Document 4
From:
(SANTE)
Cc:
(SANTE);
;
FEDIOL Secretariat; SANTE CONSULT-E1
Subject:
Re: Nutrient Profiles and Nutriscore - FEDIOL suggestions for bottled vegetable oils and fat
Date:
lundi 27 janvier 2020 16:22:19
Attachments:
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19NUT329 FEDIOL position on an adapted Nutriscore for vegetable oils and fats - 27 September 2019.pdf
Dear
,
Many thanks for your response.
We can well understand your time constraints.
A phone call on 19/2 11:00-11:30 would also fit us.
We could possibly do it through google meet for exemple, so to show
you some slides for ease. At your best convenience.
In the meantime, we would like to share with you our FEDIOL detailed
suggestions on how to adapt the current Nutriscore for bottled
vegetable oils to align it with existing WHO and national dietary
guidelines and with EU health and nutrition claims. You will find it
attached.
Happy to further discuss it, as well as feedback from national
authorities, during the phone call.
For your information, we have also launched a short FEDIOL
video on
the same topic. It has been released though Euractiv today.
Wish you a good week!
Scientific & Regulatory Affairs
@fediol.eu
+
On Fri, Jan 24, 2020 at 5:03 PM
@ec.europa.eu> wrote:
Dear
Thank you for your message and your suggestion to meet to discuss your views and
suggestions regarding the Nutri-Score classification for vegetable oils and fats.
As mentioned over the phone, in the meantime we have checked internally potential dates but
unfortunately, due to the current urgencies, it will not be possible to set up a meeting in the
short term.
We could suggest to have a phone call with
and myself on 19/2 a.m (11h-11h30) or
on 20/2 a.m (12h-12h30) if this would suit you.
In any case, we can assure you that we have taken good note of the input you have sent us in
December on the Farm to Fork strategy regarding food information to consumers as well as
the FEDIOL assessment of Nutri-Score of April 2019.
Kind regards and wishing you a nice weekend,
European Commission, Health and Food Safety Directorate-General
Policy Officer – Unit E1 Food information and composition, food waste
Rue Breydel 4 – 1040 Brussels
Tel: +32 2
– E-mail:
@ec.europa.eu
From:
<
@fediol.eu>
Sent: Friday, January 10, 2020 12:27 PM
To:
@ec.europa.eu>
Cc:
(SANTE) <
@ec.europa.eu>;
(SANTE)
<
@ec.europa.eu>;
fediol.eu
>; FEDIOL Secretariat <xxxxxx@xxxxxx.xx>
Subject: Nutrient Profiles and Nutriscore - FEDIOL suggestions for bottled vegetable
oils and fat
Dear
,
Following the sharing of our FEDIOL assessment of the
Nutriscore in April 2019, we have further looked into the
Nutriscore, given its uptake in other countries.
Reaching the conclusion that it does not enable a proper
comparison of vegetable oils and fats within their category, we
have developed some suggestions for alignment with existing
EU health and nutrition claims and with WHO and national
dietary guidelines.
We started to discuss them with national authorities end of last
year.
In the context of the upcoming Commission report on nutrient
profiles, the priority for the new Commission set on "improving
consumer information on the health of food products" and the
upcoming Farm to Fork approach, we would like to meet you at
your best convenience to present our suggestions with you and
discuss it further, and more generally on how bottled vegetable
oils and fats could fit in such context.
Many thanks in advance.
Best regards,
Regulatory Affairs
@fediol.eu
+
Ref. Ares(2020)3177170 - 18/06/2020
27 September 2019
Ref. 19NUT329
FEDIOL position
Towards an adapted Nutriscore for bottled vegetable oils and fats
Context
FEDIOL has been engaged in discussions and has followed the developments on nutrient
profiles for many years.
FEDIOL understands the need to introduce a food labelling system such as the Nutriscore
to push consumers to favour rated “healthier” food.
