an herbicide, is classified as "probably carcinogenic" by the WHO. These objections have been catalyzed by the rejected ruling on 28 October 2015 that would have enabled any EU Member State to restrict or prohibit the sale and use of EU-approved GMO food or feed on its territory. MEPs are now calling on the Commission to table a new proposal that they will consider workable.2 s The European Commission has awarded funding of €32.5 million to support the 43 EU Reference Laboratories in 2016 and 2017. The EU-RLs provide scientific and technical support to national laboratories on food and feed safety. The European Com m is s ion intends to rule on an important decision in 2016 on whether or not a new generation of genetic engineering techniques will be covered by EU GMO legislation. A great deal has been invested in these technologies by private corporations and it is therefore thought that lobbying activities will increase throughout the year.26 An amendment to a former European Commission ruling, passed in March 2015, permitted its member states to abstain from growing GMO crops, even if the specific GMO strain had already been authorized to be grown within the union. States were given an October 3, 2015, deadline to notify the Commission should they decide to exercise their "opt-out" option. In total, 19 countries chose to "opt-out", including: Austria, Belgium for the Wallonia region, Britain for Scotland, Wales and Northern Ireland, Bulgaria, Croatia, Cyprus, Denmark, France, Germany, 2 s http://www.telesurtv.net/english/news/Argentina-Protests-Monsanto-Toxicity-and-GMO-Plant-2016 2 4 http://www.mapo.org.ar/ 2 s https://www.agriland.ie/farming-news/gmos-authorised-eu-without-member-state-support-meps/ 26http://www.theecologist.org/News/news analysis/2Q87034/brussels biotech lobbys last push for gm 20 technologies to escape regulation.html Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Greece, Hungary, Italy, Latvia, Lithuania, Luxembourg, Malta, the Netherlands, Poland and Slovenia. Non-EU members Serbia and Switzerland are also strongly opposed to GMO.2 ? Campaign and Consumer Insights An EU-funded project has undertaken extensive feeding trials to further inform the debate on the safety of mandatory GM animal feeding studies in advance of an expected 2016 EU re-evaluation. The EU-funded GMO Risk Assessment and Communication of Evidence (GRACE) project was driven by the need to reconsider the value of rat feeding trials for the safety assessment of GM plants. The project also aimed to address the continued controversial debate on the safety of GM plants.28 In February 2016, the Transatlantic Consumer Dialogue is urging the negotiators of the Transatlantic Trade and Investment Partnership (TTIP) deal, not to echo controversial Trans-Pacific Partnership language that may liberalize trade restrictions for GMOs. The TCD represents a variety of consumer groups' interests with regard to U.S.-EU trade considerations. They claim that the exact language of the TTIP regarding GMOs dangerously loosens restrictions and invasive species could go undetected and gain footholds in the importing country. The group also expressed worry about the quality of scientific data that the text will call for.2 9 In response to the 2015 ban on GMOs in Scotland and Northern Ireland the former EU Chief Scientific Adviser, Professor Dame Anne Glover, called on the Scottish public in February 2016 to hold Holyrood to account and said that the Scottish Government's decision to outlaw the technology was not based on science. Speaking at a heated debate organized by the Fellows and Associates of the Royal Agricultural Societies Scottish Conference Prof Glover said: "The Scottish government did not ban GM on the basis of evidence - there has never been a technology more scrutinized than GM and scientists and numerous other bodies from throughout Europe, Asia and North America, say GM and GM technology is safe, and could transform people's lives".3° Responding to public concerns, the European Commission has fervently denied any claims that EU food safety standards, or other standards for that matter, would be lowered as a result of TTIP. European attitudes towards GMOs are marked by a low level of new legislative action as labeling of GMOs is the norm in EU markets. There is, however, a high degree of difference in consumer, farming and political attitudes towards GMOs across different EU markets. For example Finland has relatively high rates of consumer acceptability of GMOs but does not grow any GMO crops; Spain has moderate levels of support for GMOs and is Europe's largest producer of GMO crops; UK consumers are split on the issue, whilst many British farmers and politicians would like to be able to use more GMO crops. Germ an consumers and politicians are strongly against the sale and growth of GMOs in Germany. In February 2016 McDonald's revealed that their burgers may come from cows fed GM crops. Sourcing non-GM animal feed is becoming increasingly difficult and expensive, said Connor McVeigh, McDonald's Supply Chain Director. He said that the company's research found that customers did not want to eat GM crops directly but he suggested that they were willing to eat meat from animals fed on GM soy and corn.31 http://ecowatch.eom/201.s/10/o.s/european-union-ban-gmos/ 28 http://cordis.europa.eu/news/rcn/124740 en.html 2 9 http://www.law.260.com/articles/7617s8/consumer-group-warns-against-gmo-imports-under-ttip 3° http://www.thescottishfarmer.co.uk/news/top-scientist-backs-gmos.28s74ao8 3 1 http://www.thetimes.co.uk/tto/life/food/article46Q8141.ece Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Eurasia and Middle East Political & Regulatory Action: Azerbaijan is to toughen its existing laws on the use of GMOs. The State Committee for Standardization, Metrology, and Patents has decided to carry out measures to curb the circulation of products made from GM plants. Moreover, changes have been made to requirements on packaging and labeling in order to ensure that consumers are made aware of the lack of GMOs in food products. Despite these provisions, experts believe that GMO products are widely used in Azerbaijan and as a result the Government has found it necessary to launch a system of check-ups to identify cases of farmers using GMO seeds at grain-growing farms from March 2016 onwards.s2 In May 2015 Iran unveiled the first sample of GM cotton produced through indigenous technology by Iranian specialists. In the absence of clear regulations, the Ministry of Agriculture has approved repeated imports of GM crops such as rice, soybeans, rapeseed and edible oil. In September, a Senior Deputy Russian Prime Minister Arkady Dvorkovich told reporters that the cabinet had decided that any food production in the country will completely exclude GMOs: "As far as GMOs are concerned, we have made decision not to use any GMO in food productions". Although there has been no formal change to this statement, Monsanto's office remains in the country and neighboring countries such as Belarus and Kazakhstan continue to grow GM crops - with borders between growing countries difficult to police and regulate. Further on February 15 2016, a Russian national import ban on soybeans and corn imports from the United States took effect. Campaign and Consumer Insights An Israeli-Am erican collaboration is helping to develop a non-GMO alternative to better crop yields. The Israel-U.S. Binational Industrial Research and Development Foundation (BIRD) have funded a project that relies on the strong tradition of plant breeding in the Middle East. Africa Political & Regulatory Action Africa adopted a position similar to that of the EU in the early 2000s (see appendix, page 11). The primary concerns were about the impact on small scale farmers, health concerns and the perception of corporate colonialism. Having seen little evidence of health issues and the widespread adoption of GM crops by South American countries, African nations are now revising their position. The widespread drought that has affected a large number of Southern African nations at the start of 2016 has also seen a loosening of the restrictions on GMOs. As famine begins to settle in these nations, they 3 2 http://wWW.azerneWS.az/bUSineSS/Q2677.html Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

are quickly realizing the benefit of encouraging drought resistant crops with high yields.33 South Africa is currently the ninth largest producer of GM foods in the world and ministers have already announced that the country will relax some of its tough rules on GM crops so it can ramp up maize imports from the United States and Mexico to avert a potential food crisis amid a severe drought.34 Kenya is on the verge of reversing its ban on GMOs. Kenya banned the import and planting of GMOs since 2012 due to health concerns. If the ban is lifted, it will become only the fourth African country to allow the cultivation of GMO crops following South Africa, Bukina Faso & Sudan.35 Nigeria, Africa's second largest economy, has just passed legislation allowing GM crops to be grown. This has culminated in the new Biosafety law, the last Bill passed by President Goodluck Jonathan before leaving office at the end of 2015. It has been reported at the start of 2016 that due to regulatory framework issues the Government is struggling to implement the law. These activities coupled with food shortages and rising fuel costs mean the growth of GM crops is likely to accelerate in the coming years. Campaign and Consumer Insights As the use of GM crops and ingredients is becoming more commonplace in the continent, so is consumer activity against their use. In South Africa, for example, Nestle has already caved in to consumer pressure to remove GMO maize from their infant cereals The Inkatha Freedom Party (IFP) has called for GM foods in South Africa to be banned, pending an investigation into whether they can be toxic to humans. Monsanto and Gates Foundation are said to be actively supporting Kenya to lift ban on GMOs.36 Asia Pacific Political & Regulatory Action Hectare-for-hectare China's farmers produce one-fifth less cereal than the United States. This may be precipitating a thawing of attitude towards GMOs. The country's population is growing but their productivity is lagging behind other emerging economies. China has previously been very strict on GM crops due to health concerns but the recent bid for $43 million by ChemChina to buy the Swiss GM company Syngenta may demonstrate a change in attitude. ChemChina is state owned and Syngenta is one of the largest GMO companies in the world. This purchase, if successful, would launch China onto the GMO map in a significant way.37 33 https://weather.com/science/envlronment/news/south-africa-turns-to-gmos 34 http://www.planetark.com/enviro-news/item/74186 35 http://ecowatch.com/2016/01/07/kenya-gmo-ban/ 36 http://ecowatch.com/2016/01/07/kenya-gmo-ban/ 37 http://www.scmp.com/news/china/economy/article/iQOQ682/chemchinas-syngenta-bid-could-change-chinas-stance-gmo-foods Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Further to the ChemChina deal Chinese officials have issued warnings to seed dealers and farmers not to use unapproved GM seeds in the country's main crop belt, shortly after Greenpeace said it had found widespread GM contamination in corn.s8 Australia and New Zealand both have stringent border control policies for agricultural products. GMOs are regulated for import and for producing in small quantities. The labeling laws are also very similar to the European Union. In August 2015, the Australian Federal Senators backed a motion supporting GM crops as being an environmentally friendly farming technology supported by scientific rigor. In March 2015, the Australian Greens called on the Federal Government to establish a national contamination insurance scheme in order to ensure any loss of income associated with cleaning up a genetically modified contamination. It was funded by levies on GM crops. A six year long, well publicized case in Australia has recently been closed where a farmer was claiming $85,000 of damages because he claimed that contamination from a neighbors' GM crop had destroyed his organic accreditation. The courts found in favor of the GMO farmer in an uncharacteristic movement of support for GMO by the Australian government.39 A recent ruling by the New Zealand government that local councils should have the ability to decide whether or not they want GMOs is being fought through the courts and by protesters who are supporting a group of NZ farmers. The farmers claim that the introduction of GM crops will damage biodiversity and affect the purity of New Zealand's farming produce^0 In 2015 it was reported that Vietnam is considering using GM seeds in order to enable its farmers to remain competitive. After Taiwan's FDA issued GM labeling requirements in 2015, the country has gone one step further in 2016 by banning any GM additives or ingredients in school meals across the country. This move has been made as a precaution to protect the health of Taiwanese children but is also seen as a major knock to the Taiwanese GM industry.41 India is the fourth largest GMO producing nation in the world but it primarily grows GM Cotton. In February 2016 the Indian government, which currently does not allow the growing of GM crops, announced it is preparing to lift its import ban on corn for the first time in 16 years which could potentially open the doors to wider opportunities for the GMO industry in the future. India will receive 250,000 tons of non-GMO corn from South Korea's Daewoo International via Ukraine. Prime Minister Narendra Modi has advocated using biotechnology to improve farm productivity and even encouraged open GMO corn field trials after a five-year de facto ban.42 The Philippines was the first country in the region to allow planting and commercialization of GM corn, which it did in 2002, and has permitted GM crop imports for more than a decade. It is seen as a trailblazer of GM tech and, as of February 2016, the country expects to finalize a new set of rules on GMOs after a top court demanded an overhaul of previous regulations43. The new legislation is expected to tighten environmental scrutiny before bio-safety permits are issued and require suppliers of GMO products to provide more documentation to importers44. Fears have been raised that the 3 8 http://www.reuters.com/article/us-syngenta-ag-m-a-china-gmo-idUSKCNoVEoUA 39 http://www.alternet.org/food/organic-farmer-dealt-fina 4° http://www.nzherald.co.nz/hawkes4jay4oday/news/article.cfm7c id=isoa462&objectid=iis88aQ8 4 1 http://www.chinapost.com.tw^ 4 2 http://ecowatch.com/2016/02/18/india-gmo-contamination/ 43 http://www.reuters.com/article/us-philippines-gmo-idUSKCNoVXoDH 44 http://www.reuters.com/article/us-philippines-gmo-idUSKCNoVPoTE Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

halting of GM planting and issuance of new GM import permits as the Government works to finalize new legislation could result in a food crisis in the country.45 Campaign and Consumer Insights Origin Agritech Ltd., the Beijing-based firm that is China's leading agricultural biotechnology company, saw a rise in its share prices after a China Ag report stated that China was "3 to 5 years" away from commercializing GM corn. After the recent acquisition bid by ChemChina for Syngenta this process may be galvanized and accelerated. Report by Greenpeace suggests that Chinese farmers are illegally growing GMO corn. In its report, Greenpeace said 93% of samples taken last year from corn fields in five counties in Liaoning province, part of China's breadbasket, tested positive for GMO contamination. "Such reports have intensified public opposition to the technology, with some anti-GMO campaigners going as far as suing the government over the failure to disclose information about its approvals for imported GMO crops and plans to allow domestic cultivation. "46 Bill Gates has been publicly advocating for 'scuba' rice used in India that can be grown under water. The Bangladesh Rice Research Institute (BRRI) recently announced field trials of the world's first vitamin A-enriched rice, also called 'Golden Rice'. This comes in the wake of the same institute releasing the world's first zinc-rich rice variety in 2013. Global Industry Competitive Landscape In December 2015, the Grocery Manufacturers Association (GMA) announced that 30 major food, beverage (including TCCC), and consumer goods companies and GMA members were taking part in a SmartLabel™ initiative to enable consumers to have easy and instantaneous access to detailed information about thousands of products.47 By scanning a barcode from a smartphone or tablet with camera or barcode reader, consumers will be transported to a landing page with information on ingredients and other attributes of a wide range of food, beverage, pet care, household, and personal care products. By the end of 2017, companies are expecting to disclose via SmartLabel™ whether 20,000 food or beverage products do, may, or do not contain GMO ingredients. Food &Beverage Companies Campbell Soup In 2016 the Campbell Soup Company joined the list of global firms recommending GMO labeling at a national and regulated level. Campbell's President and CEO Denise Morrison wrote in a message to employees: "We now believe that proposing a mandatory national solution is necessary. Printing a 45 http://www.planetark.com/envlro-news/item/741s4 46 http://www.reuters.com/article/us-china-gmo-corn-idUSKBNoUK06B20160107 47 http://www.gmaonline.org/news-events/newsroom/new￾Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

clear and simple statement on the label is the best solution for consumers and for Campbell". Whilst it supports a mandatory national solution it opposes state-by state labeling laws calling them impractical and claiming it would confuse consumers.48 Campbell Soup continues to recognize GMOs as safe. Campbell's is taking part in the SmartLabel™ initiative. ConAgra Foods In March 2016, ConAgra Foods became the fourth U.S.-based company to voluntarily label products nationally. The company stated it "...will begin adding labels to products nationwide by July 2016 to meet Vermont's GMO labeling requirements. We stand behind the health and safety of all of our products, including those with genetically modified ingredients, and believe consumers should be informed as to what's in their food. But addressing state-by-state labeling requirements adds significant complications and costs for food companies. With a multitude of other states currently considering different GMO labeling requirements, the need for a national, uniform approach in this area is as critical as ever. That's why we continue to urge Congress to pass a national solution as quickly as possible."49 Dr. Pepper Snapple Group Dr. Pepper Snapple Group does not have a public position on GMOs. Ferrero 100% of the sugar and soy lecithin that Ferrero sources is non-GMO. In its 2014 Corporate Social Responsibility (CSR) report, it states that it has always sourced non-GMO soy lecithin and will continue to uphold this commitment. It also specifically communicates that all of its KINDER products do not contain GMO ingredients.s0 In March 2015, Ferrero Rocher was included on a Greenpeace list of common products that contain GMOs.s1 Before this in 2013, Occupy-Monsanto called for a boycott of all Ferrero products until the company ceased to be members of GMA, who are strong supporters of GMOs and against GMO labeling.s2 Ferrero has announced it is taking part in the SmartLabel™ initiative. General Mills General Mills supports the broad global consensus among food and safety regulatory bodies that approve GM ingredients as safe. In the issues section of its website it outlines how GMO crops have been widely used for more than 20 years without a single incident of harm to health or safety demonstrably linked to the use of GMOs anywhere in the world. General Mills present positive cases for the use of GMOs, including their reduced environmental impact, for instance via reduced greenhouse gas emissions, improved water quality, reduced use of insecticides and harmful herbicides. General Mills also highlights GMO's ability to protect against weeds or disease meaning that farmers can achieve more stable and sometimes higher yields.53 4 8 fatp://mvestor.campbelisoupcompany,co 49 5° http://wvvw.ferrerocsr.com/planet/4gricLb-tural--practise3/3UStainable--raw--materiaIs 5 1 http://www\homeheaIthyfecipes.eom/Ust--of-gm s 2 htt.p://occupy--monsanto.com/t.ag/ferrero-usa/ 53https://w^vw9generalmills.com/en/Nevys/----/link.aspx? id=a2.'34BB7FQQB.q;474o82,qi448,': ;soD2Art?,o& z=z Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

General Mills has added a simple search tool to its website to provide GMO ingredient information for hundreds of its U.S. productsst and to communicate about options of products without GMO ingredients available in some markets. This includes information on non-GMO brands like Annie's, Cascadian Farm, Muir Glen and LARABAR. General Mills has announced it is taking part in the SmartLabel™ initiative. With regards to labeling of GMOs it opposes state-based labeling, but supports nationally standardized labeling of non-GMO products in the U.S. In a blog post in March 2016 it committed to the nation-wide labeling of many products using the wording required by legislation in the state of Vermont. General Mills commits to doing this whilst saying it can't label its products for only one state without significantly driving up costs for its consumers.ss In 2014 following consumer and activist group pressure, General Mills committed to using non-GMO sugar cane in order to make its original Cheerios GMO-free.56 Group Bimbo In a question and answer section on the Bimbo Bread website it states that some of its ingredients may be derived from genetically modified corn, soybean and canola.s? Group Bimbo makes no public commitments around GMOs but in an interview available on its website^8 Group Bimbo's CEO supports the position of the American Bakers Association calling for the introduction of bioengineered wheat. Group Bimbo has announced it is taking part in the SmartLabel™ initiative. Group Bimbo has not communicated its position relating to GMO labeling. However, in 2012 it was reported that the company donated over $320,000 to fight Proposition 37 that would have required GMO labeling in California.59 Group Bimbo was one of the companies fined by Brazil's Consumer Protection Agency after it found that the GMO content of some of its products exceeded the 1% threshold after which a product requires a warning label in Brazil.60 Hershey's Hershey's announced in February 2015 that it will make its Kisses chocolates and Milk Chocolate Bars free of ingredients from GMOs by the end of 2015. This will involve swapping genetically modified sugar beet for cane sugar, as well as a switch to non-genetically modified soy lecithin. These changes come as part of its 'Simple Ingredients' approach. However, the company has not communicated plans relating to which products will be made non-GMO in the future.61 Hershey's has announced it is taking part in the SmartLabel™ initiative. 54http://blog.generalmills.com/20i6/o3/vve-iieed-a-iiational-solution-for-gmo-labeling/, #sthash.SsivB5zp.dpuf 55 http://Flog.generalmiI3s.com/20i6/o.Vw 5 6 htLp://www.usatoday.com/stO"ry/tnoney/bus3ness/20i4/oi/Q2/cheerios-gmos-cereals/42Q.i S7aQ/ 57 http://mvw.bimbobread.com/faqs/defau3t.aspx s 8 http://www.grupobimbo.cora/e:n/press-room 59 https://prof77.wordpress.com/2012/Q8/ns/these-companies-oppose-labeUng-of-gmo-foods/ 60 http://ecowat.ch.com/2Qi6/oi/o8/braziI-fines-nestle-pepsi-gmos/ 6lhttps://iv\vw.thehersheycompany.com/our-ingredients/q-and-a.aspx Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Kellogg's Kellogg's references the findings of the WHO, U.S. Department of Agriculture and the America Medical Association that GMOs are safe whilst also stating that they help to feed the hungry and malnourished in developing nations.62 It recognizes GMOs as an area of consumer interest and highlights its Kashi brand as a leading producer of non-GMO foods in the U.S. In Europe it has a fully traceable procurement system to ensure a non-GMO supply chain and in Australia, New Zealand and Brazil non-GMO grain is used in its cereals and snack bars.63 In March 2016, Kellogg's announced that it would start to label its products in the U.S. that contain GMOs with the words "Produced with Genetic Engineering". The labels will appear nationwide because a special label for Vermont would be costly for Kellogg's and its consumers.64 Kellogg's has announced it is taking part in the SmartLabel™ initiative. Mars On its corporate website Mars states that it firmly believes GMO ingredients are safe based on the extensive studies undertaken by regulatory agencies, scientists and health professionals that have judged them to be so.6 s Mars does not publically communicate which of its products or ingredients are non-GMO. To comply with the state of Vermont's mandatory GMO ingredient labeling law, Mars is introducing clear, on-pack labeling on its products that contain GMO ingredients nationwide across the U.S.66 Green America reported Mars' commitments to removing artificial colors and flavorings were a sign that it is a company which listens to consumers. Green America therefore encourages consumers to call for Mars to deepen its sustainability commitment through offering non-GMO human and pet food products.6 ? Mondelez International Mondelez International considers various factors when deciding whether or not to use GM ingredients in individual countries. In addition to meeting its strict safety and quality criteria, other factors its local businesses take into account include local regulatory requirements for use, consumer acceptance, and availability of alternatives. As there is no global agreement on the labeling of GM-ingredients and government approval on use and labeling differs from country to country, Mondelez International complies with all local applicable regulatory requirements in each country regarding the use and labeling of GM ingredients in food.68 62http:/7iiewsroom.keIloggcornpany.com/^ 6 3http://wvvw.ke]loggcompany.(X)m/content/dam/kelloggcogipanyus/corporate responsihility/pdf/2015/Keiloggs CRR 2014 FINAL.pdf 6 4 http://sitstainablepu3se.com/20i6/oa/22/keloggs-and-mars-announce-gmo-3abeUng-as-big-food-cracte 6 s http://www.mars.com/global/press-center/gmo.aspx 66http://\vww.mars.com/giobai/press-center/gmo.aspx 67 http://acti0n.greenamerica.0rg/p/dia/acti0n/pubiic/Pact.i0n KEY=Q52f; 68 http://vmw.mondelezintemational.ra Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

According to an analysis by the Environmental Working Group (EWG) published on 4 August 2015, U.S. companies and trade associations had spent $51.6 million U.S. dollars on lobbying in the first half of 2015. Some or all of this went to lobbying for legislation preventing state and federal agencies from requiring food companies to label products containing GMO ingredients. A total of 81 companies and trade associations were listed in the report. Mondelez Global spent $190,000 during the period.^ Nestle Nestle considers GMOs that have passed regulatory approval are safe, and have a potential role to play in increasing food production, supporting sustainable agriculture and helping feed a growing world population. It takes the decision to use, or not to use, ingredients that have been derived from GMOs at the local level in response to consumer concerns.7° Nestle has been criticized for taking this approach, for instance when in 2014 it was found that the company removed GMO ingredients from baby foods in South Africa but not in the U.S.?1 Nestle has announced it is taking part in the SmartLabel™ initiative. In early 2016, Brazil's Ministry of Justice fined six global food giants, including Nestle, for failing to disclose that its products contained GMOs.?2 PepsiCo PepsiCo provides a statement on the use of GM ingredients in the U.S. that says: "The use of genetically modified (GM) ingredients is safe for people and our planet, and also has a number of important benefits." It is a statement on the use of GM ingredients broadly; not of PepsiCo's use of them.73 PepsiCo has announced it is taking part in the SmartLabel™ initiative. PepsiCo is launching a range of organic Gatorade for 2016. PepsiCo also announced plans to launch Tropicana juices with non-GMO varieties that will display a certification label from the non-GMO Project. Under current U.S. Department of Agriculture guidelines, organic products are also free of GMOs, so the new Gatorade could also be eligible for the non-GMO Project verification seal.?4 Unilever In line with Unilever's aspiration to make sustainable living commonplace, it believes that science and technology, used in a responsible manner in agriculture, hold the potential to help meet the world's long-term food needs more sustainably. As one of the largest consumer goods companies in the world, Unilever's priority is to provide consumers with products that are safe, meet all regulatory requirements and fulfill its high standards for quality. It believes that GM crops authorized by regulatory bodies are as safe as their traditional counterparts and fully support regulatory control of the use of GM technology and continued scientific review in this area.?5 Unilever has announced it is taking part in the SmartLabel™ initiative. 6 9 http://www.ethi c;4consumer.org/companystories.aspx?Con3panyId=57Q22&Categor>4d=28<) ^http:///www.ii estle.com/ask-nesJe/emironment/ansvvers/gmo-genetically-modified-organisms ^httpi/Znatura] soeiefo.com/nestle-removes-g^ ? 2 btt.p://mvw.ihtTO^ 73 https://www.pepsico.com/docs/album/policies-doc/pwp/gma gmo voiuiit.arydisciosurestatement.pdf 74fattp://mvw.forbes.com/sitGs/greatspecuiati 75 https:/Awvw.unilever.com/sustamab Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

