Document 9
(SANTE)
From:
AIPCE <xxxxx@xxxxxxxxxxxxx.xxx>
Sent:
vendredi 20 décembre 2019 12:20
To:
(SANTE)
Cc:
(SANTE)
Subject:
AIPCE-CEP concerns regarding Nutri-Score ratings for fishery products
Attachments:
20191220 AIPCE-CEP letter regarding Nutri-Score.pdf
Dear
Please find attached a letter on behalf of AIPCE-CEP (EU Fish Processors and Traders Association) on Nutri-score
ratings for fishery products.
I hope we will be able to discuss soon in person about this important issue for the sector.
For the time being, I wish you a very happy Christmas and a successful 2020.
Kind regards,
DVM
AIPCE-CEP
EU Fish Processors and Traders
Association
Avenue de Tervueren 188A,
1150 - Brussels - Belgium
Tel:
Mobile :
Fax: +32 (0)2 761 16 99
xxxxx@xxxxxxxxxxxxx.xxx
1
EU Fish Processors and Traders Association
Brussels, 20 December 2019
Ref. 166/2019
To the kind attention of:
Director DG SANTE Directorate E - Food and feed safety, innovation
CC
Head of Unit E1- Food information and composition, food waste - DG SANTE
Subject: AIPCE-CEP1 concerns regarding Nutri-Score ratings for fishery products
Dear Dr
AIPCE-CEP would like to address its concerns regarding the voluntary nutrition labelling
scheme “Nutri-Score” in relation to processed fish products (canned, smoked, frozen,
marinated, etc.), as we consider that the Nutri-Score ratings for these products are not
consistent with the nutritional recommendations2.
Specifically, the Nutri-Score system, in its current formulation,
does not take into account
the nutritional qualities of the proteins and the long-chain omega 3s of marine origin.
Fish products constitute the
vast majority of the EU consumers’ intake of
long-chain omega
3s EPA and DHA3
. Despite this,
products
such as canned sardines and mackerel have very
poor ratings in the Nutri-Score system, oscillating between “C” and “D”.
The
health and nutritional benefits of eating fatty fish are scientifically proven and the low
ratings for these products stand in contradiction with the very purpose of the Nutri-Score
1 AIPCE (EU Fish Processors and Traders Association) and CEP (European Federation of National Organizations of Importers
and Exporters of Fish) were established in 1959 and collaborate on the basis of a Co-operation Agreement, creating AIPCE-
CEP.
The association represents 20 EU National Associations and 2 Associations in Third countries, for a total of nearly 3,500
companies, the majority of which with 20 employees at most, for total employment of around 120,000 persons. The overall
value of the output of the industry represented by AIPCE-CEP amounts to around EUR 27 billion, or three times the
turnover of the catch sector.
2 Food Security Agencies
recommend eating fish twice a week, including once fatty fish (sardines, mackerel, anchovies,
herring, salmon, etc.).
3 according to the ANSES,
the 75% of total intake of omega 3s EPA and DHA derive from the consumption of these
products (for more information see: AVIS ANSES « Apports en acides gras de la population vivant en France. Comparaison
aux
apports
nutritionnels
conseillés
définis
en
2010
»
22
septembre
2015 ;
https://www.anses.fr/fr/system/files/NUT2014sa0117Ra.pdf
labelling scheme, which should serve as valuable and simple tool to help EU consumers to
make healthier choices.
As support for Nutri-Score system is fast spreading across the EU4, we call upon the relevant
Member States and EU authorities to
examine urgently the specific case of processed fish
products, in order to provide the
necessary corrections to modify the calculation that
underlies Nutri-Score, thereby taking into account the nutritional benefits of eating fish
products.
We would like to request a meeting to provide more details and explain our concerns.
Thank you for your attention.
Kind regards,
, AIPCE President
CEP President
4 E.g. the official Citizens initiative to make Nutri-Score mandatory in the EU
(https://ec.europa.eu/citizens-
initiative/public/initiatives/ongoing/details/2019/000008), while Member States (namely France, Belgium, Spain,
Germany and The Netherlands) have already adopted or endorsed Nutri-Score as voluntary nutrition labelling scheme in
their country.
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