Hence,
FEDIOL can support such initiatives as long as:
1)
it provides meaningful information to consumers;
2)
it enables bottled vegetable oils and fats to get a scoring across the
whole possible range from “A” to “E”;
3)
it enables all food products – including vegetable oils and fats - to
improve their “score”, even if challenging, through reformulation.
FEDIOL has therefore assessed such system in detail1, including the last modifications
introduced in September 20192. For bottled vegetable oils and fats, the scoring is
ranging from “C” to “E”. A detailed explanation is available in Annex I.
FEDIOL welcomes the recent modifications of the Nutriscore3, which recognises positive
effects on health from rapeseed oil, walnut oil and olive oil, by including them in the
positive category “Fruits and vegetables, legumes, nuts, rapeseed oil, walnut oil and
olive oil”4. As a result, olive oil and walnut oil can now bear a “C” scoring, instead of “D”,
whilst for rapeseed oil nothing changes, it stays in category “C”.
Whilst FEDIOL welcomes this approach as a step in the good direction,
it has limited
impact on the differentiation of bottled vegetable oils and fats.
Indeed, it still
classifies all vegetable oils and fats only between “C” and “E”, and none under
“A” or “B”. However, by this change, it will be possible to have a positive impact on a processed
composite food product containing oil/fat by replacing “D” or “E” ranked oils/fats with
“C” ranked vegetable oils and fats and thereby improve its final score.
1 FEDIOL position on Nutriscore, April 2019, 19SAF079.
2 Arrêté du 30 août 2019 modifiant l'arrêté du 31 octobre 2017 fixant la forme de présentation complémentaire à
la déclaration nutritionnelle recommandée par l'Etat en application des articles L. 3232-8 et R. 3232-7 du code de
la santé publique, JORF n°0206 du 5 septembre 2019 texte n° 6.
3 Ibidem footnote 2.
4 By this, olive, rapeseed and walnut oils benefit from 5 additional positive points.
T H E E U V E G E T A BL E O IL A N D P R O T E IN M E A L IN D U S T R Y
168, avenue de Tervuren (bte 12) ● B 1150 Bruxelles ● Tel (32) 2 771 53 30 ● Fax (32) 2 771 38 17 ● Email : xxxxxx@xxxxxx.xx
● ht p:/ www.fediol.eu
Ets n° 0843946520 ● Transparency Register n°85076002321-31
27 September 2019
19NUT329
Why the Nutriscore does not fit bottled vegetable oils and fats in practice
The current Nutriscore does not fit bottled vegetable oils and fats for the following main
reasons:
1) It does not offer consumers a better bottled vegetable oil/fat alternative
than “C”.
Despite the positive points, the system does not enable to re-balance the other negative
components. Vegetable oils will hence fall in categories “C” (light orange), “D” (orange)
or “E” (dark orange), but never in the green
categories “A” or “B”.
Therefore, the existing Nutriscore system does not enable to sufficiently
differentiate botted vegetable oils and fats within the entire category and
across the sub-categories defined by the current scoring.
2) It suggests to eat “less frequently” vegetable oils and fats rated “C” or
“D”, which should be on the contrary favored according to WHO and
national nutrition guidelines.
WHO recommends replacing butter, lard and ghee with oils rich in polyunsaturated fats,
such as canola (rapeseed), sunflower, soybean, corn and safflower oils to lower the risk
of developing non-communicable diseases5.
It further contradicts what WHO considers as core/basic products6 whereby vegetable
oils and fats are
recommended to be consumed as part of a healthy diet in most national
nutrition guidelines.
And hence, it is not in line with national nutrition guidelines such as in France7, which
recommend to favour olive, rapeseed and walnut oils, whilst a “C” or “D” Nutriscore
means that such vegetable oils are to be eaten “less frequently”.
3) It does not create a suitable environment for consumers to favour
polyunsaturated fat content in the diet.
Polyunsaturated fats (PUFA) are recognised for having proven benefits in a healthy diet.
They can come from different sources,
one of the main contributors in several
countries is vegetable oils and fats high in PUFA. This is why they are
recommended by national nutrition guidelines in the context of a healthy diet.