In 2014, Ben and Jerry's support for GMO labeling clashed with parent company Unilever's opposition. While Unilever openly opposed state efforts to legislate GMO labeling, it allowed Ben & Jerry's to assert itself as a vocal proponent of such laws.?6 Supermarkets and Retailers Tesco Tesco's promises that there are no GM ingredients in any of its Tesco branded food.77 There are however those that criticize Tesco, saying that although its products don't contain GM ingredients, its animal products have been raised on GM feed.78 Tesco does not communicate any commitments on GMO labeling. Sainsbury's Sainsbury's does not permit the sale of its own brand food, drink, pet food, dietary supplements or floral products that contain GM material. It states that it is aware that some customers have concerns regarding products from animals that may have been fed a diet containing GM material. As part of its choice offering, it offers a range of its own brand organic products which guarantee the animals are fed on a non-GM diet.79 Sainsbury's' only information on labeling relates to nutritional labeling.80 Wal-Mart There is no publically available information from Walmart on GMO products or ingredients, or on its commitments to GMO labeling. Carrefour In 2010, Carrefour launched a new 'GMO-free' label for more than 350 food items in its stores in France to meet the high expectations that French consumers have with regards to food transparency.81 In 2013, Carrefour in France made a commitment to make it easier for customers to identify eggs from hens fed GMO-free feed.82 Products are segmented to meet customers' essential needs. It has BIO labels for organic food, and offers products with GMO-free labeling.83 ^http://w\wy.bloomberg.com/news/articles/2 77htLps://reaifood.Lesco.cogi/our-food/tesco-value-range/proguse.htmI 7 8 http://wvvw.keypersonofinfluence.cogi/are-you-ea.ting-genetica31y-modified 79 http://wvvw.j-sainsbuw.co.uk/extras/faqs/responsibi3i.ty/ 8ohttp://?wvvQv\j-sainshurv\co.uk/ext:ras/faqs/responsihiIity/ 81 http://www. carrefour.com/stet.ic/cdc/rapport-interactif-2011/en/consommation-4-respecter-environnem 82 http://www.carfefour.eoin/promotmg-re^ 88 http://wiAw.carrefour.com/content/consumer-goods Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Kroger Kroger's organic section has grown in response to its customers' interest in these products. Its natural and organic store brand Simple Truth (including Simple Truth and Simple Truth Organic) now consists of more than 2,600 items. These products have clearly defined product standards in order to clearly communicate to shoppers.84 Simple Truth Organic products are made using methods that the USDA includes in its definition of organic. For customers seeking to avoid GMO's, Kroger states that it can choose from hundreds of Kroger's organic offerings that are identified as non-GMO. The National Organic Program standards do not allow GMO's in the production of organic products.85 HEB HEB states that the easiest way to avoid GMOs is to purchase certified organic products. HEB carries an assortment of more than 2,000 "Certified Organic" items across its stores. These products can be easily identified by the USDA Organic seal which appears on the front of packages and the HEB green seal which appears both on HEB brand products and also on tags located on the shelf. Both of these seals indicate that the product was produced in accordance with the requirements of organic agriculture which prohibits the use of GMOs.86 HEB is a member of the Food Marketing Institute (FMI), one of the largest food industry associations, and it supports their proposed policy positions regarding education, labeling and standards for genetically modified foods. With regards to GM foods and biotechnology, the FMI believes consumers have a basic right to know the relevant information about the products that they buy, including information about GM foods or foods containing GM ingredients. Whole Foods Whole Foods currently offers more than 25,000 certified organic products and about 11,500 Non-GMO Project Verified products in its stores (Organic items must be non-GMO to be certified).87 It states that it is impossible for them to exclude GMOs as an overarching standard at this time, since government regulations don't require the disclosure of GMOs in food. Whole Foods' position on GMOs and labeling is that it believes that consumers have a right to know what's in their food. It strongly supports mandatory labeling of GMO-derived food. It believes that government-mandated labeling of GMO ingredients would enable shoppers, retailers and manufacturers to make purchasing decisions that reflect their beliefs. It is the first national grocery chain committed to providing GMO transparency for customers by 2018. 8 8 8 4 http://sustaSnability.kroger.com/suppIy-cham.htmI 8 s http://sustainabil3ty.kroger.com/sitpply-chaixi.htTnl ^httpsbAvww.heb.com/static-pages/faqPpage^GMO-FAQ 8 ? hUp:/ywww.wholefoodsmarket.com/gmo-your-right-know 88 http://wv\^v. wholefoodsmarket.com/faqs-gmos Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Ahold Ahold has no objections to the responsible use of GMOs where there are clear, demonstrable benefits to consumers. Whether the food products it offers contain GMOs differs from country to country in line with consumer demand.89 Ahold has announced it is taking part in the SmartLabel™ initiative. Food Service & Ma jo r TCCC Customers Bloomin'Brands There is no communication relating to GMOs on Bloomin' Brands' corporate website or in its most recent annual report. Bloomin' Brands' individual restaurant chains also do not communicate on the issue. Burger King There is no communication relating to GMOs on Burger King's corporate website or in its most recent annual report. Whilst McDonald's decided not to use GMO potatoes in the U.S., Burger King has not yet made a public statement as to whether it will use GMO potatoes. This is despite the fact the company is coming under pressure from consumers, including one petition on CREDO Action with over 100,000 signatures calling on Burger King, Wendy's and KFC to not serve GMO potatoes.9° Chipotle Chipotle announced in April 2015 that it was going GMO-free and would cook with only non-GMO ingredients. This announcement was in line with its position that GMOs did not align with its vision, especially because of questions around GMOs health and environmental impacts.91 In September 2015, a class action lawsuit was filed on behalf of a Chipotle consumer against Chipotle claiming that the chain's communication around GMOs was confusing and misleading. According to the complaint, Chipotle's meat, cheese, and sour cream is made from animals fed with GMO soy and corn, and the soft drinks it serves are made with corn syrup made from GMO corn. Chipotle states on its website that most animal feed in the U.S. is genetically modified meaning the meat and dairy it serves is likely to come from animals given at least some GMO feed. It reports the company is working hard on this challenge of completely removing GMOs from its supply chains. Compass Group There is no communication relating to GMOs on Compass Group's corporate website or in its most recent CSR or annual report. Compass Group UK does not communicate on the issue of GMOs either. 8 9 Ahold Corporate Responsibility Policies 9° http://act.credoaction.com/sign/no-gmo-potato 9 1 http://chipotle.com/GMQ Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Dairy Queen There is no communication relating to GMOs on Dairy Queen's corporate website or in its most recent annual report. Darden There is no communication relating to GMOs on Darden's corporate website or in its most recent annual report. Genetically modified foods are identified as a risk in the materiality assessment featured in its 2014 Citizenship Report, however this is their sole mention. No further information is given in the body of the report. Domino's There is no communication relating to GMOs on Domino's' corporate website or in its most recent annual report. Research by GM Freeze in March 2015 found that Domino's was selling pizzas containing GMOs despite making a claim on its UK website that it was GMO free.92 The company's UK website currently states that its Double Decadence and Thin & Crispy pizza bases contain genetically modified soybean oil and maize flour. In January 2016 it communicated that it hoped to be back to fully non-GMO by the end of February 2016.93 Dunkin'Brands There is no communication relating to GMOs on Dunkin' Brands' corporate website or in its most recent annual report. In its 2014 CSR report however, GMOs are identified as an issue in its materiality assessment. GMOs are put in the category of high importance to stakeholders and medium importance to the business94, however there is no further mention on GMOs in the report. McDonald's In the FAQ section of its website, McDonald's communicates that some of its food menu items contain GMOs, in particular those that contain ingredients derived from corn, soy and canola.95 The reasons given behind the use of GMOs are its benefits, including reducing pesticide use, improving nutrition and making it possible to feed more people using fewer resources. It also states that the cattle, chickens and pigs in its supply chain do eat some GMO crops.96 In 2014 McDonald's announced that it would not be sourcing USDA GMO potatoes despite the company behind the creation of the GMO potato variety being its main supplier.97 This follows on from the company stating in 2013 that it did not at the time, nor did it plan to in the near future, source the GMO Arctic Apple variety.98 92 hltjpj//^ww_Midep_endenL^ 93 http://corporaLe.dominos.co.iik/food-faq-s 94 http://wvvw.dunkinbrands.com/internal redSrect/cms.ipressroom.com.sa.amazonaws.com/226/fi]es/20i.^4/FmaI%2oCSR%2oReport.pdf 95 http://www.mc.cioxiakIs.com/us/en/your questions/our food/a:re-ge:net3cally-modifted-o:rganisms-GMO-ingredients-in-yoiir-food.html 9 6 http:/Avww.mccionaicis.CQm/us/en/your questions/our food/cio-you-feeci-your-aT3imais-a-gmo-diet..html 97 http://naturalsociety.com/even--mcdoiialds-Teiects-new-gmQ-pot.ato-fren 9 8 http://libcloud.sa.amazonaws.eom/Qa/78/b/aMOQ/McDonalds response.pdf Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

McDonald's UK & Northern Ireland state that whilst it does not use GMO ingredients in its food (as from 1st April 2014), it ended a restriction on its chicken, pork and beef suppliers which required them to only use non-GMO feed.99 McDonald's France and Germany do not communicate on the issue ofGMOs. Subway The only statement that Subway publically makes about GMOs is that it has verified with its suppliers that the following products are all non-GMO; apple slices, avocado, banana peppers, cucumbers, green peppers, jalapeno peppers, lettuce, mushrooms, pickles, red onions, shredded carrots, spinach and tomatoes, Cheddar, Monterey Cheddar Blend, Parmesan, Pepperjack, Provolone and Swiss cheese.100 It makes no longer term commitments on the issue stating that it will continue to provide its customers with "many choices that fit their lifestyles". 99 ht£p://www.mcdonalds.co.uk/ukhom^ in-your-rest.auran.html 100 http://www.subway.com/subwayroot/about us/Social Responsibility/SustainableSourcmg.aspx#nongmo Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Manufacturer mmm 4SNAPP:„£-' :&'' -Sis ^'&&:&.SSs >££%^<? WSlfWi ?$-;$ }-;$8"JHSV Mfe^^ - IVf A ¥1 <% % * Iti&^MMttft N # Nestle OnShwvr Products or ingredients specified as non-GMO ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^ ^ Prod ucts: Alexia frozen potato products are organic or non￾GMO project certified. ^^§^^^^^g^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^ ^ ^^^^^^^8^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^ ^ 1 n g re d i e n ts: ioo% non-GMO Sugar and Soy Lecithin P rod ucts: All KINDER products are GMO free Prod ucts: Original Cheerios GMO free as well as some branded products e.g. Annie's and Cascadian Farm ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^ ^ Product: Kisses chocolates and Milk Chocolate Bars to be non￾GMO by end of 2015 Prod ucts (Europe): no GMOs in their entire supply chain 111 gre die 11 ts (Australia, New Zealand and Brazil): no GMO grain in cereal and snack bars ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^ ^ 111 gre die 11 ts: decision to use, or not to use, ingredients derived from GMOs at the local level in response to consumer concerns, (e.g., removed GMO ingredients from baby food in S. Africa) Products: Tropicana ^^^^^^^^^^^^^^^^^I^M^^^^^^^^^^^^^^^B Commitments to GMO labeling Voluntary nationwide labeling based on Vermont legislation & part of the SmartLabel™ initiative Voluntary nationwide labeling based on Vermont legislation & part of the SmartLabel™ initiative ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^ Part of the SmartLabel™ initiative Voluntary nationwide labeling based on Vermont legislation & part of the SmartLabel™ initiative Part of the SmartLabel™ initiative Part of the SmartLabel™ initiative Voluntary nationwide labeling based on Vermont legislation & part of the SmartLabel™ initiative Voluntary nationwide labeling based on Vermont legislation ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^ M Part of the SmartLabel™ initiative Part of the SmartLabel™ initiative Part of the SmartLabel™ initiative Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Retailers Gl Ahold <&rr«#bur <§^ %jjLafc^. fill H y :;:;!n *•;..!' ••:;:;; r\ ^ 1 §>« %%| | 1 sfe &»s* Sxss*^ ^SWS %* # Wataart mmmm&HmaiimiBuam Products or ingredients specified as non-GMO Products (France): Since 2010, more than 350 food items have been non-GMO. However, this does not apply globally. P rod u cts: States that the easiest way to avoid GMOs is to buy any of its more than 2,000 certified organic products. Prod ucts: Hundreds of Kroger's Simple Truth Organic products are also non-GMO. In gredie 11 ts: No GMO ingredients in Sainsbury's branded food In gre d ien ts: No GMO ingredients in Tesco branded food Products: Offers about 11,500 non-GMO products and more than 25,000 certified organic products (which are non-GMO) Commitments to GMO labeling Part of the SmartLabel™ initiative (France) Offers products with GMO-free labeling ffl^^^^^i^^^j^^^^^^^^^^^^^^^^^B ^^^^^^^^^^^^^^^^^^^^^^^^m A^^^^^^^^^^^^^^^^^^^^^^^^ Committed to providing GMO transparency for customers by 2018. Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Service Cos. Products or ingredients specified as non-GMO Commitments to GMO labeling f ^ ItggWN' (TCCC) Not specified Not specified (TCCC) Not specified Not specified (PepsiCo) Products & Ingredient: Foods only use non-GMO ingredients Not specified COMPASS (TCCC) Not specified Net specified (TCCC) Not specified Not specified J ^Kbfc ^ (TCCC) Not specified Not specified (TCCC) Not specified Not specified Syxs-v&u (TCCC ) Not specified Not specified (TCCC) Prod ucts (Europe): GMO free but GMOs included in food chains. This does not apply to the USA. Nm specified CeTRWTf> miislsmU (TCCC) Prod ucts: Shares a list of products that are non-GMO on their website Not specified dfWss^%. \xump (PepsiCo) Ingredients (UK, Netherlands & Australia): Only source from suppliers who do not use GMOs in chicken. This does not apply to the USA. Not specified Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Appendix A report of a study commissioned by the African Development Bank (2013)101 Chambers, J. et al (2013) GM Agricultural Technologies for Africa: A State of Affairs, page 60: f a « *§ Limits «m f emmAsiy mrffmst ££»M! pmd&si,y$& lib ssjmd: Mmssm cmmfffes* 10Xttps://books.googleXg/books?id=u7ylB QgpakKrDCqEN6qQaKxLuk&hl=en&sa=X&ved=oCEM06AEwBmoVChMIaNLztqTWvArVC4ksChokOAT #v=onepage&q&f=tru Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Ingredients Campaign and Consumer Insights; Food Industry Competitive Landscape April 2016 Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Regulatory Pressures - Ingredients (Global Highlights) i®& Canada: SPA-b^bv i Lj-'jv/biv Norway : Car?® Iceland: CaH-ein* •SMMiiiim EU&US: Peru: Ifllsg Brazil, Ecuador, Peru, Venezuela; .* Uruguay: • : Azerba ijan: <SIVS Q -h Turkey; Cancans- i" D vak.: Japan: SPA-ivy[ WW GCC: Caffeine -l: L; yd Thailand: Colars￾Australia, New Zealand: S ^w e Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

International Caffeine The International Council of Beverage Associations (ICBA) developed global guidelines for energy drinks: ICBA Guidelines for the Composition, Labeling and Responsible Marketing of Energy Drinks, which states that energy drinks should not be marketed to children (under 12 years old).1 Caramel Two pieces of scientific research released in late 2015 added to evidence that consumption of 4-MEI has negative health effects. The International Agency for Research on Cancer (IARC) has classified 4-MEI as a group 2B possible human carcinogen2 and a study published in Drug and Chemical Toxicology concluded that 4-MEI has a genotoxic and cytotoxic effect in mice.s North America Caffeine In accordance with the Am erican Beverage Association's Guidance for the Responsible Labeling and Marketing of Energy Drinks (2014), all members have agreed not to market energy drinks to children under the age of 12 years. U.S. senators are asking companies to go further and are criticizing those whose marketing targets under 18s, as the safety of energy drinks have been called into question. Following the release of the 2015 U.S. Dietary Guidelines for Americans in January 2016, the American Beverage Association issued a response in which they reiterated that caffeine safety was supported by a long history of consumption and extensive clinical and nonclinical studies undertaken by health authorities and international organizations worldwide. They stated that energy drinks contain about the same amount of caffeine as home-brewed coffee and significantly less caffeine than a similarly-sized coffeehouse coffee. They also supported the Dietary Guidelines' conclusion that the majority of the U.S. population is consuming amounts of caffeine well within safe levels, with 70-90% of all caffeine intake from coffee and tea. Average intakes of caffeine by children and adolescents are low.4 1 http://vvr vvw.icba-net.org/fiIes/resoitrces/energy-d:rink-gin.cielines.pdf 2 http://www.ncbi.nim.nih.gQv/pubmeci/26s80486 s http://www.medicalnewstoday.com/articles/289687.php 4http:/AviAn,v.ameribev.org/news-niedia/newT s-releases-statements/more/s64/ Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

The National Coffee Association (NCA) in the U.S. has placed on its website information on the amount of caffeine that can be found in coffee. Based on advice from the NCA Scientific Advisory Group (SAG) and in consultation with the U.S. FDA, this is the first time that the NCA has officially recognized levels of caffeine in coffee.s Also in the U.S., the manufacturers of Monster energy drink are facing a wrongful death suit in California after a 14-year-old girl with a pre-existing heart condition died after drinking two cans of their product.6 Evidence obtained by the FDA shows 34 deaths linked to energy drinks since 2004, with 11 of these deaths being linked to Monster. Caramel Sensient Food Colors suggests that 67% of consumers are worried about the use of caramel color in food and beverage. Of those concerned, over 40% indicated that they were extremely or very concerned about Caramel Colore In January 2014 a product testing firm, Consumer Reports, published the results of tests it had undertaken on a variety of different soft drinks to identify 4-MEI levels. Consumer Reports stated their results showed a 'concerning' level of 4-MEI in soft drinks and they called for the FDA to impose federal limits below that of California's Proposition 65.8 The 2014 Consum er Reports found 4-MEI levels to be higher than 2Qmg per serving in Malta Goya and Pepsi products. At the time, Pepsi said that they had moved immediately to reach the requirement in California and were planning to have products with lower levels of 4-MEI available nationally by February 2014.9 Sensient Food Color suggests that the brands that are prioritizing caramel replacement appear not to be traditional carbonated soft drinks, but rather beverage types that are positioned as "better" alternatives. Leading examples include10: • Ready-to-drink teas • Smoothie type drinks, especially those with added protein • Ready-to-drink iced coffees • Sparkling beverages • Coffee syrups and creamers • Iced tea mixes • Liquid drink mixes and water enhancers 5 http://www.ncausa.org/llealtb-Caffeine 6 http://www.abcm et.au/radionational/programs/lawreport/^^ 7http://www.se:nsie:ntfoodcoiors.com/cok)rSnsight/sensient-options-fo:r-caraTnel/ 8 http://oehha.ca.gov/public_info/facts/4MEIfacts_021012.html 9 http://www.consumerreports.org/cro/2014/01/regulations-needed-against-risky-caramel-coloring-inToods/ind 10 http://www.sensientfoodcolors.com/colorinsight/sensient-options-for-caramel/ Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Demand for a different caramel color has seen Sethness Products Company launch a new sugar-derived caramel color which is GMO-free and low in sulfites, and no 4-MEI is created during its production.11 Colors In the USA, the FDA has received criticism from organizations such as BioHealthBase.org for continuing to allowthe use of the specific colorings that are no longer used across Europe. The Center for Science in the Public Interest (CSPI) has issued a new report, Seeing Red, in 2016 calling for the FDA to ban FD&C colors, and in the interim, to require a warning label on products containing these colors. The report claims that mounting evidence has led to a growing consensus among researchers, physicians, psychologists, and others who treat patients with such behavioral disorders as attention deficit hyperactivity disorder (ADHD) that avoidance of food dyes benefits some children. The report estimates that more than half a million children in the United States suffer adverse behavioral reactions after eating or drinking food dyes, which leads to upwards of $5 billion per year in health costs. They also claim the FDA's recent exposure assessment is flawed and relies too heavily on parental accounts.12 The call for a ban is supported by research conducted by Bernard Weiss from the University of Rochester Medical Centre that finds that dyes have "some capacity to harm".^ H As with artificial flavoring an increasing number of companies are committing to removing artificial colorings from their products. In June 2015 Ze via announced it would remove colorings from its soft drinks making them clear. Technavio Research released findings in November 2015 suggesting that 58% of U.S. consumers prefer food with coloring from natural sources, a large increase from the 2005 figure of 23%.^ Flavors In the US a petition was filed in June 2015 with the U.S. Food and Drug Administration (FDA) calling for a total ban on eight synthetic flavors currently used in small quantities in products including baked goods, candy and ice cream, as they are known to induce cancer in animals and humans. The eight substances (Benzophenone, Ethyl acrylate, Eugenyl methyl ether, Myrcene, Pulegone, Pyridine, Styrene and Trans, trans-2,4-hexadienal) are classified by the Flavor and Extract Manufacturers Association's (FEMA) as "Generally Recognized As Safe" (GRAS) and already have extremely strict maximum allowable levels. A quick review of the sector did not suggest that NGO campaigning activity was a significant driver behind these commitments. 11 http://www.foodna\dgator-usa.com/Manufart^ 12http:/7cspinet.org/reports/seeing-red-report.pdf ^ http://wvAv.scientificamerican.com/articie/does-artificial-food-coloring-contribute 1 4http:/7www.ncbi.nlm.nih.gov/pubmed/2iQ26oaa 1 5http://wv,nv.technario.com/mews/companies-try-make-food-coloring-more-natural Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

