Which nutrition information is mandatory on food labels?
As from December 2016, Regulation (EU) No 1169/2011 requires the vast majority of pre-packed foods to bear a nutrition declaration. It must provide the energy value and the amounts of fat, saturates, carbohydrate, sugars, protein and salt of the food. The declaration must be presented in a legible tabular format on the packaging. Where space does not permit it, the information may be presented in linear format. This mandatory nutrition declaration is often provided on the back of food packaging.
The content of the mandatory nutrition declaration may be supplemented voluntarily with the indication of the amounts of mono-unsaturates, polyunsaturates, polyols, starch, fibre, vitamins and minerals. This voluntary information must not be displayed to the detriment of space allocated to mandatory information.
All the information must be expressed per 100g or per 100ml. It may also, in addition, be expressed per portion or per consumption unit of the product.
GUIDANCE ON NUTRITION LABELLING
COMMISSION NOTICE on Questions and Answers on the application of the Regulation (EU) No 1169/2011 – Section 3 concerns nutrition declaration.
Guidance documentfor competent authorities, tolerances for the control of compliance of nutrient values declared on a label with EU legislation
A simplified summary table gives an overview of the different tolerance values included in the guidance document. In case of doubt the guidance document text should be consulted as the official reference
Guidance document for competent authorities, methods of analysis for the determination of the fibre content declared on a label for the control of compliance with EU legislation
What is front-of-pack nutrition labelling?
Front-of-pack nutrition labelling is simplified nutrition information provided on the front of food packaging aiming to help consumers with their food choices. Under the current EU rules, the indication of nutrition information on the front-of-pack is not mandatory but could be provided on a voluntary basis.
EXCHANGE OF INFORMATION BETWEEN MEMBER STATES, STAKEHOLDERS AND THE COMMISSION
Article 35 of Regulation (EU) No 1169/2011 requires the Commission to facilitate and organise the exchange of information between Member States, itself and stakeholders on matters relating to the use of additional forms of expression or presentation of the nutrition declaration ("front-of-pack nutrition labelling").
To that end, the Commission organised joint meetings on the topic between Member States and EU-level stakeholder organisations, i.e. members of the Advisory Group on the Food Chain, Animal and Plant Health and interested EU-level stakeholder organisations of the EU Platform for Action on Diet, Physical activity and Health.
All relevant documents such as agendas, presentations and minutes are publicly available:
Report on front-of-pack nutrition labelling
Article 35 of Regulation (EU) No 1169/2011 requires the Commission to adopt a report on the use of additional forms of expression and presentation of the nutrition declaration, their effect on the internal market, and the advisability of further harmonisation in this field.
On 20 May 2020, the Commission adopted the Report to the European Parliament and the Council regarding the use of additional forms of expression and presentation of the nutrition declaration.
Questions and Answers
Why this report (now)?
Regulation (EU) No 1169/2011 on the provision of food information to consumers does not harmonise the presentation formats (e.g. graphical forms or symbols) for repeating nutrition information on the front-of-pack. Given the absence of a front-of-pack nutritional scheme that would be understandable and acceptable for all consumers at the moment of the adoption of the Regulation in 2011, it was decided to leave this matter to Member States and food business operators to develop their own schemes, adapted to their consumers, provided they comply with certain criteria.
In the light of the experiences gained with these schemes, it was also decided that the Commission should submit a Report by December 2017 on their use and impact (Article 35 of Regulation (EU) No 1169/2011).
Considering the limited experience in the area of front-of-pack nutrition labelling in the past years and recent developments at national level, the adoption of the Report was postponed with a view to including the experience with recently introduced schemes. The Report was adopted by the Commission on 20 May 2020.
What is the content of the report ?
The Report presents the main front-of-pack nutrition labelling schemes currently implemented or being developed at EU level, as well as some of the schemes implemented at international level. The report looks into consumer understanding and impacts of the schemes, including on purchasing behaviour, food reformulation and the internal market. It also addresses the positions of Member States and stakeholders and the question of possible EU harmonisation. The Report builds upon literature reviews and data gathered and analysed by the Joint Research Centre and extensive consultation carried out by the Commission with national competent authorities and relevant stakeholders.