In his book, The Dorito Effect, author Mark Schatzker claims that over exposure to artificial flavors has not only made consumers crave them, but has programmed us to believe that is how food should taste, reducing appreciation for natural flavors in fresh food.16 Preservatives In 2006, Sustain suggested that soft drinks should have a similar legal limit for benzene as drinking water's lppb. This followed a study that found a number of soft drinks with benzene levels above 1 ppb. This was also picked up by campaign group KillerCoke.org. There is no evidence of significant campaign activity around this topic in recent years. Benzene is increasingly receiving attention as a dangerous air pollutant. Early in 2016 there were media stories relating to high concentration of benzene in the air in Houston1 ? and Los Angeles.18 In an article on the growth in popularity of craft sodas in Canada, Matt Philips, the owner of Phillips Soda Works said "I don't know why you would launch any product today with preservatives in it. It's not what consumers want", whilst referring to the presence of sodium henzoate in many beverages. 19 There are a number of articles on sodium henzoate appearing on health websites, with one claiming that it is the new chemical on everybody's mind these days.2021 NaturalNews.com published a strongly worded article suggesting that sodium henzoate deprives human cells of oxygen and breaks down the immune system and causes blood cancer. They claim that Foodinsight.org (International Food Information Council and Foundation) is part of a disinformation campaign as they downplay the health issues associated with the preservative.22 Abouthealth.com supports the findings of the FDA and suggest that it would take approximately 180 times the amount of sodium henzoate present in a typical diet before any problems might occur.2 s They also downplay the level of risk associated with benzene in soft drinks. l6liLtp://w\vw.markschatzker.com/doritoeffect-home-page/ ^ http://wvvw.ho ustonpress.com/new 18 http:/7 www.nbclosangeles.com/h1ews/local/-Cancer-Causing-Benzene-Becon3es-Focus-of-Gas-Leak-Air-San3plm ^http/^sharebaa. tumblr.ro 20 http://thegoodhumaii.com/what-is-sodium-benzoate/ 21 http://dheorganicdiabetlc.org/20iis/ii/dangers--of-sodium-benzoate/ 22 http://www.naturaInews.com/QS2Q47 sodium benzoate perishable foods chemical preservatives.html# 2 3 http://nutrition.about.eom/od/changeyourdiet/a/sodiumbenzoate.htm Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Europe Caffeine Energy Drinks Europe has developed a Code of Practice for the Marketing and Labeling of Energy Drinks, which contains several voluntary commitments that includes no marketing to children. 24 Activism has been evident in the UK and Germ any throughout 2015. In the UK, campaign group Action on Sugar has argued that energy drinks should be banned for those under 16.2 s Similarly, in Scotland campaigners called on the Scottish Government to ban the sale of energy drinks to children after a new study found just one of the beverages could put a nine-year-old boy over the safe daily limit for caffeine. 26The German consumer group Fo o d w actch has previously criticized Germany's Minister of Food and Agriculture for claiming that there is currently no reason to restrict energy drinks. Foodwatch contests that the sale of energy drinks to those under 18 should be banned.2 ? There are also reports of some local shops banning the sale of energy drinks to children based on pressure from local parents. Some companies like Nestle have also sought to demonstrate the positive effects that consuming smaller amounts of caffeine from beverages (e.g., coffee) can have an effect on mood and concentration. The Red Bull website gives the option to compare the caffeine content of a can of Red Bull with other caffeinated products to demonstrate its comparatively reasonable levels.28 PepsiCo also has a visual on their website comparing the amount of caffeine in a i6oz bottle to a i6oz can of energy drink and i6oz cup of coffee.2 9 5ie YOU amw Caffelno Comparison M w *^a Source: http://energydriiik-uk.redbull.com/red-bull-caffeiiie-conteiit" Source: littp://V.AVvv.pepsic(>l>everagelacts.coiu/H()riie/caffeme 2 4 http://www.eriergydririkseurope.org/regiilation/ 2 s http://www.bbc. co.uk/news/health-at62a77t 26 http://ww\v.edinburghriews.scotsrna:n. com/news /healtb/call-for-ban-o:n-sale-of-energ\, -drinks-to-kids-i-a788o4.; i#ixzz4iBz4czre 2 7ht.tp://www.eurofoodl^^^ 28http://energ>f drink-uk.redbul[.com/red-buil-caffeiT3e-conterit 2 9http:///tvww.pepsicobeveragefarts.com/Home/caffeine Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Asia Pacific Caramel In the UK and South Africa there is evidence of a small amount of consumer pressure being directed towards companies to encourage them to produce products to the same standard as California (below 29mg of 4-MEI per day). Colors In the EU food manufacturers are increasingly using food colors that are considered ingredients rather than additives. This is seen as beneficial as these ingredients replaced the negatively perceived E numbers on the ingredient statement. Caffeine In June 2015, TCCC transferred ownership of its worldwide energy drinks to Monster—NOS, Full Throttle, Burn, Mother, BV, Gladiator, Samurai, Nam, BPM, Play, and Power Play. TCCC has become Mo nste r 's preferred global distributing partner. This lawsuit prompted a number of national governments to reconsider their position on energy drinks, for example in Au s tralia the case reignited calls for the sale of energy drinks to children to be banned.s0 The Australian Medical Association has consistently been one of the strongest campaigners on this issue. Africa Caramel In South Africa there is evidence of a small amount of consumer pressure being directed towards companies to encourage them to produce products to the same standard as California (below 29mg of 4-MEI per day). In response to this, Coca-Cola SA communicated that they would roll out their reduced 4-MEI recipe in South Africa by September 2015. 3 0 littp://www.abc.net,au/radionatio^ Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Global Industry Competitive Landscape Food &Beverage Companies Campbell Soup Campbell Soup Companys1 will make all of its North America products without artificial colors or flavors by the end of fiscal 2018. Based on feedback from parents, the company will simplify the recipes of existing condensed soups for kids, removing ingredients such as added MSG and continuing to make the soup with no preservatives, no artificial colors and no artificial flavors. Additionally, they have also launched a new platform where consumers can go to find out what the ingredients are in Campbell's products.32 ConAgra Foods ConAgra is moving is moving to all natural protein and no artificial ingredients in its Healthy Choice and Simply Steamers brands, as well as launching a new natural Orville Redenbacher popcorn line with no artificial flavors, colors, or preservatives.33,34 Dr. Pepper Snapple There is no publically available information from Dr. Pepper Snapple on the ingredients covered in this briefing document. Ferrero There is no publically available information from Ferrero on the ingredients covered in this briefing document. General Mills In January 2016, General Mills filed a law suitss against Chobani LLC after they suggested that their Yoplait Yogurt Brand contained pesticides. They did this by initially saying that the product used the preservative potassium sorbate, then implying that this ingredient is actually a pesticide, saying: "That stuff is used to kill bugs."36 >37 General Millss8 re-launched seven of their breakfast cereals with new recipes making 75% of their cereal portfolio free of artificial flavors and colors. The company plans to have 90% of its cereals free from artificial colors and flavors by 2016. 3 1 http://www.campbellsoupcompany.com/pressrelease/campbell-continues-to-shift-portfolio-toward-faste s 2 http://www.whatsinmyfood.com/ 33 http://www.foodnavigator-usa.com/Manufacturers/ConAgra-Food-s-outlines-3-point-plan-to-grow-consumer-business 34 http://www.conagrafoods.com/news-room/news-Orville-Redenbachers-New-Natural-Line-Pops-with-Savory-Gourmet-Flavors-1040168 35https://consume:rmed3allc.fi]es.wordpress.com720i6/oi/2Qr>i36340-general-mi]ls-v-chobani-complaint-i6-cv-ooori2.pdf 3 6 http://v>n^^v\chicagotribune.com/business/ct-chobani-controversial-advert-20i6oii3-stow.html 37hUp://consumerist.cnm/20i6/oi/i2/general-mills-sues-chobani-for-advertising-that-yoplait-contains-bug-spray/ 3 8 http://blog.generalmills.com/2015/06/a-big-commitment-for-big-g-cereal/ Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Grupo Bimbo There is no publically available information from Grupo Bimbo on the ingredients covered in this briefing document. Heineken In February 2015, Heineken announced that it would change the recipe for Newcastle Brown Ale, replacing its caramel food coloring, which contains 4- MEI, with roasted malts. Hershey's In Feb 2015, Hershey^ made the commitment to transition to 'simple and easy-to-understand ingredients'. In Nov 2015, Hershey's released the "Holiday Hershey's Kisses Milk Chocolates and Hershey's Milk Chocolate Bars made with simple ingredients and no artificial flavor".4o These are some of the first products from Hershey's to transition to 'simpler ingredients'. Kellogg's Kellogg's plans to remove all artificial colors and flavors in its cereal and snack brands by the end of 2018.41 Kraft Heinz Kraft removed artificial colors, flavors, and preservatives from Kraft Macaroni & Cheese and began selling it in December 2015 without a formal announcement, only having changed the ingredient line on packaging. In March 2016 they announced the changed2 In the UK, Kraft removed sodium benzoate from their product lines as a result of consumer pressure and government recommendations. Mars In February 2016, Mars announced it will be removing all artificial colors from its human food portfolio. They expect the artificial color removal to be complete in about five years.43 In their press release, Mars stated that artificial colors pose no known risks to human health or safety, but there commitments are driven by consumers calling on food manufacturers to use more natural ingredients in their products.44 Mars had been targeted by a petition by Center for Science in the Public Interest in February 2015 with the aim of encouraging them to follow Nestle's example and remove artificial colors and flavors from their products.45 In the UK, Mars removed sodium benzoate from their product lines as a result of consumer pressure and government recommendations. 39https://www.thehersheycompany.com/newsroom/news-release.aspx?id=20i7846 https://www.thehersheycompany.com/newsroom/news-release.aspx?id=2iii905 4 1 http://www.nbcnews.com/business/business-news/kelloggs-eliminate-artificial-ingred^ 4 2 http://www.kraftmacandcheese.com/ 43 http://www.mars.com/global/press-center/press-list/news-releases.aspx?SiteId=94&Id=6984 44http://\v\vw.mars.com/globai/press--center/press-Iist/news--reieases.aspx?SiteId=: 94&Id==6Q84 45https://'www.cspinet.org/new/20i.c 502iqi.htmI Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Mondelez International Mondelez International removing all artificial colors and flavors in key brands.46 Mondelez has also set themselves the target of removing all artificial flavors and colors from their packaged food brands by 2020.47 Nestle Nestle USA committed to removing all artificial colors and FDA-certified colors from all of its chocolate candy products by the end of 2015.48 These products will be identified by a "No Artificial Flavors or Colors" claim on the pack.49 PepsiCo There is no publically available information from PepsiCo on the ingredients covered in this briefing document. Unilever Unilever is taking out artificial colors and flavors from many products like Knorr, "to deliver better, more natural products.s0 Supermarkets and Retailers Ahold Ahold and its banners Giant Food and Stop & Shop announced the introduction of Nature's Promise "Free from" products. Nature's Promise "Free from" ingredients are clearly indicated on the product packaging and all Nature's Promise "Free from" products are free from artificial ingredients, including artificial colors, flavors and preservatives. Nature's Promise "Free from" household products are free from harsh chemicals, including ingredients like added artificial dyes and fragrances. The more than 800 fresh, grocery, health and beauty and household Nature's Promise products can be found only at Ahold banners.s1 Carrefour There is no publically available information from Carrefour on the ingredients covered in this briefing document. 4 6 http://www.mondelezinternational.eom/~/media/MondelezCorporate/Uploads /downloads /mondelez_mtl_fact_sheet.pdf 47http://www.foodbusinessnews.net/articles/news home/Business News/2015/10/Mondelez to remove artificial.asgx?ID=%2B0254Q3CC-J3.AB7-440a-9342- OQ4DiACE6FE8%7D&cck=l 4 8 http://www.nestleusa.com/media/pressrete end-of-20 49 http://www.nestleusa.com/media/pressreleas end-of-20 5° https://www.unilever.com/sustainable-liwng/the-sustainable-liwng-plan/improwng-health-and-well-being/improving-nutrition/delivering-better-products/index.html s 1 http://mypbrand.com/2016/02/28/ahold-evolves-natures-promise-free-private-brand/ Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Delhaize Group In the U.S., Delhaize Group's supermarkets are Hannaford and Food Lion. Global chains include those in the Belgium, Luxembourg Greece, Serbia, and Indonesia. There is no publically available information from the Delhaize Group on the ingredients covered in this briefing document. HEB HEB's Select Ingredients program allows consumers easily identify products that are free of artificial flavors, high fructose corn syrup, and other synthetic ingredients by choosing products with the Select Ingredients logo. The Select Ingredients program also has a list of all ingredients that are included, and not included in these products.s2 Kroger Kroger's organic section has grown in response to its customers' interest in these products. Its natural and organic store brand Simple Truth (including Simple Truth and Simple Truth Organic) now consists of more than 2,600 items. These products have clearly defined product standards in order to clearly communicate to shoppers.53 All of the products within the natural section must adhere to Kroger's strict natural food ingredient standards which mean they must refrain from using 101 artificial preservatives and ingredients deemed "undesirable" by consumers.54 Morrisons Morrisons conducted a trial of not selling energy drinks to children less than 16 years of age across six of their stores. Despite receiving positive publicity and praise from local schools there has been no commitment that a similar policy will be rolled out at scale. Sainsbury's There is no publically available information from Sainsbury's on the ingredients covered in this briefing document. Tesco There is no publically available information from Tesco on the ingredients covered in this briefing document. Wahnart In the UK, Wahnart (ASDA) removed sodium benzoate from their product lines as a result of consumer pressure and government recommendations. Whole Foods Whole Foods does not sell any products with artificial colors, flavors, sweeteners, preservatives, or hydrogenated fats in their stores. They also have a list of unacceptable ingredients on their website.ss s 2 https://www.heb.com/static-page/select-ingredients-landing 53 http://sustainability.kroger.com/supply-chain.htmi 54 http://www.simpletruth.com/about-simple-truth/101-free/ 55 http://www.wholefoodsmarket.com/about-our-products/quality-standards/food-ingredient Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Service & Ma jo r TCCC Customers Bloomin'Brands There is no publically available information from Bloomin' Brands on ingredients covered in this briefing document. Burger King There is no publically available information from Burger King on ingredients covered in this briefing document. Caribou Coffee Caribou Coffee announced it will eliminate artificial flavorings in all of their menu items by the end of 2016. They plans to convert all of its flavor syrups to a 'clean label standard', starting with vanilla syrup and moving to caramel syrup. They are promoting 'simple ingredients'.s6 Chipotle Chipotle57 has removed artificial flavoring from their products. Compass Group There is no publically available information from Compass Group on ingredients covered in this briefing document. Dairy Queen There is no publically available information from Dairy Queen on ingredients covered in this briefing document. Darden There is no publically available information from Darden on ingredients covered in this briefing document. Domino's Domino's Australia says it will remove all artificial colors, flavors, and preservatives from its pizza by 2017.58 Dunkin' Brands There is no publically available information from Dunkin' Brands on ingredients covered in this briefing document. McDonald's There is no publically available information from McDonald's on ingredients covered in this briefing document. 5 6 http://wWW.f00dbUSineSSneWS.net/articles/neWS_h0me/F00d-Service-Retail/20l6/0l/Carib0U_C0ffee_makeS_Clean 5ACQ222C4089%7D 57 https://wivw.chipotle.com/food-with-integritv 5 8 http://aUSfoOdneWS.COm.au/2Ol5/06/29/dominOS-tO-remOVe-all-artificial-COlOUrS-flaVOUrS-and-preSerVativeS-frOm-pizZa-menU.html Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Panera Bread Panera Bread pledged to remove all artificial preservatives, colors, sweeteners, and flavors from their food in all U.S. bakery-cafes by the end of 2016.59 They have also created an ingredient "No-No List" for ingredients not allowed in their food.60 Papa John's In January 2016 Papa John's61 became the first national pizza chain to announce it has removed artificial colors and flavors from its entire menu. Subway Subway will remove all artificial flavors, colors, and preservatives from its menu items in North America by 2017.62 Yum! Brands Yum! Brands have made a commitment to remove artificial flavoring from their products in the near future, including Taco Bell and Pizza Hut. Pizza Hut removed all artificial colors and preservatives.6 s 59 https://www.panerabread.com/en-us/company/food-policy.html 60 https://www.panerabread.com/panerabread/documents/panera-no-no-list-05-2015.pdf 6lhttp://myw.businesswire.com/hiewT s/home/20i6 62 http: //www. subway, com/menu/ alwaysimproving/default. aspx 6 3http://'www.eater.com/20i5/5/26/8659683/taco-bell-pizza-hut-cut-artificia]-ingredients-menus Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Manufacturer IdfelMl&sl 5 ''v;.i.^, '"i'^ <0' ", ,.\."-:. q$ >.x. x; ,'-\ > •** • \.*Y. •$!,' ^^^V^^^x^sA^^y * %»*> ' • X m S&Bf x^x^^CxSSxf'x* • • <x<$ ^ f ft?4xf V Cxixxftx.** f? 4$ Kraf&/i&#i& r\/tf A ¥? Q Statement on Ingredients Hordi America products without artificial colors or flavors by soiB Hcaltliy Choice * simply Steamers Brands: Noartifidalhigrediontaand all natural protein. Orvllle Redenbacher popcorn: No artificial flavors, colors, preservatives. Not specified Not specified Seven breakfast cereals with no artificial colors or flavors. 90% of its cereals free or artificial colors and flavors by end of 2016, Noi specified Kefaeken replacing caramel food coloring Newcastle Brown Ale with roasted malts. Holiday Hwskey s Kisses Milk Chocolates and Hershey 's Milk Chocolate Bars made with simple ingredients and no artificial flavor. Removing artificial colors and flavors in its cereal and snack brands by the end of 2018. Removed artificial colors* flavors,, and preservatives from Kraft Macaroni & Cheese Removing artificial colors from human food portfolio. Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Manufacturer ^" i«*mts&*<*m(i ^ Nestle iJmXMfmr Statement on Ingredients Removing all artificial colors and flavors in packaged food brands by 2020.. Nestle USA removed all artificial colors and FDA-certified colors from chocolate candy prodncts. Not specified Removing artificial colors and flavors from many products. Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Retailers Statement on Ingredients Nature's Promise "Free from" program includes products that are free from all artificial ingredients including ardfteial odors, flavors,, and preservatives. Not specified Not specified &.m..TcmL..r... Select Ingredients program products are free from, artificial flavors, HFCS, and other synthetic ingredients. Simple Truth program products do not use 101 artificial preservatives and ingredients Not specified &*W*SW**J& Not specified Walmart (ADSA) in the UK removed sodium benzoate. ss. WHOLE FOODS Ho products with artificial colors, flavors, sweeteners, preservatives, or iwdrogenated fats sold. Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Service Cos. HP^ftNDV (TCCC) •—** (TCCC) °^iJ>M (TCCC) (PepsiCo) COMPASS (TCCC) V ^ : (TCCC) i DARDEN (TCc q (TCCC) 4»«««^ (TCCC) (TCCC) Statemen t on Ingredients Not specified Not specified ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^P ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^ ^ Not specified Not specified Not specified ^^^^^^^^K^^^^^M^^^^^^^^^^^^^^^^^^pW^^^^^^^^^^^^^^^^^^ Not specified Not specified Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Service Cos. <§3? <?."**A> (PepsiCo) (PepsiCo) o 'to ft Statement on Ingredients Removing all artificial preservatives, colors, sweeteners, and flavors by end of &ai6. Removed ar&ficial colors and flavors. Removing artnMal colors, flavors, and preservatives in NA by 2017. Removing aitifleial flavoring. Pirn Hot to remove artificial eoiors and preservatives, Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Caffeine Regional and Competitive Landscape Brief April 2016 Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

The Coca-Cola Company Messaging All Company messaging has been developed according to Coca-Cola's Guiding Principles for Messaging Every day, millions of people enjoy beverages with caffeine, including coffee, tea and soft drinks. Because caffeine has been consumed for centuries, we know a lot about it - it's widely studied and is known to be safe when consumed in moderation. People are often surprised when they learn that a can of Coca-Cola contains much less caffeine than the same amount of coffee. But we know that not everyone drinks caffeine and not everyone wants to drink it all the time, so we also offer a range of caffeine-free beverages so people can make the choice for themselves and their families. Political and Regulatory Action and Trends Research conducted by the World Health Organization (WHO) has warned that increased consumption of energy drinks poses a danger to public health, especially among young people.1 It is stated that over consumption of caffeine present in these drinks can cause cardiac arrests, headaches and migraines, addiction and behavioral problems in children. However, Codex Alimentarius does not currently set a standard for caffeine in foods or beverages. The International Council of Beverage Associations (ICBA) has developed global guidelines for energy drinks: ICBA Guidelines for the Composition, Labeling and Responsible Marketing of Energy Drinks, which states that energy drinks should not be marketed to children (under 12 years old).2 Energy Drinks Europe has developed a Code of Practice for the Marketing and Labeling of Energy Drinks, which contains several voluntary commitments that includes no marketing to children.s In the U.S., the Food and Drug Administration's (FDA) Code of Federal Regulations (CFR), 21 CFR 182.1180 specifies that a tolerance of 0.02 percent is Generally Recognized As Safe (GRAS) when used in cola-type beverages in accordance with good manufacturing processes.4 The GRAS process is embedded in the Federal Food, Drug and Cosmetic Act (FD&C Act).s The Food Labeling Modernization Act requires the disclosure of caffeine content above lomg caffeine per serving. An updated version of the Act was introduced in 2015 but all content relating to caffeine remained the same.6 237 new laws came into effect on the 1st of January 2016 in Illinois. These included a law that prohibits the sale of powdered caffeine to anyone under the age of 18 years old.? 1 http://www.euro.who.intAn/lrealt^ 2 hltp://vvw\v.icba-net.org/files/resources/energy-drink-guidelines.pdf 3 http://www.energydrinkseurope.org/regu3at3on/ 4 http://www.accessdata.fda.gov/scripts/cdrh/ cfdocs/cfcfr/CFRSearch.cfm?fr= 182.1180 5 http://www.fda.gov/regulatoryinformation/legislation/federalfooddrugandcosmeticactfdcact/ 6 https://w^vw.congress.gov/bill/ii4th-congress/senate-bill/2aoi/text 7http:/7patch.com/iUinois/joliet/new-illinois-laws-20i6-c.rime-courts-corrections-law-enforcement-o Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

In the EU, a Labeling Directive and the recently implemented Food Information to Consumers Regulation, requires food supplements, and food and drinks with added caffeine content over lsomg per liter to carry a front of pack warning: "High caffeine content. Not recommended for children or pregnant or breast feeding women" followed by the indication of the amount of caffeine per 100ml in brackets.8 This legislation constitutes harmonized European law and is directly applicable in all EU member states. In the EU the scope for beneficial claims on energy drinks has previously been restricted. Since December 2012, only so-called "bodily function" claims, scientifically substantiated and approved by the European Commission and either appear on an EU positive list or have been individually authorized, may be used on energy drinks. In November 2015 however, a working group discussed a draft regulation ((EU) No 432/2012) proposing to authorize a number of health claims on caffeine, as well as altering a safety warning to become less prescriptive. The proposed safety warning in the regulation would read "Information shall also be given to the consumer that it is recommended not to exceed a daily intake of 400mg of caffeine". 9 The health claims for which authorization is being considered include: o Caffeine contributes to an increase in endurance performance, targeting adults performing endurance exercise o Caffeine contributes to an increase in endurance capacity, targeting adults performing endurance exercise o Caffeine helps to increase alertness, targeting the adult population o Caffeine helps to improve concentration, targeting the adult population An additional safety warning that recommends that one should not exceed an intake of 20omg caffeine in a single dose was advocated by EU Member States. It is proposed that the claims targeting the adult population should have additional wording in the conditions of use so that it 'shall not be used for claims targeting children'. An updated version of the European Commission's proposed list of permitted health claims for caffeine will be included as an Annex to the Commission Regulation amending Regulation 432/2012. The draft claims and warnings have still yet to be signed off, with groups like the World Trade Organization yet to be consulted. A source from the European Coffee Federation believes that the claims may not become law until late in 2016.10 The European Food Safety Authority (EFSA) released a scientific opinion on health claims in relation to caffeine and increased fat oxidation leading to a reduction in body fat mass, increased energy expenditure leading to a reduction in body weight, increased alertness, and increased attention. These claims have proposed wording to be used per topic as well as conditions of use that include a minimum amount required in order to use the claim.11 Following a request from the European Commission, the EFSA Panel on Dietetic Products, Nutrition and Allergies was asked to deliver a scientific opinion on the safety of caffeine.12 They were also asked to analyze possible interactions between caffeine and other constituents of "energy drinks" (alcohol, p￾synephrine and physical exercise). It found that: Single doses of caffeine up to 200 mg (about 3 mg/kg bw for a 70-kg adult) do not give rise to safety concerns. Single doses of caffeine up to 200 mg do not give rise to safety concerns when consumed < 2 hours prior to intense physical exercise under normal environmental conditions. 8 http:/'/y^w.energydrinkseurope.org/regu3ation/ 9ht.tps://vvww.gov.uk/'governmeTa7k3ploads/system/'up]oads/at.tachment data/fiIe/4772Qi/Commission Working Group on health claims Q Nov 15.pdf 10fattp://mvw.nutraingrediente^ n http://www.efsa.europa.eu/sites/def^ 12http:/Av\vw.efsa.europa.eu/en/efsajounial/pub/4i02 Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Other constituents of "energy drinks" at typical concentrations in such beverages (about 300-320, 4 000 and 2 400 mg/L of caffeine, taurine and d￾glucurono-y-lactone, respectively), as well as alcohol at doses up to about 0.65 g/kg bw, would not affect the safety of single doses of caffeine up to 200 mg. Habitual caffeine consumption up to 400 mg per day does not give rise to safety concerns for non-pregnant adults. Habitual caffeine consumption up to 200 mg per day by pregnant/lactating women does not give rise to safety concerns for the fetus/infants. For children and adolescents, the information available is insufficient to derive a safe caffeine intake. In Uzbekistan, the Ministry of Health has adopted an amendment to the current Sanitary Rules (SanPiN 0283-10), in which the maximum permissible caffeine level is decreased from 150 mg/kg to 100 mg/kg for beverages with caffeine and from 400 mg/kg to 300 mg/kg for energy drink categories.^ A number of countries, such as Uruguay, No r way, Iceland and Turkey have gone a step further and have banned the sale of certain types of energy drinks. The sale of energy drinks has been banned to those 18 years and under in Lithuania and those 15 years and under in Sweden. In Germany, the Social Democratic Party (SPD) is urging the Parliament to outlaw the sale of energy drinks to those less than 18 years of age. The U.S. Congress is currently researching sales of energy drinks to those under 18 years and whether they should be restricted. The FDA will be publishing a rule on the Generally Recognized as Safe (GRAS) process in 2016, which could affect caffeine and other GRAS ingredients. In Kazakhstan, a Ministry of Health Resolution allows caffeine obtained only from vegetable sources to be used in energy drinks (the same applies in Malaysia). The risk is that such an approach could spread to other caffeine containing beverages and to other members of the Eurasian Economic Union (Russia, Belarus, Armenia and Kyrgyzstan) due to common trade and regulatory environment. Such an approach could also potentially be adopted in South Korea and Japan. In Australia and New Zealand, according to the Food Code, formulated caffeinated beverages must contain no less than 145 mg/L and no more than 320 mg/L of caffeine. Product labels must include advisory statements to the effect that: a) The food contains caffeine; b) The food is not recommended for children, pregnant or lactating women and individuals sensitive to caffeine; and, c) No more than a certain amount should be consumed per day. Health Canada's scientific assessment supports the establishment of a recommended intake level for total caffeine of 400 mg per day with a maximum amount of caffeine not to exceed 180 mg per container.^ In France, taxation on drinks with the level of caffeine above 22omg/L has been in place since 2014. In 2011, Hungary introduced a tax levied specifically at energy drinks.^ TheUAE, Saudi Arabia, Qatar, Bahrain and Oman have moved to restrict all marketing campaigns and advertising in the energy drink category. Warning labels have also been implemented. « TCCC SRATop 10 issues- Updates Jan 2016 1 4http://^Tyw.hc-sc.gc.ea/fn-an/legislation/poi/energy-drinks-boissons-energisantes-eng.php ^httpyVfoodresearch.org.uk/wp-coM Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Campaign, Consumer and Competitor Insights In accordance with the American Beverage Association's Guidance for the Responsible Labeling and Marketing of Energy Drinks (2014), all members have agreed not to market energy drinks to children under the age of 12 years. U.S. senators are asking companies to go further and are criticizing those whose marketing targets under 18s, as the safety of energy drinks have been called into question. Following the release of the 2015 U.S. Dietary Guidelines for Americans in January 2016, the American Beverage Association issued a response in which they reiterated that caffeine safety was supported by a long history of consumption and extensive clinical and nonclinical studies undertaken by health authorities and international organizations worldwide. They stated that energy drinks contain about the same amount of caffeine as home-brewed coffee and significantly less caffeine than a similarly-sized coffeehouse coffee. They also supported the Dietary Guidelines' conclusion that the majority of the U.S. population is consuming amounts of caffeine well within safe levels, with 70-90% of all caffeine intake from coffee and tea. Average intakes of caffeine by children and adolescents are low.16 The National Coffee Association (NCA) in the U.S. has placed on its website information on the amount of caffeine that can be found in coffee. Based on advice from the NCA Scientific Advisory Group (SAG) and in consultation with the U.S. FDA, this is the first time that the NCA has officially recognized levels of caffeine in coffee.1 ? Also in the U.S., the manufacturers of Monster energy drink are facing a wrongful death suit in California after a 14-year-old girl with a pre-existing heart condition died after drinking two cans of their product.18 This lawsuit prompted a number of national governments to reconsider their position on energy drinks, for example in Australia the case reignited calls for the sale of energy drinks to children to be banned.^ The Australian Medical Association has consistently been one of the strongest campaigners on this issue. Similar activism was evident in the UK and Germ any throughout 2015. In the UK, campaign group Action on Sugar has argued that energy drinks should be banned for those under 16.20 Similarly, in Scotland campaigners called on the Scottish Government to ban the sale of energy drinks to children after a new study found just one of the beverages could put a nine-year-old boy over the safe daily limit for caffeine.21 The German consumer group Food watch has previously criticized Germany's Minister of Food and Agriculture for claiming that there is currently no reason to restrict energy drinks. Foodwatch contests that the sale of energy drinks to those under 18 should be banned.22 The double standards of criticizing energy drinks for their caffeine content whilst, ounce per ounce, coffee contains more caffeine, has been called to question. This debate is ongoing and also touches on factors such as energy drinks sugar content and the presence of preservatives and colorings. Some companies like Nestle have also sought to demonstrate the positive effects that consuming smaller amounts of caffeine from beverages (e.g., coffee) can have an effect on mood and concentration. The Red Bull website gives the option to compare the caffeine content of a can of Red Bull with other caffeinated products to 16 http://www.ameribev.org/news-media/news-releases-staten3ents/tnore/a64/ ^ http://vvwvv.ricausa.0rg/H ealth-(^affelne 18 http://mvw.abc.net.au/radionationa3/prograra 1 9http://www.ahc.net.au/:radionatio^ 20http://\vw^v.bbc.co.uk/news/bealth-ai62a77i 21 http://www.edinburghnews. Scotsman. com/news/heaith/cali-for-ban-Qn-sale-of-energy-drinks-t.o-kids-i-a788o4.c i#ixzz4iBz4czre 22 http://www.eurofoodiaw.co^ Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

demonstrate its comparatively reasonable levels.2 3 PepsiCo also has a visual on their website comparing the amount of caffeine in a i6oz bottle to a i6oz can of energy drink and i6oz cup of coffee.2 4 DID im sum? ?•=>«?;? ,j f, >y; pi mg •10 .*?*&' Source: http://energydrink-uk.redbull.com/red-bull-caffeine-content Source: http://www.pepsicobeveragefacts.com/Home/caffeine 2 3 htt.p://energ>xlrink-uk.redbu[].com/red-bull-caffeine-confent 2 4http:/7tvwvj .pepsicobeveragefacts.com/Home/caffeine Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Global Industry Competitive Landscape Food &Beverage Companies Monster Monster is facing a wrongful death suit in California after a 14-year-old girl with a pre-existing heart condition died after drinking two cans of their product.^ Evidence obtained by the FDA shows 34 deaths linked to energy drinks since 2004, with 11 of these deaths being linked to Monster. In June 2015, TCCC transferred ownership of its worldwide energy drinks to Monster—NOS, Full Throttle, Burn, Mother, BV, Gladiator, Samurai, Nalu, BPM, Play, and Power Play. Supermarkets and Retailers Morrisons In 2013 and 2014, UK supermarket Mo rrisons trialed not selling energy drinks to children less than 16 years of age across six of their stores. Despite receiving positive publicity and praise from local schools there has been no commitment that a similar policy will be rolled out at scale. There are also reports of some local shops banning the sale of energy drinks to children based on pressure from local parents. Food Service & Major TCCC Customers Food service companies and TCCC customers offer a variety of beverages with caffeine, caffeine-free, and without caffeine. There is no publically available information from this group about prohibitions on caffeine in beverages. 2 s http://\vww.abc.net.au/radionationaV^ Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Manufacturer Statement on Caffeine Nat specified Nat specified Not specified AN AYANAV«.AN¥NA-JAAN^\\SY Not specified Not specified Not specified Not specified •*>< ? ^""Jf-W Y :VYN\<.:N > N Y Not specified Not specified MM^Memzj Not specified .A. V sAN-A... Not specified }®tmm$\mmi ^ Not specified W^^^^^^^mlS^^^^^^^SB^^^k^^mS^m^^^^^^^m Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Manufacturer Nestle PEPSICO UwJUvWT Statement on Caffeine Not specified NM specified NM specified Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Retailers Statement on Caffeine Not specified tm Not specified Not specified Not specified j&Sfk ^Hgj^ Not specified i^SH^^HI^^^^^^HHHHi^^^Hi^^^^^^^^^^^^^^fli^H^^H^^^^HK iiiiiiiiiiliillillil Not specified Ik ^% § 1 § Kkss W<# ^kw* ^s« # Not specified Not specified VttiOLE FOODS Not specified Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Service Cos. |^a¥?AND$i (TCCC) S g (TCCC) C^,^ (TCCC) H lllililllylllll (PepsiCo) " COMPASS (TCCC) (TCCC) i OAROtN (TCCC) (TCCC) ^f»'KM. (TCCC) (TCCC) Statemen t on Caffeine Not specified Not specified Not specified Not specified Not specified Not specified Not specified Not specified Not specified Not specified Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Service Cos. TAM^ A ^15** > (PepsiCo) (PepsiCo) eXunAiAh (TCCC) > (PepsiCo) Statement on Caffeine Nvl specified Nat specified Nm specified Not specified Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Caramel/4-MEI Regional and Competitive Landscape Brief April 2016 Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Political and Regulatory Action and Trends 4-methylimidazole (4-MEI) is a chemical compound that is not directly added to food but forms as a trace impurity during the manufacturing of certain types of caramel coloring that are used to color cola-type beverages and other foods. According to the World Health Organization's (WHO) International Agency for Research on Cancer, 4-MEI is a carcinogen. However, available evidence does not show that 4-MEI poses an immediate or short term danger at the levels found in normal diets. One study states that a person would have to consume over 300 12 oz. cans of soda each day to reach the doses found to cause cancer. The European Food Safety Authority (EFSA) reviewed the safety of a group of caramel colors allowed for use in food in the EU in 2011.x They revised the previously Acceptable Daily Intakes (ADIs) and set a group ADI covering all caramel colors. 4-MEI was also reviewed in 2011 and they concluded at the highest levels that could result from consumption of foods containing 4-MEI, that it is neither genotoxic nor carcinogenic. They also found there was no evidence that it has adverse effects on human reproduction or developing children. It was deemed prudent to keep consumer exposure as low as possible and the Acceptable Daily Intake (ADI) was set at 300 mg per kg body weight per day (mg/kg bw/day). One specific color, caramel E150C, had the ADI set at 100 mg/kg bw/day. In February 2015, the U.S. Food and Drug Administration (FDA) agreed with the common consensus that the levels of 4-MEI found in food and drink were not considered a public health risk. A review of all available data on the safety of 4-MEI is under way, reassessing potential consumer exposure. This review will help the FDA determine if any regulatory action needs to take place. In the interim the FDA does not recommend that consumers change their diets. No evidence suggests that other countries opinions on the possible health risk posed by 4-MEI differs from the EU and U.S. While the U.S. federal government has no limits on 4-MEI, California's Proposition 652 lists it as a substance that can cause cancer and requires businesses to display a health warning if they are manufacturing or selling products in California with 4-MEI levels that exceed 29 mg per day. Recent research published in PLOS One however, suggests routine consumption of certain SSBs can result in 4-MEI exposures greater than 29 pg/day, i.e. the level at which the state of California requires products to carry cancer warning labels.s Campaign, Consumer, Competitor Insights In the UK and South Africa there is evidence of a small amount of consumer pressure being directed towards companies to encourage them to produce products to the same standard as California (below 29mg of 4-MEI per day). In response to this, Coca-Cola SA communicated that they would roll out their reduced 4-MEI recipe in South Africa by September 2015. Echoing this concern, Sensient Food Colors suggests that 67% of consumers are worried about the use of caramel color in food and beverage. Of those concerned, over 40% indicated that they were extremely or very concerned about caramel color.4 In January 2014 a product testing firm, Con sum ers Union, published the results of tests it had undertaken on a variety of different soft drinks to identify 4-MEI levels. Consumer Reports stated their results showed a 'concerning' level of 4-MEI in soft drinks and they called for the FDA to impose federal limits below that of 1 http://www.efsa.europa.eu/en/press/news/ans110308 2 http://\v\vw.prop6.qciearinghouse.eoni/prop-6s--piain-engiish.btrnl 3 http://journals.plos. org/piosone/article?ici=io.i37i/journal. pone. 0118138 4http://w\vw.sensientfoodcolors.com/colorinsight/sensient-options-for-cararnel/ Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

California's Proposition 65.5 They also found 4 MEI levels to be higher than 2Qmg per serving in Malta Goya and Pepsi products. At the time, Pepsi said that they had moved immediately to reach the requirement in California and were planning to have products with lower levels of 4-MEI available nationally by February 2014.6 Off the back of the Consumer Reports publication, a class action lawsuit was filed against Malta Goya and Pepsi accusing them of violating California's Unfair Competition Law, False Advertising Law and Consumer Legal Remedies Act based on the deceptive omission of the amount of 4-MEI in their product.? The California Federal Court eventually dismissed the lawsuit that Pepsi should provide medical monitoring for those who had purchased their product, as the plaintiff could not establish that the alleged risks were credible or substantial.8 In February 2015, Heine ken announced that it would change the recipe for Newcastle Brown Ale, replacing its caramel food coloring, which contains 4-MEI, with roasted malts.9 Sensient Food Color suggests that the brands that are prioritizing caramel replacement appear not to be traditional carbonated soft drinks, but rather beverage types that are positioned as "better" or "healthier" alternatives. Leading examples include10: • Ready-to-drink teas • Smoothie type drinks, especially those with added protein • Ready-to-drink iced coffees • Sparkling beverages • Coffee syrups and creamers • Iced tea mixes • Liquid drink mixes and water enhancers Demand for a different caramel color has seenSethness Products Company launch a new sugar-derived caramel color which is GMO-free and low in sulfites, and no 4-MEI is created during its production.11 Two pieces of scientific research released in late 2015 added to evidence that consumption of 4-MEI has negative health effects. The International Agency for Research on Cancer (IARC) has classified 4-MEI as a group 2B possible human carcinogen12 and a study published in Drug and Chem ical Toxicology concluded that 4-MEI has a genotoxic and cytotoxic effect in miceds 5 http://0ehha.ca.gov/public_info/facts/4MEifacts_021012.html 6 http://www.consumerreports.org/cro/2014/01/regU 7 http://www.foodnavigator-usa.com/Regulation/PepsiCo-and-Goya-Foods-targetecl-in-lawsuit-over-4-MEi 8 http://www.shb.com/results/insights/fblu/california-court-dismisses-4-mei-suit 9 http://www.bbc.com/news/uk-england-tyne-31196933 10 http://www.sensientfoodco3ors.com/color3nsight/sensient-options-for-caramel/ 11ht.tp://www.foodnavigator-usa.e^ 12http://www.ncbi.nlm.nih.gov/pubmed/26.c ;8Q486 J 3 http://www.medicalnewstoday.com/articles/289687.php Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Global Industry Competitive Landscape Food &Beverage Companies Heineken In February 2015, Heineken announced that it would change the recipe for Newcastle Brown Ale, replacing its caramel food coloring, which contains 4-MEI, with roasted malts. ^ Nestle Nestle USA is removing caramel coloring from its chocolate products. Caramel coloring is an exempt-from-certification color additive, which is used in only nine of the more than 250 chocolate products.^ PepsiCo Pepsi switched to low 4-MEI caramel colors in products across the U.S.16 Supermarkets and Retailers There is no publically available information from this group. Food Service & Major TCCC Customers Panera Bread Panera has added caramel color, classes II-IV to their "No No List". They are committed to removing artificial preservatives, sweeteners, and flavors along with colors from artificial sources from the food in our bakery cafes by the end of 201647 !4 http://wWW.bbC.COm/neWS/uk-england-tyne-3ii96933 J 5 http://wWW.neStleUSa.COm/media/preSSreleaSes/neStl%C3%A9-USa of-20 16 http://www.foodnavigator-usa.com/Regulation/pepsico-and-Goya-Foods-targeted-in-lawsuit-over-4-MEI 17 https ://www.panerabread.corrFpanerabread/documents/panera-no-no-list-05-2015 .pdf Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Manufacturer ^^^^^ ^ RyRvRR ^'AAALR ' • „•$,-. -S&S v¥v =$. .&& -StiS ,<S. •%! W? Mm::.: %# BIMBO WRHII ^^ft^^^^l 1ISHEL Ktdfcitkin& MARS v s bte«fe^i v % Nlirtli PPP«tJC2€$ 0$A&m\?mr Statement on Caramel Not specified Not specified Not specified Not specified Not specified Not specified ^HI^^HM^WH^^^^^^W^^^^^iH^i^i^^iHHi^^^^^^^^^^^^^^^^^ Not specified Not specified Not specified Not specified Not specified sillily ^I^P^^^W^^^^^H^^^^H^^^^^W^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^ Not specified Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Retailers §1 Ahold Carrelour ^| ^ KlHMZElli6R0UP 1 »•* ^%i t i ,% &«0« <fc»# \M * %Si # ^sssr ,^^" ^sasr *s®sr .igssr Walmarl wf&E FOODS Statement on Caramel Not specified Not specified Not specified Not specified Not specified Not specified Not specified Not specified Not specified Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Service Cos. fly BLOOMS ipBftANDS- (XCCC) S i (xcco CmAAm (XCCC) «t».c^**.v; (PepsiCo) COMPASS (TCCC) * » (TCCC) > OARDEN (TCCC ) (TCCC) M > . (TCCC) (TCCC) ^•^. ^ (PepsiCo) Statemen t on Carame l Not specified Not specified Not specified Not specified Not specified Not specified Not specified Not specified Not specified Not specified Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Service Cos. (PepsiCo) •GJuiiLLd* (TCCC) ^ ^ (PepsiCo) Statement on Caramel Not specified Not specified Not specified Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Colors Regional and Competitive Landscape Brief April 2016 Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Political and regulatory action and trends Food coloring, or color additive, is any dye, pigment or substance that imparts color when it is added to food or drink. Since the 1970s there has been public concern that food colorings cause Attention Deficit Hyperactivity Disorder (ADHD) like behaviors in children. In the European Union (EU) safety assessments of food colors are carried out by the European Food SafetyAuthority's (EFSA) Panel on Food Additives and Nutrient Sources added to food (ANS). These safety assessments will determine whether food colors are added to an EU approved list for all food additives. In 2007 the UK's Food Standards Agency (FSA) funded research conducted by Southampton University that showed evidence of increased levels of hyperactivity in young children consuming mixtures of artificial food colors and the preservative sodium benzoate. A European wide mandate now means if any of the six artificial colors, listed below, are present in food or drink they must carry a warning label stating 'may have an adverse effect on activity and attention in children'. The FSA and UK ministers recommended manufacturers to find alternatives to these coloring by the end of 2009. Use of these six colorings has virtually been eliminated across Europe. sunset yellow FCF (E110 quinoline yellow (E104) allura red (E129) tartrazine (E102) ponceau 4R carmoisine (E122) In the US the Food and Drug Administration (FDA) separates colorings into two main categories: certified color additives and exempt-from-certification color additives. Certified color additives are generally man-made synthetic color additives that must be approved by the FDA on grounds of composition and purity before manufactures can sell the product. The following is the list of color additives subject to certification: FD&C Red #3 FD&C Red #40 FD&C Yellow #6 FD&C Green #3 FD&C Blue #1 FD&C Yellow #5 FD&C Blue #2 Five of the allowed colors in the USA are the same as those food colorings linked to ADHD in the research conducted by Southampton University. All certified color additives must be declared by name in a product's ingredient statement. Users of exempt-from-certification color additives are responsible for ensuring that color additives comply with listing regulations. Despite most exempt-from-certification colors coming from natural sources, the FDA regulation does not consider any added color to be natural, therefore labeling must make clear the product includes artificial color or that color has been added. Canadian regulations allow for the same certified colors as the United States, with the additional allowance for amaranth. Campaign, Consumer, Competitor insights In the USA, the FDA has received criticism from organizations such as BioHealthBase.org for continuing to allow the use of the specific colorings that are no longer used across Europe. Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

The Center for Science in the Public Interest (CSPI) has issued a new report, 'Seeing Red', in 2016 calling for the FDA to ban FD&C colors, and in the interim, to require a warning label on products containing these colors. The report claims that mounting evidence has led to a growing consensus among researchers, physicians, psychologists, and others who treat patients with such behavioral disorders as attention deficit hyperactivity disorder (ADHD) that avoidance of food dyes benefits some children. The report estimates that more than half a million children in the United States suffer adverse behavioral reactions after eating or drinking food dyes, which leads to upwards of $5 billion per year in health costs. They also claim the FDA's recent exposure assessment is flawed and relies too heavily on parental accounts.1 The call for a ban is supported by research conducted by Bernard Weiss from the University of Rochester Medical Centre that finds that dyes have "some capacity to harm".2 ' 3 In the EU food manufacturers are increasingly using food colors that are considered ingredients rather than additives. This is seen as beneficial as these ingredients replaced the negatively perceived E numbers on the ingredient statement. As with artificial flavoring an increasing number of companies are committing to removing artificial colorings from their products. In June 2015 Zevia announced it would remove colorings from its soft drinks making them clear. Kraft Foods has removed all synthetic colors and preservatives from its popular boxed macaroni and cheese and General Mills has announced it will remove artificial colors from it cereals in the next few years. Nestle US has committed to removing certified colors from 250 products by the end of 2015. These products will be indentified by a "No Artificial Flavors or Colors" claim on the pack.4 In January 2016 Papa John'ss became the first national pizza chain to announce it has removed artificial colors from its entire menu and General Mills6 re-launched seven of their breakfast cereals with new recipes making 75% of their cereal portfolio free of artificial colors. Mondelez has also set themselves the target of removing all artificial flavors from their packaged food brands by 20207 Mars is the latest company to make a commitment in this area and in February 2016 they announced that they will remove all artificial colors from its human food products as part of a commitment to meet evolving consumer preferences. In their press release, Mars stated that artificial colors pose no known risks to human health or safety, but there commitments are driven by consumers calling on food manufacturers to use more natural ingredients in their products.8 Mars had been targeted by a petition by Center for Science in the Public Interest in February 2015 with the aim of encouraging them to follow Nestle's example and remove artificial colors and flavors from their products.9 Technavio Research released findings in November 2015 suggesting that 58% of U.S. consumers prefer food with coloring from natural sources, a large increase from the 2005 figure of 23%.10 1 http://cspinet.org/reports/seeing-red-report.pdf 2 http:/7www.scientificamericanxom 3http:/7wwvj .ncbi.nlm.nih.gov/pubmed/2iQ26orj .'t 4hrtp://wv*rw.iiesneusa.co end-of-20 5 http:/7 vvww.bus3nesswire.com/new 6 http://wmv.bak eiyandsn^^^ 7http://wvvo^foodbus:messrH;ws.net/art:ic3es/news home/Business News/20is/10/Mondelez to remove artificial..aspx?ID=%7B02S4QaCC-.^^J?7-44Qa-Q.': t42- OQ4DiACE6FE8%7D&cck=i 8 http://www.mars.com/g^ 9hrtps://w^\Tv.cspinet.org/new/20iso2iQi.ht.rnl 10http://vAviArtechnavioxom/news/companies-tiy-make-food-coioring-more-natural Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Global Industry Competitive Landscape Food & Beverage Companies Campbell Soup Campbell Soup Company11 will make all of its North America products without artificial colors or flavors by the end of fiscal 2018. Based on feedback from parents, the company will simplify the recipes of existing condensed soups for kids, removing ingredients such as added MSG and continuing to make the soup with no preservatives, no artificial colors and no artificial flavors. Additionally, they have also launched a new platform where consumers can go to find out what the ingredients are in Campbell's products.12 ConAgra Foods ConAgra is moving is moving to all natural protein and no artificial ingredients in its Healthy Choice and Simply Steamers brands, as well as launching a new natural Orville Redenbacher popcorn line with no artificial flavors, colors, or preservatives.^M General Mills General MiLVs re-launched seven of their breakfast cereals with new recipes making 75% of their cereal portfolio free of artificial flavors and colors. The company plans to have 90% of its cereals free from artificial colors and flavors by 2016. Kellogg's Kellogg's plans to remove all artificial colors and flavors in its cereal and snack brands by the end of 2018.l6 Kraft Heinz Kraft removed artificial colors, flavors, and preservatives from Kraft Macaroni & Cheese and began selling it in December 2015 without a formal announcement, only having changed the ingredient line on packaging. In March 2016 they announced the change.1 ? Mars In February 2016, Mars announced it will be removing all artificial colors from its human food portfolio. They expect the artificial color removal to be complete in about five years.18 In their press release, Mars stated that artificial colors pose no known risks to human health or safety, but there commitments are driven by consumers calling on food manufacturers to use more natural ingredients in their products.^ Mars had been targeted by a petition by Center 11 http://www.campbellsoupcompany.com/pressrelease/ campbell-continues-to-shift-portfolio-toward-faster-growing-categories-and-regions/ 12 http://www.whatsinmyfood.com/ « http://www.foodnavigator-usa.com/Manufacturers/ConAgra-Food-s-outlines-3-point-plan-to-grow-consumer-business J 4 http://www.conagrafoods.com/news-room/news-Orville-Redenbachers-New-Natural-Line-Pops-with-Savory-Gourmet-Flavors-1040168 !5 http://blog.generalmills.com/2015/06/a-big-commitment-for-big-g-cereal/ 16 http://www.nbcnews.com/business/business-news/kelloggs-eliminate-artificial-ingredients-cereal-snacks-n404451 J 7 http://www.kraftmacandcheese.com/ 18 http://www.mars.com/global/press-center/press-list/news-releases.aspx?SiteId=94&Id=6984 1 9http://wT>vw.niars.com/global/press-center/press-list/nevj s-releases.aspx?Siteid: =94&Id==6984 Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