How many front-of-pack schemes have been developed or endorsed within the EU?
There are currently six front-of-pack schemes developed or endorsed by the public sector which are present on the EU market: the Keyhole logo (used in Sweden, Denmark, Lithuania), the Nutri-Score (used in France and Belgium and future implementation announced by Germany, Spain, the Netherlands and Luxembourg), the Finnish Heart Symbol, the Slovenian 'Little Heart' logo, the Croatian 'Healthy Living' logo and the Traffic Light scheme which is also present on the Irish market. Italy has developed a scheme called NutrInform Battery, which has not been implemented yet.
Besides public schemes, some private schemes are present on the EU market such as the Reference Intakes Label or the Healthy Choice logo.
Does the Report conclude on which front-of-pack label works the best?
The Commission’s Report provides an overview of the main findings of a literature review carried out by the Joint Research Centre concerning the effects and potential impacts of front-of-pack schemes. The studies reviewed confirm the potential of front-of-pack schemes to help consumers make health-conscious food choices. The literature review further suggests that evaluative schemes that use colour-coding, with or without a graded indicator, appear most promising in improving the nutritional quality of food choices.
Does the Commission propose to harmonise front-of-pack nutrition labelling across the EU? Does the Commission propose any specific front-of-pack scheme?
In the Report, the Commission concludes that it seems appropriate to introduce a harmonised mandatory front-of-pack nutrition labelling at EU-level.
This conclusion is also reflected in the Farm to Fork Strategy adopted by the Commission on 20 May 2020. As part of the Farm to Fork Strategy, the Commission is proposing actions to empower consumers to make healthy food choices, including the introduction of a mandatory front-of-pack nutrition label.
In its report, the Commission does not recommend any specific type of front-of-pack scheme. As announced in the Farm to Fork Strategy, the related initiative to be launched by the Commission will require further and thorough discussion with all stakeholders and an impact assessment.
What will happen next?
The Commission will soon launch an impact assessment on different options for front-of-pack nutrition labelling.
The impact assessment will take the conclusions of the literature review by the Joint Research Centre and the Report on front-of-pack labelling into account.
As indicated in the Farm to Fork action plan, the Commission intends to adopt a proposal by the end of 2022.
Key findings of the Report
Front-of-pack nutrition labelling is increasingly seen as a tool to support strategies for the prevention of diet-related non-communicable diseases.
Most consumers declare that they find front-of-pack nutrition labels helpful. Older and overweight citizens are more likely to report a need for a front-of-pack label.
A variety of front-of-pack nutrition labels have been developed by public institutions, health NGOs and/or private sector.
Most existing schemes use so-called ‘nutrient profiling criteria’ to evaluate the nutrition information for the consumer (e.g. through colours, grading indicator, symbol).
Front-of-pack schemes have the potential to help consumers make health-conscious food choices. Evaluative schemes that use colour-coding, with or without a graded indicator, appear most promising for improving the healthfulness of consumers' shopping baskets.
Evidence that recommendations from Member States to use a specific front-of-pack scheme may or may not hamper the free circulation of food products, is so far limited and inconclusive.
The use of different front-of-pack schemes in the internal market could result in certain costs for businesses as well as consumer confusion and lack of trust. Many EU Member States and stakeholders therefore favour a common harmonised approach.
Considering the strong link between nutrient profiling and front-of-pack nutrition labelling, there could be possible synergies in reflecting on the two topics together.
Given the political priority of the European Green Deal and the Farm to Fork Strategy to help consumers choose healthy and sustainable diets, the elements outlined in the Report and the potential of front-of-pack schemes to help consumers make health-conscious food choices, it seems appropriate to introduce a harmonised mandatory FOP nutrition labelling at EU-level. The Commission will prepare a legislative proposal.
The Joint Research Centre has provided input to this Report through a literature review of scientific publications concerning the effects of front-of-pack schemes on consumers' understanding, food purchases, diet and health as well as food reformulation and other potential (intended or unintended) effects or impacts of introducing front-of-pack schemes. The review ‘Front-of-pack nutrition labelling schemes: a comprehensive review’ summarises the main findings.