for Science in the Public Interest in February 2015 with the aim of encouraging them to follow Nestle's example and remove artificial colors and flavors from their products.20 Mondelez International Mondelez International removing all artificial colors and flavors in key brands.21 Mondelez has also set themselves the target of removing all artificial flavors and colors from their packaged food brands by 2020.22 Nestle Nestle USA committed to removing all artificial colors and FDA-certified colors from all of its chocolate candy products by the end of 2015.2 3 These products will be identified by a "No Artificial Flavors or Colors" claim on the pack.2 4 Unilever Unilever is taking out artificial colors and flavors from many products like Knorr, "to deliver better, more natural products.2 s Supermarkets and Retailers Ahold Ahold and its banners Giant Food and Stop & Shop announced the introduction of Nature's Promise "Free from" products. Nature's Promise "Free from" ingredients are clearly indicated on the product packaging and all Nature's Promise "Free from" products are free from artificial ingredients, including artificial colors, flavors and preservatives. Nature's Promise "Free from" household products are free from harsh chemicals, including ingredients like added artificial dyes and fragrances. The more than 800 fresh, grocery, health and beauty and household Nature's Promise products can be found only at Ahold banners.26 HEB HEB's Select Ingredients program allows consumers easily identify products that are free of artificial flavors, high fructose corn syrup, and other synthetic ingredients by choosing products with the Select Ingredients logo. The Select Ingredients program also has a list of all ingredients that are included, and not included in these products.2 ? 20 https://www.cspinet.org/new/20ifs02iQi.html 21 http://www.mondelezinternational.eom/~/media/MondelezCorporate/Uploads/downloads/monde 22http://www.foodbusinessnews.net/articles/news home/Business News/2015/10/Mondelez to remove artificial.aspx?ID=%7B025493CC-3AB7-4403-9342- OQ4DiACl^FE8%7D&cck= 1 2 3 http://wWW.neStleUSa.COm/media/preSSreleaSes/neStl%C3%A9mSa-COm end-of-20 2 4 http://www.nestleusa.co:m/:med end-of-20 2 s https://www.unilever.com/sustainable-living/the-sustainable-living-plan/improving-health-and-well-being/improving-nutrition/delivering-better-products/index.html 26 http://mypbrand.com/2016/02/28/ahold-evolves-natures-promise-free-private-brand/ 27 https://www.heb.com/static-page/select-ingredients-landing Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Kroger Kroger's organic section has grown in response to its customers' interest in these products. Its natural and organic store brand Simple Truth (including Simple Truth and Simple Truth Organic) now consists of more than 2,600 items. These products have clearly defined product standards in order to clearly communicate to shoppers.28 All of the products within the natural section must adhere to Kroger's strict natural food ingredient standards which mean they must refrain from using 101 artificial preservatives and ingredients deemed "undesirable" by consumers.2 9 Whole Foods Whole Foods does not sell any products with artificial colors, flavors, sweeteners, preservatives, or hydrogenated fats in their stores. They also have a list of unacceptable ingredients on their website^0 Food Service & Major TCCC Customers Domino's Domino's Australia says it will remove all artificial colors, flavors, and preservatives from its pizza by 2017.31 Panera Bread Panera Bread pledged to remove all artificial preservatives, colors, sweeteners, and flavors from their food in all U.S. bakery-cafes by the end of 2016.32 They have also created an ingredient "No-No List" for ingredients not allowed in their food.33 Papa John's In January 2016 Papa John's34 became the first national pizza chain to announce it has removed artificial colors and flavors from its entire menu. Subivay Subway will remove all artificial flavors, colors, and preservatives from its menu items in North America by 2017.35 Yum! Brands Yum! Brands have made a commitment to remove artificial flavoring from their products in the near future, including Taco Bell and Pizza Hut. Pizza Hut removed all artificial colors and preservatives.36 28 http://sustainabiiity.krog6r.coni/supply-chain.htmI 29 http://www.simpletruth.com/about-simple-truth/101-free/ 3° http://www.wholefoodsmarket.com/about-our-products/quality-standards/food-ingredient s 1 http://ausfoodnews.com.au/2015/06/29/dominos-to-remove-all-artificial-colours-flavours-and-preservatives-from-pizza-menu.html s 2 https://www.panerabread.com/en-us/company/food-policy.html 33 https://www.panerabread.com/panerabread/documents/panera-no-no-list-05-2015.pdf 34 http:/ywv^."businesswire.com/ 35 http: //www. subway, com/menu/ alwaysimproving/default. aspx 3 6 http://\v^ntweatei\com/2oi5/5/26/865Q68s/taco-beri-pizza-hut-cut-artificial-ingredients-menus Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Manufacturer f^llllllPiii^ M m& m&.mm$£& M%.%M VHHP8 ^^^^^^^B 5,-iK ..¥"".>•*¥':' f.W^^NY <rf$ .<%vf * KmHtMeim M A.R S K btf&rmstk?**K&i "^ Statement on Colors North America products without artificial colors or flavors by 2018 lieaithy Choice & Simply Steamers Brands: No artifieial ingredients and all natural protein. Orville Redenbacher popcorn: No artifieial favors., colors, preservatives. Not specified Not specified Seven breakfast cereals with no artificial colors or flavors. 90% of ins cereals free or artificial colors and flavors by end of 2010. Not specified Not specified Not specified Rommmg^mmcohv^mM^o^in Its cereal and snack brands by the end of *»8> Removed artificial colors, flavors* mid, preservatives frorn Kraft Macaroni & Cheese Removing artmcial colors from human food portfoiio. Removing all artificial colors and flavors in packaged food brands by 2020. Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Manufacturer Nestle PEPSICO UwJUvWT Statement on Colors Nestle USA removed all ardflcial colors and FBA-certmed colors from chocolate eandy products. Not specified Removing artificial colors and flavors from many products. Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Retailers St Ahold O&rrettour <§ # 0ELHAIZEJK6R0UP {1*14*1*^*11 1 | « *W.4f % « Walmart WHuLErOODS Statement on Colors Nature's Promise "Free from" program includes products that are free from all artificial ingredients iuclnding artificial colors, flavors, and preservatives. Net specified Nm specified Select Ingredients program products are free from artificial flavors, HFCS, and otfier synthetic Ingredients* Simple Truth program products do not use tot artificial preservatives and ingredients Not specified Nm specified Nm specified No products with artileial colors, flavors* sweeteners* preservatives, or hydrogenated fats sold. Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Foo d Service Cos. fm SLOGAN' A 3RANSS! (TCCC) S iS (TCCC) G~U~ (TCCC) «.v: ,c.x5S.,. (PepsiCo ) COMPAS S (TCCC) AA ^f^^T=F ^ * ' (TCCC) ) - GARDEN (TCCC) w Smmmmm (TCCC) w*. (TCCC) (TCCC) m«*±W> (PepsiCo) iffjlte (PepsiCo) Statemen t o n Colors Not specified Nof specified No£ specified Ncf specified Net specified No£ specified Not specified ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^B Not specified Nof specified ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^8 Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Service Cos. Cl&ii&U" (TCCC) ..^ ^ (PepsiCo) Statement on Colors Removing artificial colors, flavors, and preservatives in NAby 2017. Removing arfificial flavoring Pizza Hnt to remove artificial colors and preservatives. Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Flavors Regional and Competitive Landscape Brief April 2016 Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Political and Regulatory Action and Trends There is currently a great deal of attention in relation to the distinction between natural and artificial flavorings. Most global bodies follow the lead of either the U.S. or EU when determining if a flavor is natural. Although U.S. and EU regulatory requirements are similar, they do have distinct differences. In the U.S., as specified within the US Code of Federal Regulation 21CFR 101.22 (Specific Food Labeling Requirements section) a material is deemed natural when it is derived from a product such as a spice, fruit, extract, oleoresin, or from a group of materials that the Food and Drug Administration (FDA) recognizes as natural starting materials. There is a long list of processes that can be applied which allow for the natural claim to be upheld. These include distillation, extraction, roasting, heating, enzymolysis, hydrolysis and fermentation. The word natural can only be used as described above. In the U.S. and Canada, flavors can be collectively declared as natural or artificial without listing the specific flavor components included. Regulations are slightly stricter in the EU, because the European Food Safety Authority (EFSA) is more restrictive with the permitted processes. EU regulation 1334/2008 contains a list of processes that are acceptable for producing a natural item which is limited in comparison to the lengthy U.S. permissions list. Additionally, the EU requires a natural substance be identical to that found in nature and not altered in any way. In the EU, general labeling requirements are defined in Regulation 1169/2011. This states that when flavors are present in a product, the labels must include either the word 'flavoring' or a more specific description. In addition, a statement relating to the flavors intended food use must be included (i.e. "for food" or the statement "restricted use in food" or a more specific reference to its intended food use). The EU Regulation 1334/2008 stipulates flavor labeling requirements. "Natural flavoring substance(s)" may only be used for flavorings where the flavoring part contains exclusively natural flavoring substances. The term natural may only be used for substances or preparations derived directly from an animal or vegetable material. Citrus flavoring perilla aldehyde was flagged as potentially genotoxic in 2013. As a result the EFSA conducted a safety evaluation that further questions the safety of the flavoring. The results suggested that perilla aldehyde and nine other chemically similar flavorings are believed to causes DNA damage to the liver. The ESFA's risk manager is in the process of determining the best next steps following this conclusion. The flavoring is not reported to be widely used in the EU. Approximately 250 substances are currently under evaluation by the EFSA - of which several are critical to TCCC's business. If the EFSA issues a safety concern it is likely that a substance will be banned or otherwise restricted.1 In February 2016 the EU List of Flavoring Substances was amended and a Commission Regulation has been published announcing the removal of five no longer supported flavoring substances. Those are: Vetiverol, Vetiveryl acetate, Methyl-2-mercaptopropionate, 2-Acetyl-i,4,5,6-tetrahydropyridin, 2- Propionyl pyrroline 1 % vegetable oil triglycerides.2 http://v»\'w.efsa.europa.eu/sites/default/files/sdenti.fic output/files/main documents/4i73.pdf 2 http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=:CELEX:a20i6Roi78 Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Codex has proposed to revise flavor labeling and there has been debate if using a negative term, "synthetic" should be used for artificial colors. Currently, the Codex Labeling Committee is discussing flavor labeling. This would lead to several label changes in countries that follow Codex. In Germany, flavor regulation is strongly enforced, with strict interpretation. In the CCAR Region (Armenia, Kazakhstan, Kyrgyzstan, Tajikistan, Turkmenistan and Uzbekistan), product registration which requires product and ingredient information may generate specific questions for TCCC, which could prove a risk to IP. A WHO expert panel continues to review flavorings in order to provide global safety assessments. The EFSA is also continuing to evaluate additional information provided by the industry on flavorings that were flagged for further evaluation. Campaign, Consumer and Competitor Insights In the US, a petition was filed in June 2015 with the FDA calling for a total ban on eight synthetic flavorings, currently used in small quantities in products such as baked goods, candy and ice cream, which are considered to induce cancer in animals and humans.s The eight substances (Benzophenone, Ethyl acrylate, Eugenyl methyl ether, Myrcene, Pulegone, Pyridine, Styrene and Trans,trans-2,4-hexadienal) are classified by the Flavor and Extract Manufacturers Association's (FEMA) as "generally recognized as safe" and already have extremely strict maximum allowable levels. A 2015 Nielson study based on a global online survey showed on average 41% of global consumers saw the absence of artificial flavors as a very important factor in their purchasing decisions and 29% were willing to pay a premium for natural flavors.4 Percentage that rate no artificial flavors as very important in their purchasing decisions Percentage that are very willing to pay a premium for natural flavors Global Average 41% 29% Asia￾Pacific 42% 31% Europe 40% 2 0% Middle East/ Africa 41% 45% Latin America 45% 46% North America 30% 21% 3 http://www.foodsafetynews.com/2015/06/petition-asks-fda-to-ban-8-synth hittp:/7www.nielsen.com/yx)ntent/dam Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

This consumer behavior has resulted in a number of large organizations e.g. Kellogg's, Nestle, Yum! Brands, Chipotles, Campbell Soup Company6 , Hershey? and Panera Bread making commitments to remove artificial flavoring from their products in the near future. In January 2016 Papa John's8 became the first national pizza chain to announce it has removed artificial flavors from its entire menu and General Mills9 re-launched seven of their breakfast cereals with new recipes making 75% of their cereal portfolio free of artificial flavors. Mondelez has also set themselves the target of removing all artificial flavors from their packaged food brands by 202010 . A quick review of the sector did not suggest that NGO campaigning activity was a significant driver behind these commitments. In his book, The Dorito Effect, Mark Schatzker claims that over exposure to artificial flavors has not only made consumers crave them, but has programmed us to believe that is how food should taste, reducing appreciation for natural flavors in fresh food.11 Global Industry Competitive Landscape Food & Beverage Companies Campbell Soup Based on feedback from parents, the company will simplify the recipes of existing condensed soups for kids, removing ingredients such as added MSG and continuing to make the soup with no preservatives, no artificial colors and no artificial flavors. Additionally, they have also launched a new platform where consumers can go to find out what the ingredients are in Campbell's products.12 ConAgra Foods ConAgra is moving is moving to all natural protein and no artificial ingredients in its Healthy Choice and Simply Steamers brands, as well as launching a new natural Orville Redenbacher popcorn line with no artificial flavors, colors, or preservatives.^M 5https://www.chipotIe.com/food-\vith-integriW 6 http://www.bloomberg.eom/news ^ 7http://www.techtimes.com/article^^ 8 hUp://\vww.busmessvvire.com/^ 9 http://Vvww.bak eiyandsnacks.co^ 10httg:y_/www.foodbiisinessnews.net/articles/news home/Business News/20 i/y/iO/jMondelez to remove artificial.aspx?ID=%7B02j549/3CC-3AB2-4403-9342- OQ4l3iACE6FE8%7D&cck=i 11 http://Avww.markschatzker.com/cloritoeffect--home-page/ 12 http://www.whatsinmyfood.com/ « http://www.foodnavigator-usa.com/Manufacturers/ConAgra-Food-s-outlines-3-point-plan-to-grow-consumer-business J 4 http://www.conagrafoods.com/news-room/news-Orville-Redenbachers-New-Natural-Line-Pops-with-Savory-Gourmet-Flavors-1040168 Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

General Mills General Mills^ re-launched seven of their breakfast cereals with new recipes making 75% of their cereal portfolio free of artificial flavors and colors. The company plans to have 90% of its cereals free from artificial colors and flavors by 2016. Hershey's In Feb 2015, Hershey16 made the commitment to transition to 'simple and easy-to-understand ingredients'. In Nov 2015, Hershey's released the "Holiday Hershey's Kisses Milk Chocolates and Hershey's Milk Chocolate Bars made with simple ingredients and no artificial flavor".1 ? These are some of the first products from Hershey's to transition to 'simpler ingredients'. Kellogg's Kellogg's plans to remove all artificial colors and flavors in its cereal and snack brands by the end of 2018.l8 Kraft Heinz Kraft removed artificial colors, flavors, and preservatives from Kraft Macaroni & Cheese and began selling it in December 2015 without a formal announcement, only having changed the ingredient line on packaging. In March 2016 they announced the change.10 Mondelez International Mondelez International removing all artificial colors and flavors in key brands.20 Mondelez has also set themselves the target of removing all artificial flavors and colors from their packaged food brands by 2020.21 Nestle Nestle USA committed to removing all artificial colors and FDA-certified colors from all of its chocolate candy products by the end of 2015.22 These products will be identified by a "No Artificial Flavors or Colors" claim on the pack.2 s Unilever Unilever is taking out artificial colors and flavors from many products like Knorr, "to deliver better, more natural products.2 4 !5 http://blOg.generalmills.COm/2Ol5/06/a-big-COmmitment-for-big-g-Cereal/ 16 https://www.thehersheycompany.com/newsroom/news-release.aspx?id=2017846 17 https://www.thehersheycompany.com/newsroom/news-release.aspx?id=2iii905 18 http://www.nbcnews.com/business/business-news/kelloggs-eliminate-artificial-ingredients-cereal-snacks-n404451 J 9 http: //www.kraftmacandcheese. com/ 20 http://www.mondelezinternational.eom/~/media/MondelezCorporate/Uploads/downloads/mondelez_intl_fact_sheet.pdf 2mttp://www.foodbusinessnews.net/articles/news home/Business News/2015/io/Mondelez to remove artifieial.aspx?ID=%7B025493CX-3AB7-4403-Q342- OQ4DlA{;E6FE8%7Dfe 22 http://www.nestleusa.com/media/pressreleases/nestl%C3%A9-usa-commits-to-removing-artificial-flavors-and-fda-certified-colors-from-all-nestl%C3%A9-chocolate-ca end-of-20 2 3 htt.p://www.nest[eusa.com7m.edia/pressreleases/nest]% end-of-20 24 https://www.unilever.com/sustainable-living/the-sustainable-living-plan/improving-health-and-well-being/improving-nutrition/delivering-better-products/index.html Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Supermarkets and Retailers Ahold Ahold and its banners Giant Food and Stop & Shop announced the introduction of Nature's Promise "Free from" products. Nature's Promise "Free from" ingredients are clearly indicated on the product packaging and all Nature's Promise "Free from" products are free from artificial ingredients, including artificial colors, flavors and preservatives. Nature's Promise "Free from" household products are free from harsh chemicals, including ingredients like added artificial dyes and fragrances. The more than 800 fresh, grocery, health and beauty and household Nature's Promise products can be found only at Ahold banners.2 s HEB HEB's Select Ingredients program allows consumers easily identify products that are free of artificial flavors, high fructose corn syrup, and other synthetic ingredients by choosing products with the Select Ingredients logo. The Select Ingredients program also has a list of all ingredients that are included, and not included in these products.26 Kroger Kroger's organic section has grown in response to its customers' interest in these products. Its natural and organic store brand Simple Truth (including Simple Truth and Simple Truth Organic) now consists of more than 2,600 items. These products have clearly defined product standards in order to clearly communicate to shoppers.2 ? All of the products within the natural section must adhere to Kroger's strict natural food ingredient standards which mean they must refrain from using 101 artificial preservatives and ingredients deemed "undesirable" by consumers.28 Whole Foods Whole Foods does not sell any products with artificial colors, flavors, sweeteners, preservatives, or hydrogenated fats in their stores. They also have a list of unacceptable ingredients on their website.2 9 25 http://mypbrand.COm/2Ol6/02/28/ahold-eVOlveS-natUreS-prOmise-free-private-brand/ 26 https://www.heb.com/static-page/select-ingredients-landing 2 7 http://sust.ainability.kroger.com/supply-chain.html 28 http://www.simpletruth.com/about-simple-truth/101-free/ 2 9 http://www.wholefoodsmarket.com/about-our-products/quality-standards/food-ingredient Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Service & Major TCCC Customers Caribou Coffee Caribou Coffee announced it will eliminate artificial flavorings in all of their menu items by the end of 2016. They plans to convert all of its flavor syrups to a 'clean label standard', starting with vanilla syrup and moving to caramel syrup. They are promoting 'simple ingredients'.3° Chipotle Chipotles1 has removed artificial flavoring from their products. Domino's Domino's Australia says it will remove all artificial colors, flavors, and preservatives from its pizza by 2017.32 Panera Bread Panera Bread pledged to remove all artificial preservatives, colors, sweeteners, and flavors from their food in all U.S. bakery-cafes by the end of 2016.33 They have also created an ingredient "No-No List" for ingredients not allowed in their food.34 Papa John's In January 2016 Papa John'sss became the first national pizza chain to announce it has removed artificial colors and flavors from its entire menu. Subway Subway will remove all artificial flavors, colors, and preservatives from its menu items in North America by 2017.36 Yum! Brands Yum! Brands have made a commitment to remove artificial flavoring from their products in the near future, including Taco Bell and Pizza Hut. Pizza Hut removed all artificial colors and preservatives.37 3° http://www.foodbusinessnews.net/articles/news_home/Food-Service-Retail/2016/0 i/Caribou_Coffee_makes_clean_lab.aspx?ID=%7BDi9C0577-AE27-4F2C-9334- 5AC9222C4089%7D 3 1 https:/Avww.chipotle. com/food- with --integrity s 2 http://ausfoodnews.com.au/2015/06/29/domm 33 https://www.panerabread.com/en-us/company/food-policy.html 34 https://www.panerabread.com/panerabread/documents/panera-no-no-list-05-2015.pdf 35 http://www.businesswire.com/news /home/20 i6oii2005348/en/Papa-John%E2%8o%Q9s-National-Pizza-Chain-Aiinounce-Elimination s 6 http: //www. subway, com/menu/ alwaysimproving/default. aspx 37 http://wwvv.eater.eom/2015/5/26/8659683/haco-bell-pizza-hut-cut-anaficial-ingredients-menus Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Manufacturer yiidi^i&i {"V-.A. A .-,,\-' ^ A. " V™,' .•>! N < \Cj? " - '^ A ; & ,-,:;> {.•>,••,••«.•>;. v. • & .S^A^^A^A^S^V: 1 , UrBMBD ''SSR8 ^^^te^^ S 5,-i % v!i^:•: y i-^ y A<N^»,\:y Y KraftKHemz a\ A* A a "*% C"* % / i /%. !"C ^% Jtaftttrmrtfottol "^ Nestle PEPSICO U*\£fifcVGV* Statement on Flavors North America products without artificial colors or flavors by 2.0 lS Healthy Choice & Simply Steamers Brands: No artificial ingredients arid all natural protein, OrviiJeEedcnbaeherpopeorm No artificial flavors* colors, preservatives. Not specified Not specified Seven breakfast cereals with, no arfitMal colors or flavors. 90% of its cereals free or artificial colors and flavors by end of noim Not specified Not specified Holiday Hershey3 s Kisses Milk Chocolates and Htc&hey y s Milk Chocolate Bars made with simple ingredients and no artificial flavor. Removing artificial colors and fiarorsin its cereal and snackbrand^ by the end of ^Oi8+ Removed artificial colors, flavors, and preservatives from Kraft Macaroni & Cheese Not specified Removing all artificial colors and flavors in packaged food brands by 20-20-, Nestle USA removed all artificial colors and FDA-certlficd colors from chocolate candy products. Not specified Removing artificial colors and flavors from many products. Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Retailers IAI Hi lul u C&rref&ur 4§# DELHNZEH6R0UP $*&£&& JOHHF rf^Sf ^^SB?" MOH" ^BSSP" Walmart Wl&£ POODS Statement on Flavors Nature's Promise "Free from" program includes products that are free from all arfifidal ^gradients induohng artificial colors, flavors, and preservatives. Not specified Not specified Select Ingredients program products are free from artificial flavors, HFC$> and other synthetic ingredients￾Simple Truth program products do not nse ion artificial preservatives and ingredients Not specified Not specified Not specified No products with artificial colors, flavors, sweeteners, preservatives, or liydrogenated fats sold. Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Foo d Service Cos. fm SLOGAN' A 3RANSS! (TCCC) S i S (TCCC) G~U~ (TCCC) (PepsiCo) COMPAS S (TCCC) (TCCC) i DARDEN (TCCC) 4t Xfcmbwi* (TCCC) *** (TCCC) (TCCC) Ai**SJC (PepsiCo) Statemen t o n Flavors Not specified Not specified ^^liffi^^H^^^^^^^^^W^W^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^ silliiii^^ Not specified Not specified Not specified ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^R Not specified Not specified ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^K Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Service Cos. (PepsiCo) <£JZL1L&U (TCCC) J * ^ (PepsiCo) Statement on Flavors Removed artificial colors and flavors. Removing artificial colors, flavors, and preservatives in MA by 2017, Removing arnfleral flavoring. Pisza Hut to remove artificial colors and preservatives. Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Preservatives Regional and Competitive Landscape Brief April 2016 Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Political and regulatory action and trends A preservative is a substance that is added to products such as foods and beverages to maintain beverage quality by preventing decomposition by microbial growth or by undesirable chemical changes that result in off-taste. Two popular liquid preservatives are potassium sorbate and sodium benzoate. The regulatory authorities and the World Health Organization (WHO) have raised concerns over using benzoate preservatives because in combination with ascorbic acid (Vitamin C, which is present in many food and beverages) a carcinogen called benzene is produced at low levels. The beverage industry has issued guidelines for their members to mitigate benzene formation when using benzoates. Sodium benzoate and potassium sorbate have been on the FDA's Generally Recognized As Safe (GRAS) substance database since 1973 and 1975 respectively. This is because there is currently no evidence in the available information to show that benzoic acid, sodium benzoate and sorbic acid as food ingredients constitute a hazard to the general public when used at current levels or that might reasonably be expected to in the future. A Center for Food Safety and Applied Nutrition (CFSAN) survey of almost 200 samples of soft drinks and other beverages tested for benzene conducted from 2005 through May 2007 found a small number of products contained more than 5 ppb of benzene.1 Whilst there are currently no limits for the amount of benzene allowed in soft drinks, limits do exist for drinking water. This varies from 10 ppb in the Republic of Korea, to 5 ppb in Canada and the United States (though some states e.g. California and Florida have stricter limits), to 1 ppb in the EU. The UK Food Standards Agency (FSA) has down-played the contribution of soft drinks to people's exposure to benzene as people would need to drink at least 20 liters (5.5 gal) per day of a drink containing benzene at 10 pg to equal the amount of benzene they would breathe from city air every day. General atmospheric pollution, cigarette smoke and exhaust fumes all contains benzene. Following a request from the European Commission, the Panel on Additives and Products or Substances used in Animal Feed (FEEDAP) reiterated its former conclusion that the use of benzoic acid at the maximum level of 125 mg/kg for complete feed is safe for all animal species. However the Panel could not conclude on the safety of benzoic acid for pigs for fattening at the proposed maximum use level of 10,000 mg benzoic Acid/kg complete feed.2 The EFSA Panel on Food Additives and Nutrient Sources added to Food (ANS) recently delivered a scientific opinion re-evaluating benzoic acid (E 210), sodium benzoate (E 211), potassium benzoate (E 212) and calcium benzoate (E 213) when used as food additives (EFSA Journal 2016;14(4):4433). The Panel concluded that the results of short-term and subchronic studies on benzoic acid and its salts indicate that their toxicity is low, that benzoate additives do not raise a concern with respect to genotoxicity and the Panel noted that the available data did not indicate any carcinogenic potential. However, the Panel expressed a concern that the group ADI was exceeded in the brand-loyal scenario in particular for toddlers and children consuming on a regular basis flavoured drinks. The main food categories contributing to this exceedance were unprocessed fruits and vegetables and flavoured drinks. 1 http://www.fda.gov/Food/FoodborneillnessContaminants/ChemicalContaminants/ucmo55815.htm 2 http:/Avwn,v.efsa.europa.eu/en/efsajournal/pub/4SS.'t Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

As a conclusion of the 48th session of the Codex Committee of Food Additives (CCFA) that was held in March 2016 in China, based on recommendations of the FAO/WHO Joint Expert Committee on Food Additives (JECFA), the Committee decided to review the Maximum Level (ML) of benzoates in water-based flavored drinks and due to a safety concern stated by JECFA at current use levels, revoked the current ML of 600/1000 ppm to an interim ML of 250 ppm. The ML for benzoates will be finalized at the next session in 2017.3 Sodium sorbate was included on the list of food additives for evaluation by the Joint FAO/WHO Expert Committee on Food Additives (JECFA) at the 48th session of CCFA as well.4 In response to this, Colombia shared its opinion that there is no publication showing unacceptable risk of using the preservative and the country would not support its removal from Codex Standard 192-1995.5 The EFSA Panel on Food Additives and Nutrient Sources added to Food (ANS) delivered a scientific opinion re-evaluating sorbic acid (E 200), potassium sorbate (E 202) and calcium sorbate (E 203) when used as food additives ( EFSA Journal 20i5;i3(6):4i44). The Panel noted that there was no evidence of genotoxic activity for sorbic acid or potassium sorbate. The Panel established a new temporary significantly reduced group ADI expressed as 3 mg sorbic acid/kg bw/day for sorbic acid and its potassium salt. The Panel noted that the most realistic approach using reported use levels and analytical data in the non-brand-loyal scenario did not exceed the temporary group ADI in any population group at the mean or in adolescents, adults and the elderly at the high level, except in the toddler and children population groups in one country. Campaign, Consumer, Competitor insights In 2006, Sustain suggested that soft drinks should have a similar legal limit for benzene as drinking water's lppb. This followed a study that found a number of soft drinks with benzene levels above 1 ppb. This was also picked up by campaign group KillerCoke.org. There is no evidence of significant campaign activity around this topic in recent years. Benzene is increasingly receiving attention as a dangerous air pollutant. Early in 2016 there were media stories relating to high concentration of benzene in the airinHouston6 and Los Angeles.7 In an article on the growth in popularity of craft sodas in Canada, Matt Philips, the owner of Phillips Soda Works said "I don't know why you would launch any product today with preservatives in it. It's not what consumers want", whilst referring to the presence of sodium benzoate in many beverages 8 . s http://www.fao. org/fao-who-codexalimentarius/sh-proxy/en^ 48%252FReport%252FR.EP16_FAe.pdf 4 vvww.fao.org/mpuL/download/report/Q46/fa48 01e.pdf 5 http://www.fao.org/fao-who--codexalimentarius/sh-proxv 48%252FWD%252Ffa48 16e.pdf 6 hrtp:/Avww.faoustonprGss.com/new 7 htt.p://www.nbcto 8 httpy/sharebaa.tumblr.com/^ Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

There are a number of articles on sodium benzoate appearing on health websites, with one claiming that it is the new chemical on everybody's mind these days.910 NaturalNews.com published a strongly worded article suggesting that sodium benzoate deprives human cells of oxygen and breaks down the immune system and causes blood cancer. They claim that Foodinsight.org (International Food Information Council and Foundation) are part of a disinformation campaign as they downplay the health issues associated with the preservative.11 Abouthealth.com supports the findings of the FDA and suggest that it would take approximately 180 times the amount of sodium benzoate present in a typical diet before any problems might occur.12 They also downplay the level of risk associated with benzene in soft drinks. There appears to be less in the media about potassium sorbate, however there are examples of articles that promote the potential negative health impacts of the preservative e.g. damage to white blood cells and its ability to damage genetic information in cells.13 Research carried out on the health impacts of sodium benzoate have found that: • Rats subjected to constant doses of sodium benzoate developed anxiety and poor motor function.^ The link between anxiety and sodium benzoate comes as the liver uses glycine to metabolize sodium benzoate, and a low level of glycine can lead to anxiety according to research by Dr. Arcady Marked.^ • Sodium benzoate has also been linked to hyperactive behavior in children through a 2007 study by the University of Southampton.16 The Asthm a and Allergy Foundation of Am erica also states that significant numbers of people report allergic reactions to the compound.1 ? • In 2010 a study found that sodium benzoate disrupted chromosomes and could cause human white blood cells to mutate.18 A more recent study published in 2016 supported these finding and suggested that sodium benzoate has the potential to be immunomodulatory.10 • A 2007 study by Sheffield University found that sodium benzoate can damage the DNA of mitochondria, affecting everyday bodily functions.20 On 11 January 2016, orphan designation, a status assigned to a medicine intended for the use against a rare condition, was granted by the European Commission to Syri Limited, United Kingdom, to use sodium benzoate in the treatment of hyperargininaemia. This is an inherited disorder known as 9 http://thegoodhuman.com/what-is-sodium-beT3ZQate/ 10http:/7theorganicdiabetic.org/20if;/ii/dangers-of-sodium-benzoate/ 11http://y>rww.naturalnews.com/o.q;2Q47 sodium benzoate perishable foods chemical preservatives.html# 12 http://nutrition.about.eom/od/changeyourdiet/a/sodiumbenzoate.htm ^ lxttp://w\vw.doctorsh6althpf ess.com/food-and-nutrition-articles/common-side-effects-of-potassiuin-sorbate ^ http://europepmc.org/abstract/MED/244iQ44fi ^ http://wvvw.sctencedirect.com/science/article/pii/SooQiaoix7iioooo25 16 http://www.thelancet.com/journ als/lancet/article/PIISoi40-6736(07)6i3o6-3/abstract 1 7http://www.whatsmyige.com/display.cfm?id=9Sz:sub=2oSz:cont=285 18 http://www.ncbi.nlm.nih.gov/pubmed/21130826 ^ http://wTAnv.ncbi.nlm.nih.gov/pubmed/267066Q7 20 http://www. theguaihian.com/lifeandstyle/2007/jun/o.7/healthandAvellbeing.health Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

'urea-cycle disorder', which causes ammonia to accumulate in the blood.21 There is also evidence suggesting that the chemical is a good treatment for Schizophrenia.22 In China a random inspection test conducted by the Taipei Department of Health found a dried radish product that contained up to 2.3g/kg of Benzoic Acid when the legal maximum level is i.og/kg.2 s Global Industry Competitive Landscape Food &Beverage Companies Campbell Soup Based on feedback from parents, the company will simplify the recipes of existing condensed soups for kids, removing ingredients such as added MSG and continuing to make the soup with no preservatives, no artificial colors and no artificial flavors. Additionally, they have also launched a new platform where consumers can go to find out what the ingredients are in Campbell's products.2 4 ConAgra Foods ConAgra is moving is moving to all natural protein and no artificial ingredients in its Healthy Choice and Simply Steamers brands, as well as launching a new natural Orville Redenbacher popcorn line with no artificial flavors, colors, or preservatives.2 5>26 General Mills In January 2016, General Mills filed a law suit2 ? against Chobani LLC after they suggested that their Yoplait Yogurt Brand contained pesticides. They did this by initially saying that the product used the preservative potassium sorbate, then implying that this ingredient is actually a pesticide, saying: "That stuff is used to kill bugs."28> 2 9 2 ^lttp://\^^v\^^ema.eul•opa.eu/ema/index.j'sp?curl=pages/medicines/human/orphaIls/20l6/o2/humaIl orphan ooi70i.jsp&mid=WCoboiac058ooidi2b 22 http://wvvr vv.ncbi.nlm.mh.gov/pubmed/ 24089054 2 3http://w\yw.taipeitimes.com/News/taiwan/archives/20i6/o 1/12/2003637028 2 4 http://www.whatsinmyfood.com/ 2 s http://www.foodnavigator-usa.com/Manufacturers/ConAgra-Food-s-outlines-3-point-plan-to-grow-consumer-business 26 http://www.conagrafoods.com/news-room/news-Orville-Redenbachers-New-Natural-Line-Pops-with-Savory-Gourmet-Flavors-1040168 2 7 https://consumermediallc.fil es.wordpress.com/2Qi6/01/2QRi36340-general-mills-v-chobani-cnmplaint-i6-cv-ooo.c ;2.pdf 28 http://w1vw.chicagotribune.com/business/ct-chohani-controversial-advert-20160113-stow.html 2 9 http://cOnSUmerist.com/2Ol6/Ol/i2/general-mills-SUeS-CllObani-for-advertising-that-yOplait-COntaillS-bUg-Spray/ Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Kraft Heinz Kraft removed artificial colors, flavors, and preservatives from Kraft Macaroni & Cheese and began selling it in December 2015 without a formal announcement, only having changed the ingredient line on packaging. In March 2016 they announced the changes0 Mars In the UK, Mars removed sodium benzoate from their product lines as a result of consumer pressure and government recommendations. Supermarkets and Retailers Ahold Ahold and its banners Giant Food and Stop & Shop announced the introduction of Nature's Promise "Free from" products. Nature's Promise "Free from" ingredients are clearly indicated on the product packaging and all Nature's Promise "Free from" products are free from artificial ingredients, including artificial colors, flavors and preservatives. Nature's Promise "Free from" household products are free from harsh chemicals, including ingredients like added artificial dyes and fragrances. The more than 800 fresh, grocery, health and beauty and household Nature's Promise products can be found only at Ahold banners.s1 HEB HEB's Select Ingredients program allows consumers easily identify products that are free of artificial flavors, high fructose corn syrup, and other synthetic ingredients by choosing products with the Select Ingredients logo. The Select Ingredients program also has a list of all ingredients that are included, and not included in these products.s2 Kroger Kroger's organic section has grown in response to its customers' interest in these products. Its natural and organic store brand Simple Truth (including Simple Truth and Simple Truth Organic) now consists of more than 2,600 items. These products have clearly defined product standards in order to clearly communicate to shoppers.33 All of the products within the natural section must adhere to Kroger's strict natural food ingredient standards which mean they must refrain from using 101 artificial preservatives and ingredients deemed "undesirable" by consumers.34 Walmart In the UK, Walmart (ASDA) removed sodium benzoate from their product lines as a result of consumer pressure and government recommendations. 3° http://www.kraftmacandcheese.com/ s 1 http://mypbrand.com/2016/02/28/ahold-evolves-natures-promise-free-private-brand/ s 2 https://www.heb.com/static-page/select-ingredients-landing 33http://sustainabilit.y.kroger.com/supply-chain.htmi 34 http://www.simpletruth.com/about-simple-truth/101-free/ Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Whole Foods Whole Foods does not sell any products with artificial colors, flavors, sweeteners, preservatives, or hydrogenated fats in their stores. They also have a list of unacceptable ingredients on their website.ss Food Service & Ma jo r TCCC Customers Domino 's Domino's Australia says it will remove all artificial colors, flavors, and preservatives from its pizza by 2017.36 Panera Bread Panera Bread pledged to remove all artificial preservatives, colors, sweeteners, and flavors from their food in all U.S. bakery-cafes by the end of 2016.37 They have also created an ingredient "No-No List" for ingredients not allowed in their food.38 Subw ay Subway will remove all artificial flavors, colors, and preservatives from its menu items in North America by 2017.39 Yum /Brands Yum! Brands have made a commitment to remove artificial flavoring from their products in the near future, including Taco Bell and Pizza Hut. Pizza Hut removed all artificial colors and preservatives^0 35 http://www.wholefoodsmarket.com/about-our-products/quality-standards/food-ingredient s 6 http://ausfoodnews.com.au/2015/06/29/dominos-to-remove-all-artificial-colours-flavours-and-preservatives-from-pizza-menu.html 37 https://www.panerabread.com/en-us/company/food-policy.html 3 8 https://www.panerabread.com/panerabread/documents/panera-no-no-list-05-2015.pdf 39 http: //www. subway, com/menu/ alwaysimproving/default. aspx 4 0 htlp://w^vw.eater.com/20i5/5/26/8659683/taco-be]l-pizza-hut-cut-artificial-rngredients-menus Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

ppj'pdds i&ft pmfpzds toft *%* UF%#ft3»tt»3»«K ppfpdds totf ^ ybwt\mm&\ p&lfpadx tOM iliill l mi iiiil£ lllllliili|illi; MmmWW^^m^^^mW^^^m W*W 7 ¥ 4 1 ^3 C l V ¥ % iiiiiiii!;iiiiiiiiii!;iiii! iiiimii :iiiiii;:ii!iiiiiiiiiiiii; ?#/9/?>i|£i; ppj'pdds lOft **&, ppj'pdds i&ft >.NV-*V<f>> A.'JK^yJ:-* •?:-*> ppj'pdds lOft ppj'pdds lOft iiiiiiiiiii iiiiiiii i liillililiiiiliiliil pmfpads WN ..^NV^^^^W^^^''- •&? p&tlp&ds fojq iliiillllliliii; liiiiiiiill;i§ii!; ^^^^^^^^^^^ ^ lililii; m^^g^$^$0$fc iiiiiiii i iiijpiiiiiiii ; ^^^^^^^^^^^^ ^ i«i e liiiliiiiliBI I P^^^^^^^^^^^^^^^^^^^^^^^^^^H^^^^^^^P S3AIJBA.I3S3.Id UO JU3UI3JBJS A3jnj3BjnuBj\[ poo d Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Retailers WAhoicJ Carrefbur <§#> y y y y y J & y Wm y y y y s ® wv^xi^vwK: ^swisss ^s» ^ ^54 . B 4W«4S4 M ^^^<s'W# ' .(SS^ .<S8833r .y ^ .<S58&Sr .tSS ^ Walmart Wfl&iJIRXSClS ^s.yM;^yj:^c^4^smy ^ Statement on Preservatives Nature's Promise "Free from* program mdndes products mat are free from all artificial ingredients Inckclmg artificial colors, flavors, and preservatives. Not specified Not specified Select Ingredients program products are free from artificial flavors, MFCS, and otlier synthetic ingredients. Simple Trnth program products do not use 1.01 artiocial preservatives and ingredients Not specified Not specified Walmart (ADSA) removed sodium benzoate in the UK. No products with artificial colors, flavors, sweeteners, preservatives, or hydrogenated fats sold. Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Service Cos. Statement on Preservatives p ^ f>LOOHjN> (TCCC) Not specified HM5 (TCCC) Not specified Not specified (TCCC) !T (PepsiCo) Not specified C OM PAS S (TCCC) Not specified (TCCC) Not specified i DARDEN (TCCC) Not specified (TCCC) ^^^^^^^^^^^^^^^^•^^^•^^^^^I^^^^^^^^^ W *™»* (TCCC) Not specified (TCCC) Not specified <McJ (PepsiCo) Hllllllll: illllilll illliilliiillil •II I :|iiiiiliilil ^^^^^^^^^^^ ^ iii i .sSVi-J&s (PepsiCo) Not specified Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Food Service Cos. <CuUiluM (TCCC) J3^ ^ (PepsiCo) Statement on Preservatives Removing artificial colors, flavors, and preservatives in MA by 2017. Pirn Hat to remove artrficial colors and presorvatives. Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Sugar, LNCS, and Sweetness Regional and Competitive Landscape Brief April 2016 Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Executive Summary With global overweight and obesity rates along with non-communicable diseases (NCD) rising, there has been an increased attention on caloric content of foods and beverages from sugar, particularly added1 or "free"2 sugars. During 2015 and continuing into 2016, this intense focus on sugar, and in particular, its role in diet and health has accelerated discriminatory attention to caloric beverages. Additionally, there is a growing aversion to ingredients considered artificial or synthetic, and processed foods in general. Our low- and no-calorie sweeteners (LNCS) are among those "artificial" ingredients considered controversial, though debate around arguably the most contentious sweetener aspartame has slowed. The emergence of "natural" sweeteners like Stevia however, have more recently served to divide opinion, though it is now permitted as a food additive in many countries. These developments have prompted governments to propose and enact some policies and regulations around taxation, labeling, warning statements, marketing restrictions, and others. Many of the proposed policies and regulations are discriminatory or punitive, targeting specific ingredients or categories. Many negatively affect the TCCC portfolio, caloric sparkling beverages in particular and those containing LNCS. Although the impact of these measures to date may be considered limited, as the policies and regulations spread and intensify, the impact in the future may be considerable. TCCC continues to build its mid-calorie category of beverages, using a combination of LNCS and sugar, where allowed by local governments, as well as continue to expand the zero and low-calorie beverage category, along with smaller, controlled-portion packaging. With research and scientific opinions around "sweetness" developing, a push from the public to reduce the level of sweetness, regardless of whether from a caloric or non-caloric sweetener in foods and beverages, is beginning to enter the global debate on foods and beverages and their relationship to health. The Global Setting Despite warnings not to demonize one single ingredient - namely sugar - in the obesity debates, there has been a proliferation of studies focused on sugar and its role not just in obesity, but also in contributing to non-communicable diseases. At the same time, increasing attention has been paid to global, regional and national consumption rates of sugar. There is growing concern about high rates of obesity and intake of sugar in the developing world, as evidenced in a report 1 The U.S. Food and Drug Administration defines "added sugars" as "Sugars that are either added during the processing of foods, or are packaged as such, and include sugars (free, mono- and disaccharides), syrups, naturally occurring sugars that are isolated from a whole food and concentrated so that sugar is the primary component, for example fruit juice concentrates, and other caloric sweeteners." 2 The World Health Organization defines "free sugars" as: "Free sugars refer to monosaccharide's (such as glucose, fructose) and disaccharides (such as sucrose or table sugar) added to foods and drinks by the manufacturer, cook or consumer, and sugars naturally present in honey, syrups, fruit juices and fruit juice concentrates." 3 The Food and Drink Federation in http://www.bbc.co.uk/news/health-^^rsiAQi Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

by the Oversees Development Instituted Individual nations, including the UK, U.S. and the Netherlandss, are reformulating their Nutrition Guidelines, all with an emphasis on reducing sugar consumption. A 2015 World Health Organization (WHO) guideline recommends adults and children reduce their daily intake of free sugars to less than 10% of their total daily energy intake. A further conditional recommendation calls for reduction "to provide additional health benefits" to below 5% of total daily energy intake, or roughly 25 grams (6 teaspoons) per day. WHO based their quantitative recommendations exclusively on scientific evidence related to dental caries. The scientific evidence for the <5% recommendation was judged and reported as "very low quality." The WHO intention is for the recommendation to be used by policy-makers to assess current intake levels of free sugars in their countries relative to a benchmark. If intake levels of free sugars are high, then the country may choose to develop measures to decrease intake of free sugars, where necessary, through a range of public health interventions (e.g., dietary guidelines, labeling, taxation, marketing restrictions, and channel restrictions, such as schools and feeding programs). As discussion continues about the role of LNCS in foods and beverages, some regulators are starting to look at the sweetness profile of products regardless of the calories they contain, with the goal of asking manufacturers to reduce sweetness just as sodium was reduced at a population level working with producers over the past decade. Short-term research has shown that changes in consumption of sugar may influence perceived sweetness.6 Additionally, recent research has shown that preferences and the ability to perceive sweetness varies from person to person,? and that reducing sugar intake can modify perception of sweet intensity but not pleasantness. In fact, the authors reported that, during the fifth month of the study, subjects who had been in the reduced-sugar group quickly increased their sugar intake to baseline levels. A study released in 2015 has argued that artificial sweeteners are unable to satisfy an individual's craving for sugar, since the brain responds to taste and calorie counts in fundamentally different ways and it is the brain's yearning for calories, and not sweetness, which dominates a person's craving for sugar.8 More research needs to be conducted on the topic of sweetness to determine the health, genetic, and environmental factors at play and how this may shape government policy and the food and beverage industry. Two WHO bodies, WHO Europe and Pan American Health Organization (PAHO), have released nutrient profile models to be applied to restricting marketing of foods and beverages to children (WHO Europe) or broad policies to reduce obesity and improve diet (PAHO). The WHO Regional Office for Europe Nutrient Profile Model (NPM) is designed for use by governments for the purpose of restricting marketing of foods to children.9 Although TCCC's responsible marketing policy is not to direct marketing of any beverages to children under 12 years of age, the WHO Europe NPM 4 http://www.odi.org/sites/odi.org.uk/files/odi-assets/publications-opinion-files/8776.pdf mttps://www.gezondheidsraad.nl/en/publication/Healthy%20 %20the%20Dutch%20dietary%20guidelines%2020i5 6 Wise PM, Nattress L, Flammer LJ, Beauchamp GK. Reduced dietary intake of simple sugars alters perceived sweet taste intensity but not perceived pleasantness. Am J Clin Nutr. 2015 Nov 25. 7 Reed DR, McDaniel AH. The human sweet tooth. BMC Oral Health. 2006;6(Suppl 1V.S17. 8 http://www.nature.com/neuro/iournal/vaop/ncurrent/abs/nn.4224.html 9 http://www.eimxwho.int/ data'assets/bdi_file/0Q05/2^^ Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

includes a prohibition on beverages with LNCS in its category criteria for beverages such as soft drinks, juice drinks, energy and sports drinks. Expanded use of the WHO Europe NPM is of concern for foods and beverages in schools, labeling, or other policy proposals. In February 2016, the Pan American Health Organization (PAHO) NPM was published.10 The aim of the model is to be used as a tool in the design and implementation of strategies relating to the prevention and control of overweight/obesity and improving healthful diets. PAHO recommends governments throughout the Americas use the NPM in policymaking, with broad application to: marketing restrictions, school foods & beverages, FOP "warning" labels, taxation, agriculture subsidies, and food assistance programs. The NPM defines "processed" & "ultra-processed" foods & beverages, and exempts unprocessed & minimally processed foods. All "cola, soda, and other soft drinks; sweetened juices and energy drinks" are defined as "ultra-processed." 100% fruit or vegetable juice are defined as "minimally processed" and exempt; as well as "culinary ingredients" including sugar and honey. "Excessive in free sugars" is defined as >io% energy from "free sugars" - almost all caloric beverages will be excessive in free sugars. "Excessive in other sweeteners" is defined as "Any amount of other sweeteners." "Excessive in sodium" is defined as ">i mg of sodium per 1 kcal" and would apply to caloric sports drinks. The energy- and ingredient-based standards in the PAHO NPM are the strictest globally proposed standards for foods and beverages to date. 10http://iris.paho.org/xmlui/bitstream/handle/i2a4s678Q/i862i/Q78Q27Sii87aa eng.pdf?sequence=8&isAllowed=y Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

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The Regional Landscape North America Sugar Consumer Behaviour According to research by the University of North Carolina, the U.S. is no longer the world's leading consumer of SSBs on a per capita basis11 and sales of full calorie soda have fallen by more than 20% over the last 20 years. The drop in consumption of SSBs was heralded by the New York Times12 as "the single largest change in the American diet in the last decade". A Gallup poll released in 2015 highlighted that both diet drinks and SSBs are at the top of the list of things that U.S. citizens said they try to avoid in their diets, with 62 percent saying they avoid drinking diet beverages, and 61 percent saying they avoid regular beverages.^ New guidelines and research In January 2016, the 2015-2020 Dietary Guidelines for Americans were announced by the Departments of Health and Human Services and Agriculture. No tax recommendations accompanied the guidelines which were described as, "a series of science-based recommendations...to reduce obesity and prevent chronic diseases." As part of the guidelines, Americans now are encouraged to consume: "Less than 10 per cent of calories per day from added sugars." This is the first of the eight editions of the Dietary Guidelines for Americans to recommend a quantitative target to limit intake of added sugars.^ A number of studies conducted in the U.S. reflect those elsewhere in the developed world that seek to evaluate the role of sugar in contributing to non￾communicable disease and ill-health. The studies link consumption of sugar (often in SSBs) to non-alcoholic fatty liver disease, metabolic illness, abdominal fat gain, depression, and breast cancer. The National Center on Addiction and Substance Abuse released a report addressing, for the first time, a focus beyond substance addiction to include food addiction. The report acknowledges a growing scientific opinion that certain eating behaviors, including those leading to obesity, may benefit from being explained through the lens of addiction.^ Labelling The U.S. Food and Drug Administration (FDA) has proposed regulations that would require food labels to declare the quantity of "Added Sugars" in addition to "Total Sugars" and establish a 50 g/d Daily Value for "added sugars". Final regulations are anticipated in 2016. Changes to the U.S. Nutrition Facts Panel to 11 http://www.thelancet.com/journals/landia/article/PIIS22ia-8.': ;87ri.': ;')004iQ-2/abstract 12http://www.nytimes.com/20if;/io/o4/upshot/soda-industry-struggles-as-consumer-tastes-change.html? r=i !3 http://www.livescience.com/s17aa-americans-avoid-soda-gallup-poll.html !4 http://www.hhs.gov/about/news/2016/01/07/hhs-and-usda-release-new-dietary-guidelines-encourage-healthy-eating-patterns-prevent-chronic.html !5 http://www.centeronaddiction.org/addiction-research/reports/understanding-and-addressing-food-addiction-science-based-approach-policy Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

indicate the "added sugar" in packaged foods and a Daily Reference Value (DRV) have been vaunted, but it remains contested exactly how the Nutrition Facts Panel will be altered to reflect these changes.16 In New York, if passed the Sugar-Sweetened Beverages Safety Warning Act would make it a requirement for SSBs to carry a warning stating: "Drinking beverages with added sugar contributes to obesity, diabetes, and tooth decay." The legislation is currently pending in the state Assembly but to date 26 scientists and researchers have come out in support of this legislation.1 ? A similar bill in Hawaii died in committee in 2015. In Califo rnia, the sugar-sweetened beverages safety warning act (SB 203), which would have required that warning labels are placed on sugary drink containers, failed by one vote in the Senate Health Committee on April 29, 2015. After being considered again in January 2016 the Bill yet again failed to move out of the Senate Health Committee.18 In June 2015 Canada released its revised Nutrition Facts label for public comment. The proposal includes a "% daily value" for total sugars of 100 g/day. The Canadian proposal does not make the distinction between "added" sugar and total sugars as is being proposed by the U.S. FDA. The added sugars declaration in nutrition labeling was dropped after an initial consultation. The newly proposed regulations would require grouping all "sugars" together in the ingredient declaration on food labels (e.g., "sugars (sugar, high fructose corn syrup, honey, molasses)"). There is no current Canadian government proposal for FOP labeling. Revision to Canadian nutrition labeling regulations was anticipated to be finalized by 2017, but the new government's review of all regulations could delay implementation further, and "added sugars" could return in a revised proposal. Tax In November 2014, B e rke le y became the first US city to enact a law taxing sugary drinks. According to a study published in November 2015, after three months the tax showed some (minor) impact on consumption as the average price of all SSBs in the town had increased by about 0.5 cents per ounce.10 Anti-SSB campaigners are seeking to bring voter referendums and legislation to tax SSBs in numerous U.S. cities in 2016. This follows Chicago's Alderman George Cardenas proposing a city tax of 1 cent per ounce on soda and other sugary drinks in 2015. In his proposal, 75% of the revenue generated by the tax would go into a "Chicago Wellness Fund" used to pay for city and Chicago Public Schools health initiatives. The Illinois Beverage Association (IBA) presented strong opposition to the proposal, suggesting that there already was a tax on SSBs (extant since 1992, though low) and proposing that education is a better way to battle obesity in the city. The city of Philadelphia (Pennsylvania) is considering a SSB tax. Thomas Farley is the new Health Commissioner in Philadelphia, after serving as Health Commissioner for New York City. Dietitians of Canada, along with other health societies and obesity prevention organizations, released a position statement on February 9, 2016, that recommends an excise tax of at least 10-20% be applied to sugar-sweetened beverages sold in Canada given the negative impact of these products on the health of the population and the viability of taxation as a means to reduce their consumption.20 16 http://www.bloombergview.com/articles/2015-07-27/fda-makes-m *? https://www.cspinet.org/new/201602181.html 18 http://civileats.com/2016/01/14/california-soda-warning-label-bill-dies-as-research-suggests-efficacy/ ^ http://www.ncbi.nlm.nih.gov/pubmed/26444622 20 http://www.dietitians.ca/Dietitians-Views/Sugar-sweetened-Beverages-and-Taxation.aspx Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

On March l, the Canadian Senate Committee on Social Affairs, Science and Technology released their long awaited report "Obesity in Canada - A Whole-of￾Society Approach for a Healthier Canada". The report included 21 recommendations in total and discussed a range of topics and recommendations including taxation, advertising ban, review of Canada's food guide, nutrition labelling (including FOP labeling), health promotion, public awareness, and education.21 Advertising In terms of new regional regulation, so far in 2015 the San Francisco Board of Supervisors debated and passed three pieces of legislation aiming to curb SSB consumption in the city. One new measure requires SSB adverts posted on buses, billboards and other city surfaces (including sports venues) to carry warning statements. The board also approved the prohibition of sugary beverage advertisements on public property, and the use of city funds to purchase sugary beverages.22 In response, in July 2015 the American Beverage Association started legal action against the city claiming that the new legislation requiring health warning labels on sugary beverages and prohibiting advertisements of them on city property violates the First Amendment. In January 2016 Baltimore Councilman, Nick Mosby, introduced legislation that would require a similar messaging on SSB advertising as in San Francisco. Those suggesting the legislation believe the messaging would be a simple way to educate the public, and especially children.2 3 Channel Restrictions There are an increasing number of examples of SSBs not being sold and/or served in public locations. The University of Califo rnia San Francisco is phasing out sales of sugar-sweetened drinks at its campuses, hospitals and clinics. Allina Health announced that it will no longer offer sugar-sweetened beverages and deep-fried foods in its hospital cafeterias, vending machines, cafes and other food-service areas effective January 1, 2016. In Hawaii, a bill introduced in January 2016 would prevent childcare facilities serving SSBs to children; a similar bill was introduced in Connecticut. In New York a bill was introduced with the aim of prohibiting sales of oversized SSBs to minors. Restaurants are also changing their behaviour; Burger King, McDonalds, IHOP, Wendy's, Subway, Chipotle, Dairy Queen, Panera and Apple bee's have all taken SSBs off their children's menus. Davis, California introduced legislation that restaurants must offer water or milk, not SSBs as a primary option for kid's menus.2 4 LNCS LNCS consumption has increased in the U.S. according to a recent publication analyzing the National Health and Nutrition Examination Survey (NHANES). Around 30 percent of Americans consume LNCS with about 20 percent of that coming from beverages.2 s In this commentary, published in the Lancet, authors Barry Popkin and Corinna Hawkes put forward their view that policy makers still need to make practical decisions about how to treat drinks with LNCS and fruit juice in the design of policies to tackle consumption of SSBs. However the absence of consensus on the evidence of beverages containing LNCS and fruit juices creates a practical conundrum for policy formulation.26 http://\v\vw.parl.gc.ca/content/sen/committee/42i/SQCI/Reports/20i6-02-2.g; Revised report Obesity in Canada e.pdf 22 http://www.washingtontimes.co 2 3 http://www.baltimoresun.com/health/bs-hs-sugary-beverages-20160111-story.html 24 http://www.sacbee.com/food-drink/article224a871a.html 2 s DrewnowskiA, Mennella JA, Johnson SL, Bellisle F. Sweetness and food preference. Eur J ClinNutr 20i2;i42(6):ii42S-ii48S. 26 http://w^vw.thelancetxom/journals/landia/article/PHS22ia-8s87(i.': ;)oo4iQ-2/fulltext Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Aspartame has long been a controversial substance in the U.S. When the U.S. FDA first approved aspartame in 1974, accusations of conflicts of interest and inadequate research were pervasive. This approval was rescinded the following year, but rewarded in 1981. There have been large-scale randomized trials and cohort studies investigating aspartame, the largest of which were those undertaken by the U.S. National Cancer Institute. In 2006 their study of nearly half a million people, comparing those who consumed drinks containing aspartame with those who did not, found that aspartame did not increase the risk of leukemia, lymphoma or brain cancer. In spite of these findings, debate around the substance persists; a number of scientific studies into aspartame continue to be undertaken2 ? and consumers remain cautious. In April 2015, PepsiCo announced that they were removing aspartame from Diet Pepsi. Bloomberg attributed this to declining sales considering the result of customer backlash against the controversial sweetener. The change only applies to the US market and will affect all varieties of Diet Pepsi, such as Caffeine Free Diet Pepsi and Wild Cherry Diet Pepsi. Other artificial sweeteners are also subject to investigation. A controversial study linking sucralose and cancer in mice, led by Italian researcher Morando Soffritti, was published in February 2016. The findings of the study were first presented at a cancer conference in London 2012 where they caused widespread backlash - mainly from industry. The study has now been published in the peer-reviewed International Journal of Occupational and Environmental Health. In light of the study, the US based food watch dog, Centre for Science in Public Interest has downgraded sucralose from caution to avoid.28 Though headlines around natural sweeteners have largely been dominated by Stevia, industry coverage in September 2015 was focused upon another natural sweetener - Mogroside, which hails from the Chinese indigenous luo han guo vine. Whilst demand for the product reportedly "soars across the globe", the US is emerging as a particularly strong market. According to recent statistics, over 180 products sweetened with mogroside were launched in the first five months of 2015 alone, an increase of 140% on the same period in 2014. Demand in the US has doubled between 2011 and 2014. Latin America Sugar In June 2015, Chile finalized regulatory norms defining limits for calories (70 calories/ioomL), and sugar (5g/ioomL) content in front-of-pack (FOP) food labeling. All foods that exceed these limits will be required to bear a FOP black and white octagonal stop sign that reads "HIGH IN" followed by CALORIES, SUGAR, etc., along with the words- "Ministry of Health". The stop sign symbol is anticipated to apply to 50% of TCCC's portfolio in Chile (with "High in" sugar). Labeling must be in place by July 2016. They also are implementing regulations banning the marketing of foods in the "High in" category to children less than 14 years of age to go alongside their existing SSB tax. A recent commentary published in The Lancet has reported that the fastest absolute growth in sales of sugar-sweetened beverages by country (2009-14) was seen in Chile.2 9 2 7 http://www.scientificamerican.com/article/artificial-sweeteners-may-change-our-gut-bart 28 http://www.foodnavigator.com/Science/Controversial-study-linking-sucralose-and-cancer-is-published 2 9 http://vvvvw.lEelancet.com/journals/landia/article/PIIS221a-8.s87fi.e i')oo4iQ-2/fulltext Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Ecuado r has implemented mandatory color-coded FOP labeling using nutrition criteria, including total sugars. The Ministry of Health (MoH) in Ecuador has presented a proposal for Food Advertising and Promotion Regulation, which will require that some foods/beverages carry the statement "Product high in [fat/sat fat/sugar/salt]" depending on nutrient composition. Regulations apply to full sugar soft drinks, teas, nectars, and drinks with low fruit juice content. Industrial food makers in Ecuador are not allowed to use images of animal characters, cartoon personalities or celebrities to promote products high in salt, sugar or fat and President Rafael Correa publically promised to introduce a tax in September 2014. A formal announcement has yet to be made. In Mexico, the amount of calories must be displayed FOP per serving and per container, on single-serving and multi-serving containers. Labeling also includes FOP GDA labeling for total sugars, fat, and sodium. Mexico enacted a tax on SSB and sugar-containing foods in 2013, and implemented the tax beginning on January 1, 2014. All beverages with added sugar paid a tax of $1 peso per liter or about a 10 percent price increase. In June 2015, it was reported that the Mexican soda tax cut sales of sugary soft drinks by 6% in its first year.3° Mexico's ANPRAC (National Association of Producers of Soft Drinks and Carbonated Water) released a rival report that argued that there was only a 1.9% decrease in soft drink sales up to June 2015.31 The public health community is now advocating to raise the tax to $2 pesos per liter. Research shows a very minimal average reduction of about 6 calories per day based on purchase data.32 No data are available yet related to the tax's impact on rates of obesity or health outcomes. Other government initiatives include banning adverts for high-calorie food and soft drinks during peak TV viewing times and before children's movies and a law that only allows healthy food and beverages to be served in schools. Brazil issued national dietary guidelines in 2015 that are punitive to sugar and our beverages, classifying them as "ultra-processed" foods.33 Other efforts, such as the National Pact for Healthy Eating, include progressively reducing sugar, fat, and sodium added in processed and ultra-processed foods, to encourage the consumption of healthy foods in schools, as well as regulate marketing and advertising of food and beverages in schools. The Center for Science in the Public Interest's (CSPI) report Carbonating the World identifies Brazil as an example of a country where cartoon characters, social media messages and product placement on television shows are being used to market sugar sweetened beverages to children and adolescents.34 Voluntary FOP labeling schemes have also been adopted in the country. A study in the journal, Appetite, examined caloric compensation for SSB consumption during daily meals, in a free-living setting in Brazil (which the authors argue positively distinguishes their study from similar research). They concluded that SSB consumption contributed to higher energy intake due to weak caloric compensation and recommended discouraging the intake of SSBs especially during lunch and dinner as a way to help reduce excessive energy intake and lead to better weight management.35 In Peru, a labeling law has been enacted that may create a single "high in" (red) labeling approach, encompassing almost all foods and beverages as "high in" sugar, salt, or fat, because of extremely low levels for "high in" (<2.5 g sugar per 100 ml). An advisory statement: "High in [Sat Fat] [Sugar] [Salt]: Avoid excessive consumption" accompanies the labeling. Regulations have yet to be developed. Additionally, the 2013 "Promoting Healthy Food for Children Act" prohibits advertisements that "encourage heavy consumption of foods and beverages that contain high levels of trans fat, sugar, sodium, and saturated fat". The law's integrated approach also includes nutrition education in schools, encourages more physical activity and controls advertising aimed at children and adolescents younger than 16 years. 3° http://wWW.bmj.COm/cOntent/352/bmj.h67O4 3 1 http://time.com/4O6Q7il/mexicO-Slim-SOda-tax/ 3 2 http://cie.itam.mx/sites/default/files/cie/i5-O4.pdf 33 http://bvsms.saiide.gov.br/bvs/piiblicacoes/dietary guidelines brazilian population.pdf 34 http://cspinet.org/new/2016020Qi.html 35http://www.sciencedirect.com/science/article/pii/SoiQ.': ;666ai.': ;aoi2aQ Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Bolivia has adopted a law with labeling requirements for "very high," "medium," and "low/healthy" levels of "added" sugar, saturated fat, and sodium. They also are requiring a set of four diet and health messages to rotate on packaging over time for foods and beverages "very high" in fat, added sugar, or sodium.s6 During development of regulations, there is room to advocate for total sugars versus added sugars, a move away from "very high," and to modify the diet and health messages. Bolivia also proposes to restrict advertising to adolescents. In Colombia, Health Minister Alejandro Gaviria advocated a tax on sugary drinks in order to prevent a perceived obesity crisis. The suggestion was put forward in 2014; however, no tax has been put in place to date. Venezuela recently passed legislation that would require punitive sugar labeling. Sugar sweetened beverage labels must have one of three negative public health messages about the dangers of sugar consumption and obesity and chronic disease: "Consumption of SSDs increases the risk of diabetes, heart problems, heart attack, cancer, osteoporosis, and tooth decay and erosion"; "SSDs contain high levels of phosphoric acid that have been associated with kidney stones and other renal problems"; and "Consumption of SSDs contribute to obesity". Once implemented, they must be rotated every six months and must cover 15- 20 percent of the label. The implementation of the label messages have been postponed indefinitely. LNCS Brazil's Ministry of Agriculture is now allowing the mixture of sugar and LNCS in non-alcoholic beverages. In order to use LNCS with sugar, a 25 percent reduction in calories or sugar must be achieved. Europe Sugar The 4th edition of the European Code Against Cancer has recommended that to have a healthy diet and reduce the risk of cancer, people should limit high￾calorie foods, in particular avoid foods high in sugar like sugary drinks.37 Sugar taxes are among the measures governments should consider according to Joao Breda, WHO Europe's program manager for nutrition, physical activity and obesity.s8 The WHO's Commission on Ending Childhood Obesity also reported its findings39 echoing this position, describing childhood obesity as an "exploding nightmare" and favoring an SSB tax to help fix it. s 6 The rotating statements for foods and beverages "very high" in fat, "added" sugars, and salt are: • Consume iodized salt, sugar, or fats in moderation. • Consuming fruits and vegetables improves health. • Obtain an average of 30 minutes of physical activity daily. • Consume 10 glasses of water daily. 37 http://www.cancerepidemiology.net/article/S1877-7821f i.4)ooi27-7/abstract?cc=y= 3 8 http://www.theguardian.com/world/201rs/sep/23/young-europeans-may-die-at-earlier-age-than-their-grandparents-says-who 39 http://apps.who.int/iris/bitstream/io66.'s/204i76/i/Q78Q24i.'sioo66 eng.pdf?ua=i Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

WHO Europe has proposed stronger action around marketing to children through the development of the Nutrient Profiling Model. This follows a declaration adopted by WHO Europe members committing them to decisive action to reduce food marketing to children and a policy approach that promotes a common nutrient profiling tool. The WHO Europe Nutrient Profiling Model was developed in response to this and was well received by all countries that participated in its pilot phase. Its food and beverage nutrient criteria are stricter than those in the voluntary industry EU pledge on responsible marketing to children, and for beverages, excludes LNCS.4° There is also growing pressure on the European Commission to take appropriate actions on regulations of sports foods and drinks. The EU Framework for National Initiatives on Selected Nutrients calls for a reduction in added sugars by a minimum of 10% by 2020.41 In Norway, Denmark, Sweden and Iceland the "Nordic Keyhole" voluntary labeling scheme (which highlights the healthier alternative within a product group) introduced stricter requirements in March 2015, with a transition period until 1 September 2016 for products adhering to the old requirements. Keyhole products will need to contain less salt, sugar and saturated fat. The criterion for added sugar content has been made stricter in some food groups, such as cereals and yogurt. The Norwegian Consumer Council criticized the approach as they would prefer to see labeling that identifies unhealthy rather than healthy products.42 The Nordic Council of Ministers, which includes Norway, Denmark, Sweden and Iceland, have developed a proposed protocol to monitor marketing to children (M2K) of foods and beverages high in fat, sugar, and salt (HFSS) within and among Nordic countries. The protocol focuses on children up to 12 years of age, with additional monitoring through 17 years, covering all broadcast, print, electronic, and social media; and uses the WHO Europe nutrient profiling model.43 The UK's Scientific Advisory Committee on Nutrition (SACN) recommended that the current advice of not exceeding 10% of total dietary energy from free sugars be halved to no more than 5% of total dietary energy intake from free sugars.44 This recommendation was supported with research by Cambridge University, the British Medical Journal (BMJ), and the campaign group Action on Sugar who are increasingly making links between sugar consumption, obesity, and diabetes.45,46,47 The UK is currently awaiting the release of the government's obesity strategy in which it is likely that sugar is targeted and a crackdown on marketing will constitute a stronger government approach.48 Despite activity by a diverse range of anti-sugar activists (including London Mayor Boris Johnson and Celebrity Chef Jamie Oliver) it remains unclear whether measures will include a sugar tax. This is despite Cancer Research United Kingdom (UK) commissioning the UK Health Forum to assess the impact of a SSB tax on future rates of overweight and obesity. The analysis using a modeling process concludes that the 4° http://www.euro.who.int/ data/assets/pdf file/0005/270716/Nutrient-Profile-Model Version-for-Web.pdf?ua=i 4 1 http://ec.europa.eu/health/nutrition_physical_activity/docs/added_sugars_en.pdf 4 2 http://www.eurofoodlaw.com/labeling/norways-keyhole-food-labeling-scheme-misleading--i.htm 43 Coca Cola Internal Tracker Dec 2016 44 https://www.gov.uk/government/publications/sacn-carbohydrates-and-health-report 45 http://www.diabetologia-iournal.org/files/OConnor.pdf 4 6 http://www.bmj.com/content/asi/bmj.ha.c ;76 47 http://www.thelancet.com/iournals/landia/article/PIIS22ia-8s87(is')00477-s/fulltext 4 8 http://www.thegrocer.co.uk/buying-and-supplying/health/fdf-head-wright-calls-out-nhs-boss-over-sugar- claims/siQSSi.article Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

introduction of a 20% excise tax on SSBs could avoid 3.7 million people being obese by 2025. This is equivalent to a 5% shift in obesity prevalence. The technical summary is entitled Short and Sweet: why the government should introduce a sugary drinks tax.w Measures introduced as part of the governments' childhood obesity strategy may include the ban of TV adverts for foods and beverages high in fat, sugar and salt. This is likely to prove popular as a study by The Royal College of Pediatrics and Child Health (RCPCH) found that nearly two-thirds of people supported the introduction of such a ban. The British Retail Consortium has voiced its support for mandatory and uniform reduction targetss° as large retailers such as Tesco, ASDA, Marks & Spencer and Waitroses1 take action on restricting sales of sugary drinks and reducing sugar content. Manufacturers including Kellogg's, Unilever and Ribenas2 have reported that they will be reducing the amount of sugar in their products. There is also significant debate about the optimum way to label foods with campaigners calling the current approach of using the percentage of an adult's recommended intake meaningless. It is expected that the distinction between added sugars and total sugar will attract more media and campaign attention in the future. One suggestion on how to clearly communicate with consumers is that products should include a FOP label that details the number of teaspoons of sugar in a product. The Local Government Association (LGA), which represents over 370 councils in England and Wales, is arguing for fizzy drinks and fruit juices containing up to 12 teaspoons of sugar to carry a health warning. Professor Nigel Hunt, of the Royal College of Surgeons (UK), goes one step further and has called for warning pictures to highlight the risk of rotting children's teeth. In Ireland, the Irish Heart Foundation has called for a nationwide ban on junk food in Irish schools after its survey found that despite Ireland's obesity crisis, most schools offer foods high in sugar, fat and salt. The Irish Republican Party has proposed a policy of a 20% tax on sugar sweetened drinks in a bid to tackle Ireland's rising obesity levels. The party said this tax would generate €58 million every year. The plan would come into effect if the party is elected to government after the next election in 2016. In France, mandatory restrictions are in place around marketing to children and a new health law includes the creation of a uniform, voluntary FOP food nutritional labeling system, passed in the National Assembly. The public health bill, adopted on December 17, 2015, introduces the project of identifying the most appropriate voluntary nutritional labeling scheme. A consumer test on this is scheduled to start in March, and results are expected by the end of 2016.53 External research suggests that the graded 5-Color Nutrition Label is considered by French consumers as easy to identify, simple and quick to understands^ France has also banned self-service soda fountains and soft drink free refills in restaurants. The Belgian Federation for Commerce and Services is considering whether to use FOP labeling on 'own label' products in major supermarkets. 49http://www.ukhealthforum.org.uk/prevention/pie/?entryid4a=S4Q20 5°http://www.dailymail.co.uk/health/art^ s 1 http://www.theretailbulletin.com/news/waitrose pledges commitment to sugar reduction 21-01-16/ s 2 http://www.dailymail.co.uk/wires/pa/article-a41aiQa/Sugar-levels-cut-food-drink-giants.htm 53 Coca Cola Regulatory Update Jan 2016 54http://www.idfdaiwnutrition.org/ListPage.php?siteID=26oMD=aas&specialHeaderID=a2.': ; Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

The Germ an confectionery industry has criticized plans for a 19% tax proposal on sugar aimed at reducing obesity. Taxes are also being explored in Russiass and Guernsey.s6 In Poland an amendment to the Act on Food and Nutrition Safety means that the advertising and promotion of foods that do not meet specific nutritional standards are prohibited in pre-schools, primary and secondary schools. LNCS The European Food Safety Authority is the scientific guarantor for the safety of food additives (including sweeteners) in use within the European Union. The EU has both an approved list of sweeteners and also details a maximum dose. The European Food Safety Authority brought forward its review on aspartame, planned for completion by 2020, at the request of the European Commission. This was following several studies which suggested that aspartame had increased several malignancies in rodents, and was a potential carcinogen at normal dietary doses. Scientific Opinion on the re-evaluation of aspartame (E 951) as a food additive conducted by the European Food Safety Authority [2013] represents the most comprehensive review of aspartame to date. It concluded that at the recommended levels (aomg a day per kilogram of body weight) aspartame was safe, even for children and pregnant women. In the UK, as in most European counties, laws on sweeteners (in this case Sweeteners in Food Regulations) are harmonized with EU Directives. There is increased interest in the use of stevia-based products in the European Union (EU), after certain highly purified extracts of stevia leaf were authorized for use as sweeteners at permitted maximum levels by EU Regulation 1131/2011 (Dec 2011). Whilst use is permitted as a food additive, stevia leaves require a novel food authorization before they can be legally marketed in the EU. To date, no such authorization has been issued. The Belgian Institute of Public Health, together with the Italian Council for Agricultural Research and Economics published their assessment of the Italian population's exposure to the main low calorie sweeteners. They demonstrate that for Ace-K, aspartame, cyclamate, saccharin and its Na, K and Ca salts, sucralose, thaumatin, neohesperidin DC, steviol glycosides, neotame, and aspartame-acesulfame, consumption levels are far below the respective Accepted Daily Intake.57 In France, a tax on all beverages with added sugar or with artificial sweeteners was levied in 2012. In 2015, a proposal to raise the excise tax from €7.45 per hectoliter to €9.0 per hectoliter was put forward, but it did not pass. The current reality is that France is regularly revisiting the beverage tax issue to generate revenue. 55 https://www.bostonglobe.eom/b s 6 http://www.bbc.co.uk/news/world-europe-guernsey-asaQi178 57 http://sito.eutecra.it/portale/public/documeuti/it-sweeteuers-study.pdf Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Eurasia and Africa Sugar In In dia, as part of the Financial Bill, Finance Minister Aran Jaitley has raised the excise duty on "aerated drinks with added sugar" which now runs at i8%.s8 There is also a proposal to increase "sin taxes" on aerated drinks as part of a series of recommendations by Chief Economic Advisor Arvind Subramanian on the upcoming Goods and Services Tax (GST) bill. He said in a statement in December 2015 that "All of the evidence we have to date suggests that taxing sugary drinks would be far more powerful and effective for protecting public health than simple education measures".59 It has been recommended that aerated beverages are put in the same brackets as tobacco and luxury cars, and should be subject to a 40% Goods and Service Tax. This could result in a price increase for consumers of 20%.6 ° The beverage industry has reacted strongly, and say they are shocked with the proposed tax increase which groups them with tobacco products, which they do not consider their products to be analogous to. They counter beverages are not addictive and are not required to carry health warnings.61 The Public Health Foundation of India advocate that a tax is one of the strongest interventions to reduce consumption of sugar, but this measure should be accompanied with robust behavioral interventions to change the social norms and perceptions.62 The Delhi-based Uday Foundation has petitioned the Indian Government to "immediately ban junk food and carbonated drinks in schools" and "to initiate measures to discourage the availability of fast food, unhygienic food and foods with unhealthy ingredients within 500 yards of schools". South Africa's finance minister announced consideration of a SSB tax when announcing overall fiscal measures in late February, with anticipated introduction of the tax proposal in April 2016.6 s The So uth African Department of Health has denied that one of their senior officials has suggested that the country has no choice but to introduce a sugar tax. A spokesman from the Department of Health said "We're not necessarily concentrating on one thing. You cannot deal with the bulk of communicable diseases and only deal with one thing like sugar. You need to deal with all the risk factors."6 4 According to a research institute at the University of Witwatersand's School of Public Health, a 20% tax on sugar sweetened beverages could bring in an estimated R7-billion ($440 million) a year. Additionally, the research suggests that inaction over the growing intake of sugary drinks could lead to the rise of an additional 1.2- million obese South Africans by 20i7.6 s The CSPTs report Carbonating the World has stated that whilst companies such as TCCC and PepsiCo make public pledges not to market to children, these pledges contain loopholes. For example the report shows Coca-Cola signage on school entrances in South Africa and Ghana.66 5 8 https://siteS.gOOgle.com/site/gStbharatCOin/prOpOSal-Of-4O-gSt-On-aerated-drinkS-tobaCCO-COUld-SeVerely-hk 59 http://timesofindia.indiatimes.com/india/Mo 60 https://sites.google.com/site/gstbharatcoin/proposal-of-40-gst-on-aerated-drinks-tobacco-could-severely-hit-both-sectors 61 http://www.busiuess-staudard.com/article/compauies/siu-tax-ou-aerated-driuks-stumps-mauufacturers-11rs120rsoo8aa l.html 62 http://www.thehealthsite.com/uews/oue-iu-200-deaths-iu-iudia-are-due-to-sugar-sweeteued-beverages/ 6 3 http://wvvw.parl.gc.ca/coutent/sen/comn1ittee/421/SOCI/Reports/2016-02-2rs Revised report Obesity in Canada e.pdf 6 4http://v\rww.health24.com/Diet-and-nutrition/News/is-a-sugar-tax-really-on-the-cards-for-sa-20i6oi2i 6 s http://mg.co.za/article/2016-02-04-tax-on-soft-drinks-could-benefit-obese-sa 66 http://cspinet.org/new/2016020Qi.html Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Across the Middle East, Eurasia and Africa manufacturers are adopting voluntary fact based FOP labeling schemes, there is evidence of this occurring in Georgia, Uzbekistan, Azerbaijan, Kyrgyzstan, Kazakhstan, Tajikistan, Armenia, Turkmenistan, Bahrain, Oman, Iraq, Iran, Jordan, Lebanon, Qatar, Saudi Arabia, Syria, UAE, Belarus, Ukraine, China, Turkey, Egypt, Morocco, and Mozambique.6 ? Turkey plans to ban the sale of foodstuffs containing sugar at schools after a successful ban on sugary drinks. A company from Is rae 1 has been pioneering a low sugar innovation.68 DouxMatok's has launched a flavor delivery particle which can cut the amount of sugar needed by half without affecting taste, and is cheaper than sugar. A carrier particle is coated with sugar molecules using non-covalent bonding. This increases the surface area meaning the same sweetness can be achieved using less sugar. The carrier particle has been approved for use in food and beverage applications and requires no regulatory process. LNCS South Africa's MoH proposed revisions to South African food labeling regulations in 2014. If implemented, the new regulations would not allow for any claims on any products containing LNCS. In India a recent study from the Department of Food Science and Nutrition, investigated the Nutritional Composition of Stevia rebaudiana and its Hypoglycaemic and Hypolipidaemic Effect on Patients with Non-Insulin Dependent Diabetes Mellitus.6 9 The authors conclude that "Stevia can safely be used as an antidiabetic herb, as a sweetener substitute and may help to prevent cardiovascular diseases in patients with long standing Diabetes". Asia Pacific Australia has developed a 5-Star Rating food labeling system with a nutrient component for constituents including sugars. The labeling system currently is voluntary. Beverages are using an energy (kJ) tablet without the star ranking. In primary schools in NSW, they have adopted a color coded system denoting foods high in fat, sugar or salt. Some local Councils are calling on sporting centres and clubs to review food which is offered at its sport and recreation facilities. New Ze alan d had indicated it will implement a similar 5-Star Rating system to Australia. There has also been a suggestion from the Labor party that it would support a FOP label based around the number of teaspoons of sugar in a product. The Children's Code for Advertising Food 2010 defines the age of a child as under 14 and determines that food advertisements should not undermine the food and nutrition policies of the New Zealand Government. Campaigners in favor of a sugar tax have been using the results of the BMJ research into the impacts of Mexico's SSB tax to argue their case for similar legislation. Marlborough District Council and Nelson City Council have banned sugar-added beverages sold at their buildings and events. 67 Coca-Cola FOP Tracker 2014 68 http://www.nutraingredients.com/Suppliers2/Flav0ur-delivery-particle-can-cut-sugar-by-half-and-i 69 http://www.ncbi.nlm.nih.gov/pubmed/26781312 Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

In Indonesia, a government proposal remains pending for a warning statement on labels of specific product categories, including SSBs, containing sugar, fat or sodium: "Consumption of sugar >50g, sodium >2000mg, and fat >67g per person per day contributes to the risk of hypertension, stroke, diabetes and heart attack." The proposal was issued in 2013 and has not yet been implemented by the MoH. The MoH has been asked to consider whether sugar drinks constitute a health threat as part of the early stages of exploring a potential tax on beverages sweetened with sugar. According to the ministry's customs and excise office any changes would not take place until 2016, and a tax rate has yet to be proposed.?0 In Taiwan foods where added sugars make up over ten percent of the total calorie count cannot target advertising to children under the age of 12, starting January 2016.?x In Sin gapo re a refreshed Healthier Choice Symbol (HCS), based on revised nutrient guidelines, took effect from September 2015. Existing products with the current HCS logo will have to be depleted by 1 January 2018. Products carrying the current HCS will need to re-apply to carry the revised symbol. In Thailand there are ongoing discussions between the FDA, Nutrition Institute and Choices International with a view to use the Healthier Choices interpretive symbol. It is now apparent that the Thai FDA plan to launch voluntary FOP Better Nutrient Symbol labeling without GDA monochrome fact￾based information for some food products. This will be based on nutritional profile criteria i.e. beverage total sugar should be <6%. Thailand notified WTO on new regulations in January 2016. In addition, the Thai government is reportedly considering a range of sugar reduction policies. These include measures to regulate the advertising of soft drinks and action to curb extravagant soft drink promotions. There is a great deal of concern surrounding Thailand's soaring sugar consumption, and official figures suggest that Thai's consume on average twice the recommended amount of sugar according to the WHO. In the Philippines, where a fact based mandatory FOP scheme is already in place, the House of Representatives approved a bill seeking to impose excise tax on sugar-sweetened beverages like soda and energy drinks. The bill is yet to be passed but would result in a charge of P10 ($0.22) for every liter of sugary drinks. The Department of Health has openly supported the tax.?2 The Beverage Industry Association of the Philippines (BIAP), the umbrella organization of firms engaged in the manufacture, distribution, marketing and selling of beverages in the country, has reacted to the proposed tax by labeling it counterproductive.73 Some private and public schools in Bacolod City, have implemented the banning of junk food and soft drinks, as well as other sugar￾laden drinks, to kindergarten and elementary students. French Polynesia introduced local and import taxes on all sugar-sweetened drinks, confectionaries and ice-cream in 2002. These are not intended to change behavior and as such the levels of tax are relatively low. In 2007, Nauru introduced a 30% tax on all high sugary foods and drinks with the dual aim to reduce consumption and to raise revenue. The impacts of this tax have not been properly evaluated. 7° http://www.nacsonline.eom/News/Daily/Pages/NDiiaoiSi.aspx#.VsMRiyvbpmM 7 1 http://wWW.asianSCientist.com/20l6/0l/t0pneWS/taiwan-ban-jUnk-f00d-marketing-kids/ 7 2 http://wWW.rappler.com/bUSineSS/2il-gOVernanCe/Q68Ql-SOftdrink-taX-burden-ph-COnSUmerS 73 http://wWW.rappler.COm/bUSineSS/2il-gOVernanCe/Q68Ql-SOftdrink-taX-burden-ph-COnSUmerS Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Fiji introduced and then removed different taxes on SSBs; recent efforts to increase excise duties on higher-sugar SSBs have not been successful. The country also has a Health Promoting Schools (HPS) program which trains and supports staff to develop healthy food environments and promote physical activity. In 2013, both the Cook Islands and Tonga introduced new duties on SSBs for health reasons, with Tonga using an excise duty of 1 Pa'anga ($0.45) per liter and the Cooks announcing their import duty would increase annually "to maintain the real value of the levy".74 In Samoa soft drinks, both imported and locally produced, have been taxed since 1984. In 2008 the rate was increased to 0.4 (around $0.17) Samoan Tala per liter.75 The director of education suggested that passing a law stopping the sale of junk food within 200 feet of school campuses would promote healthier eating habits to reduce the numbers of non-communicable diseases.?6 In South Korea, TV advertising to children under 18 years of age is prohibited for specific categories of food before, during and after programs shown between 5~7pm and during other children's programs. The Government of China and the Health Education and Health Promotion Unit of WHO have collaborated to establish Health-Promoting Schools (HPS). Voluntary schemes are also prevalent in Jap an, where there is a specification that each meal for primary schoolchildren, or those aged six to 12, must contain approximately 650 calories. LNCS Australia has had a continued push by NGOs saying LNCS are not safe. Regulators at this stage are satisfied as to their safety. Australia and New Zealand have approved the use of Steviol glycoside Reb M and products containing Reb M can now be introduced to the market. Indonesia requires a warning statement for the use of artificial sweeteners required on the label: "Contains artificial sweetener, not recommended to be consumed by kids below 5 years, lactating and pregnant women." Currently the MOH is conducting a Total Diet Study that includes an exposure assessment on LNCS. The MOH will evaluate the regulation related with LNCS based on the result of the study. 74 http://www.fizz. org.nz/sites/fizz.org.nz/files/7%2oSugar%2oSweetened%2oBeverages%2oin%2oPacific%20lsland%2oCountries%20and%2oTerritories.pdf 75 http://www.wcrf.org/int/policy/nourishing-framework/use-economic-tools 7 6 http://www.radionz.co.nz/international/pacific-news/2Q02Q.s/push-in-american-samoa-for-iunk-free-schools Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

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Global Food Manufacturer Competitive Landscape General Mills" In 2009, General Mills (GMI) pledged to reduce sugar in all of its cereals advertised to children under 12 to single-digit grams of sugar per serving. While GMI claims to have made "significant progress", no specific information is given. Examples of progress in individual products are shared in some instances; e.g., reducing the sugar in their Yoplait kids yoghurt by 21% since 2007.?8 General Mills has made the following commitments around marketing to children?0 : o Unless a product meets the US Children's Food and Beverage Advertising Initiative Nutrition Standards, the product must not be marketed to children under 12. o Regardless of the nutrition profile of the product, General Mills does not directly advertise food or beverage products in schools o Regardless of the nutrition profile of the product, General Mills will not engage in any product advertising on programming or media primarily directed to children under six years of age. In June 2015, GMI committed to removing aspartame from Yoplait Light, replacing it with sucralose. Little justification was given around this move other than on a blog post which suggests it was a result of customer requests.80 Grupo Bimbosl Grupo Bimbo states that their "greatest concern is the health of individuals". Nutrition is integrated in the company's corporate strategy; they have identified a comprehensive set of nutrition objectives and defined managerial accountability. Grupo Bimbo sets out their support for global nutritional recommendations by the WHO and United Nations Food and Agriculture Organization (FAO). In its Manifesto Grupo Bimbo in Health and Wellness82 the company outlines their actions to improve the nutritional profile of their product portfolio by reducing nutrients with a negative impact on public health, including sugar. Grupo Bimbo sets out a quantitative reduction target: the reduction of sugars by 10% in the categories of cookies, cakes, and pastries by 2020. The Access to Nutrition Index8 s (ATNI) has commented that Grupo Bimbo could improve their position by expanding these targets to their entire portfolio, as opposed to focusing only on specific product categories. Substantial emphasis is placed upon product reformulation as a way to achieve sugar reduction. Grupo Bimbo has developed an internal Nutrient Profiling System (NPS) to guide product reformulation. The NPS is aligned with international dietary guidelines. In their Summary Integrated Annual Report8 ^ Group Bimbo declared that product reformulations eliminated 3,061 tons of sugars across 100 products. 77 https://www.generalmills.com/Health/improvlng-health/reducing-sugar 7 8 https://www.generalmills.com/Health/improving-health/reducing-sugar 79 https://www.generalmills.com/en/Responsibility/marketing-advertising 80 http://www.blog.generalmills.eom/2014/06/removing-aspartame-from-yoplait-light/#sthash.ORPwSoSP.dpuf 81 http: //www.grupobimbo.com/en/index.html 82 http://www.nutriciongrupobimbo.com/assets/docs/bimbo-manifiesto-ingies.pdf 8 3https:/Vw\vw.accesstonutrition.org/index/2Q 1.7/company/grupo bimbo/pdf/atnindex.20irs.scorecard.grupo bimbo.20160214.061726.pdf 8 4http://wT/V^^giTipobimboxom/assets/files/inversionistas/20i4/Resumen INGLES.pdf Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Neither sweetness nor LNCS are mentioned in their Manifesto. However, in their Integrated Annual Report they reference their formal launch of "better for you" and "functional" products as category extensions; which include stevia-sweetened products. Grupo Bimbo has set out in detail their company pledge via their Responsible Marketing to Children Initiative. This includes: Advertising and Messaging; Use of Licensed and Owned Characters; Product Placement; Use of Products; Advertising in Schools and Promotions. Grupo Bimbo follows the above principles and its commitments as a member of the International Food and Beverage Alliance (IFBA). The ATNI comments that the scope of applicability trails almost all companies with an articulated policy on responsible marketing to children. Grupo Bimbo also places emphasis on FOP labelling. Their commitments include: o Incorporate at least a minimum amount of nutritional information on GB projects detailing the content of nutrients most critical to public health in each portion (energy content, total carbohydrates, sugars, proteins, fats, saturated fats, sodium and any nutrient about which some benefit is being claimed) o Continue to fully abide by all laws and regulations regarding labeling in the countries where Grupo Bimbo products are sold. o Where there are no applicable regulations in force, Grupo Bimbo will abide by international regulations (Codex) or by the best practices of the many countries where they operate. o Incorporate other information in addition to basic nutritional data, in simple and easy to-understand FOP labeling. o Have labels include a recommendation that consumers practice at least 30 minutes of physical activity a day, as part of the promotion of healthy lifestyles. Kellogg's Following speculation about a UK government sugar tax, the Kellogg Company joined other companies in announcing that it would reduce the sugar content of their products. Kellogg's committed to cutting 723 tons of sugar in 2016 from all its cereals such as Frosties and Coco Pops. Kellogg's adopts a defensive stance regarding the amount of sugar in their products (most likely due to the criticism consistently levied at breakfast cereal)8 5. Kellogg's asserts that sugar in cereals — including 'kids' cereals —contribute less than 5 percent of daily sugar intake. They com pare the amount of sugar found in examples of their cereals with that found in orange juice and yogurt.86 Kellogg's does outline a sugar reduction commitment: "we are committed to slowly reducing sugar over time while keeping the great taste and quality" expected by consumers. Kellogg's has already made some progress on sugar and have reduced sugar in many of their cereal and snack recipes. They give the example of Kellogg's Bran Flakes which, from January 2016, will contain 30% less sugar than similar flake based breakfast cereals.8 ? One serving of the old Kellogg's Bran Flakes recipe provided 1.5 teaspoons of sugar; from January, Kellogg's Bran Flakes will provide, like Kellogg's Special K Original, only 1 teaspoon of sugar per serving. Further, they outline a commitment to reducing sugar further across all of their range, and to provide consistent updates on their progress. However, they state that sugar is integral to the overall taste and texture of a cereal, whilst can additionally serve to encourage the consumption of essential minerals like fiber, vitamins, and minerals. 8 s http://www.telegraph.co.uk/news/shopping-and-TO 86 http://www.kelloggs.com/en_US/the-benefits-of-cereal/Putting-Sugar-in-Perspective.html 87 http://www.kelloggs.co.uk/en_GB/nutritioni/the-benefits-of-cereal/sugar-and-breakfast-cereal.html Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Kellogg's claims to help consumers see exactly how much sugar is in each serving by clearly labelling the front of each Kellogg's breakfast cereal pack. Each pack also has a nutrition panel in which it is possible to see how much sugar is in the food per serving and per too g. They have however, been subject to criticism for failing to sign up to certain specific national standardised FOP labelling schemes, for example in the UK88 and in Australia.89 Mars90' 91' 92: In May 2015, Mars publically stated their support of WHO's recommendations to reduce intake of added sugars to no more than 10% of total calories. In order to support consumer's to achieve this, they declared full support for a US FDA's proposal to include declaration of added sugars in the Nutrition Facts panel. Other steps that Mars have taken to help customers achieve nutritional goals include: o Having Guideline Daily Amount (GDA) labeling on all chocolate, food, and sugar confectionery products o Limiting all confectionery products to no more than 250 kcal per serving. They have also made a commitment going forward to increase the number of chocolate confections below 200 kcal per pack o Offering sugar-free and low-sugar Wrigley gum and doing more to promote the oral health benefits of sugar-free gum o Adhering to a strict Marketing Code that does not allow marketing communications to children under 12 for food, chocolate, confections, and gum products Mondelez International In 2014, Mondelez unveiled its Call for Well-being strategy in response to the WHO's goals to reduce salt and saturated fat consumption and better manage calorie and sugar intake.^ Mondelez's call for well-being comprises eight targets. Some of these fall under their pillar of "mindful snacking." This includes a commitment to FOP calorie labels on all products globally by 2016 and a 10% sodium and saturated fat reduction by 2020. However, there is no mention of reformulating products to contain less sugar, or sugar reduction targets. Instead, Mondelez has puts emphasis on education of consumers to make healthier choices and aims to manage consumption via portion control. Its other pledges include: o increasing individually wrapped options of 200 calories or less by 25% by 2020 o aiming for its "Better Choice" products to account for a quarter of revenues by 2020. There is a brief mention of sugar on the Mondelez website under "well-being" and "empower through our portfolio." Mondelez recognizes an increasing interest on sugar consumption and its impact on weight gain and other health considerations. They state they are best positioned to help people reduce sugar consumption through efforts to reduce calories and offer portion control options. Further, that reducing sugar without reducing 88 http://www.marketingmagazine.co.uk/article/1186752/pepsico-tesco-sign-label-scheme-kelloggs-stays-a 8 9 http://wWW.thegUardian.COm/aUStralia-neWS/2Oi5/mar/i7/kellOggS-mCCain-Criticised-nOt-signing-Up-h 9° http://www.mars.com/global/press-center/press-list/news-releases.aspx?SiteId=Q4&Id=6576 9 1 http://www.nbcnews.com/news/us-news/mars-inc-candy-maker-supports-sugar-intake-limits-n356086 9 2 http://fortune.com/2015/05/08/mars-backs-labels-for-added-sugar/ 93 http://www.confectionerynews.com/Manufacturers/No-sugar-reduction-in-Mondelez-health-and-wellness-pledge Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

calories is not a benefit when it comes to reducing the risk of obesity. Over the years, they have introduced products with less sugar and calories, as well as a number of sugar free options. Mondelez has committed to FOP calorie labelling on products globally by 2016. By 2014, Mondelez estimated 46% of portfolio featured FOP calorie labeling94 Unlike most food and beverage companies, and retailers, Mondelez International did not sign up to the UK's voluntary color-coded FOP scheme in 2013. Mondelez has extensive information about nutrition on their website, including a Nutrition Corner, and a downloadable version of their Nutrition Criteria. In 2005, Mondelez announced global policies for advertising to children. In 2014, they took addition steps to strengthen their Marketing to Children Policy. As of January 1, 2016, Mondelez will not advertise their products in any media primarily directed to children under age 12, irrespective of the product's nutritional profile. Nestle9596: In their policy on sugar, Nestle commits to continue reducing the level of sugars in its food and beverage products. They seek to help consumers (with a specific focus on children) achieve WHO's sugar recommendations and other leading international and national authorities. They have made the following commitments around the presence and labeling of sugar in their products97: o By 2014 - 100% of children's products to meet Nestle Nutritional Foundation criteria98 (based on nutrition science and dietary recommendations, such as those published by the WHO and the Institute of Medicine) o By 2015 - Reduce sugar content to 9g or less per serving in children's/teenagers' breakfast cereal brands. By the end of 2014, 98% of children's products met the Nestle Nutritional Foundation sugars criteria. o By 2016 -further reduce sugar content by 10% in products that do not meet the Nestle Nutritional Foundation criteria, to ensure continual improvement even in more challenging areas of the product portfolio. o By 2016 - the introduction of GDA-based labeling, using children's reference values, for all products designed for children to help parents make better nutritional choices for children. o By 2016 - Make information more accessible by providing further product information and nutrition advice on pack, via Quick Response (QR) codes for smartphones. Nestle uses its Nutritional Profiling System to evaluate the nutritional value of its food and beverage products. The system is based on nutrition science and public health recommendations issued by authorities such as the World Health Organization.99 For each of its product categories, Nestle has established criteria for energy and five health-sensitive nutritional factors including added sugar, fructose, sodium, trans fatty acids, and saturated fatty acids. 94http://www.mondelezinternational.co 95 http://www.nestle.com/csv/nutrition/sugar-reduction http://www.nestle.com/asset-library/documents/library/documents/about_us/nestle-policy-sugars.pdf 9 6 http://www.nestle.com/csv/nutrition/sugar-reduction 97 http://www.nestle.com/asset-library/documents/library/documents/corporate social responsibility/nestle-in-society-summary-report-2014-en.pdf 9 8 http://www.nestle.com/csv/nutrition/nutritious-products-children 99 http://www.nestle.com/nutrition-health-wellness/improving-products/nutrition-pleasure Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Nestle's Marketing to Children Policy states that they do not direct marketing communication to children under six. As of December 2015, direct marketing communication to children 6 to 12 years of age can only be with products that achieve EU Pledge Nutrition Criteria or meet Nestle Nutritional Foundation status.100 PepsiCo101 PepsiCo's headline target on sugar is to reduce the average amount of added sugars per serving in key global beverage brands, in key countries, by 25 percent by 2020, against a 2006 baseline. They report to be commitment to bringing balance to their beverage portfolio by increasing the options for low or zero calorie drinks and offering products in small portion sizes with clear calorie labelling.102 Their Global Labeling Pobcy103 is currently being rolled out and is expected to be fully implemented by the end of 2016. It stipulates that at a minimum they will provide the following information: o Products will provide on the side or back of packaging nutrition information on the amount of energy (as calories, kilocalories or kilojoules), protein, carbohydrate, total sugars, total fat, saturated fat and sodium per toog/ml or per serving. Additionally, the inclusion of nutrition information for nutrients for which a health or nutrition claim is made. o Products will include information on energy (as calories, kilocalories or kilojoules) per toog/ml or per serving FOP in all countries. PepsiCo also adopted a global company policy that is consistent with International Food and Beverage Alliance's policy on advertising to children. This policy includes commitments to104: o Not buy advertising in programs with an audience profile greater than 35 percent of children under 12 years of age. This now includes outdoor, interactive games, cinema and product placement. o Marketing techniques such as licensed characters, movie tie-ins and celebrities will not be used for marketing with an audience profile greater than 35 percent of children under 12 years of age In PepsiCo's Global Policy on the sale of beverages to schools10s they state 'While it is the schools which must ultimately decide which beverages should be available to students, and where and when they should be sold, PepsiCo hopes to play a role in shaping an environment in schools which facilitates healthy choices for school-age children everywhere.' This policy applies for schools outside the USA. In April 2015, PepsiCo began removing aspartame from Diet Pepsi in the US claiming that the decision was a commercial one and that they were responding to customer preference100 . The aspartame was replaced with sucralose. In their facts about their beverages section PepsiCo have a specific LNCS tab where information on specific sweeteners is available along with frequently asked questions.10? 100 http://www.nestle.com/csv/nutrition/advertising-marketing 101 https://www.pepsicobeveragefacts.com/home/sweeteners 102 http://www.pepsico.com/Purpose/Human-Sustainability/Product-Choices 1Q3http://www.pepsico.com/docs/album/policies-doc/pwp/pepsico global labeling policy OQi6i4.pdf?sfVrsn=2 1Q4 http://www.pepsico.com/docs/album/policies-doc/pwp/pepsico policy responsible.pdf?sfvrsn=2 1Qs http://www.pepsico.com/docs/album/policies-doc/pwp/pepsico global policy on the sale of beverages to schools.pdf?sfVrsn=2 106 http://www.bbc.co.uk/news/health-a247820a 1Q7 https://www.pepsicobeveragefacts.com/home/sweeteners Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

Unilever108 Unilever recognizes that energy intake from sugar should be limited in line with recommendations by a number of organizations, such as WHO and the American Heart Association. Unilever has set the following targets around sugar to assist consumers improve nutrition109: o By 2020, to remove an additional 25% sugar in ready-to-drink teas, powdered ice tea, and milk tea products. In 2014, they had achieved a 12% sugar reduction across all sweetened tea-based drinks. o By 2014,100% of children's ice creams will contain 110 kilocalories or less per portion. 60% met this level by 2012. This 2014 target was achieved. o By 2015, 80% of Unilever's packaged ice cream products will not exceed 250 kilocalories per portion. In 2014 they had exceeded this target with 90% of packaged ice-cream by volume contains 250 kilocalories or less per portion. o By 2015, the inclusion of energy per portion FOP plus eight key nutrients and % Guideline Daily Amounts (GDA) for five nutrients on the back of pack of all products globally. In 2104 65% of Unilever's global portfolio had achieved this standard. Unilever made a commitment to restrict marketing and advertising to children from the ages of six to under 12 for all products except those that meet Unilever's nutrition criteria110 , any common industry criteria committed to by Unilever, and any binding criteria set by public authorities.111 Unilever also recognizes the fact that consumers are cautious about the use of non-nutritive sweeteners, and states their intent to encourage "balanced debate" about this issue. They posit stevia as a potential solution. 108 https://www.unilever.com/sustainable-living/what-matters-to-you/reducing-sugar-in-ready-to-drink-tea 1Q9 https://www.unilever.com/sustainable-living/the-sustainable-living-plan/improving-health-and-well-being/improving-nutrition/ 110 https://www.unilever.com/Images/slp unilever-nutrition-criteria-november-2013 tcm244-4i44QQ 1 en.pdf 111 https://www.unilever.com/sustainable-living/what-matters-to-you/advertising-and-marketing.html Source: https://www.industrydocuments.ucsf.edu/docs/ylcl0226

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