Ranking as “C” or “D” known vegetable oils high in PUFA as defined under EU health
claim8 will not result in consumers favouring a vegetable oil high in PUFA over another
one.
4) It creates a
discrimination for bottled vegetable oils and fats vs. vegetable
oils and fats used as an ingredient in processed food products.
5
WHO factsheet on healthy diet, updated October 2018. https://www.who.int/news-room/fact-
sheets/detail/healthy-diet
6 Kelly B and Jewell J. What is the evidence on the policy specifications, development processes and effectiveness
of existing front-of-pack food labelling policies in the WHO European Region? Copenhagen: WHO Regional Office
for Europe; 2018 (Health Evidence Network (HEN) synthesis report 61).
7 Les matières grasses ajoutées – huile, beurre et margarine – peuvent être consommées tous les jours en petites
quantités. Privilégiez l’huile de colza, de noix et d’olive. Recommandations relatives à l’alimentation, à l’activité
physique et à la sédentarité pour les adultes. Saint-Maurice : Santé publique France, 2019. 62 p.
8 A claim that a food is high in unsaturated fat, and any claim likely to have the same meaning for the consumer
may only be made where at least 70% of the fatty acids present in the product derive from unsaturated fat under
the condition that unsaturated fat provides more than 20% of energy of the product. Regulation (EU) No 1924/2006.
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27 September 2019
19NUT329
With the new changes introduced to the Nutriscore in September 20199, a processed
food product – such as a biscuit for example – can benefit from a better score when
using a vegetable oil with a better fatty acid profile like rapeseed oil for example instead
of butter and hence contributing to reach a “B” score.
Getting to a “B” score for bottled oils and fats will never be possible through
reformulation, as none of the individual vegetable oils and fats have a better
score than “C” based on their fatty acid profile specific to their botanical origin.
Towards an adapted Nutriscore for bottled vegetable oils and fats :
FEDIOL proposal
For the above reasons, FEDIOL has further looked at how to enhance the comparability
of bottled vegetable oils and fats, based on scientifically recognised criteria.
FEDIOL proposes to keep the existing Nutriscore and to add the following 2 elements in
the calculation of the scoring system,
1) An
extension of the recognized health benefits of those vegetable oils
and fats with a “high omega 3 fatty acid10”
profile,
2) The
consideration of the unsaturated fatty acids content of vegetable oils
and fats for those oils and fats “high in unsaturated fat11”.
In addition, to ensure alignment with existing national nutrition recommendations
whereby olive oil, rapeseed oil and walnut oil are recommended in a healthy diet,
FEDIOL proposes an adaptation of the negative saturated fat ratio. Such adaptation
covers olive oil only.
The detailed proposal and calculations are available in Annex II.
By this proposal, bottled vegetable oils and fats with a “high in omega 3 fatty acid”
profile and “high in unsaturated fat” will reach the light green “B” score. The FEDIOL
proposal does not introduce changes in the scoring system for other vegetable oils and
fats not meeting such criteria.
Such FEDIOL approach:
is in line with EU nutrition and health claims12 as it proposes criteria from
such EU Regulation, which have been subject to EFSA positive
assessment,
enables to offer consumers with a range of bottled vegetable oils and
fats, ranging from “B” to “E”, for a meaningful and informed consumer
choice,
is aligned with the existing national and international nutritional
recommendations.
FEDIOL stands ready to further discuss with relevant authorities.
9 Ibidem footnote 2.
10 A claim that a food is high in omega-3 fatty acids, and any claim likely to have the same meaning for the
consumer, may only be made where the product contains at least 0,6 g alpha-linolenic acid per 100 g and per 100
kcal, or at least 80 mg of the sum of eicosapentaenoic acid and docosahexaenoic acid per 100 g and per 100 kcal.
Regulation (EC) No 1924/2006 on nutrition and health claims made on food.
11 Ibidem footnote 8
12 Regulation (EC) No 1924/2006 on nutrition and health claims made on food as further amended.
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27 September 2019
19NUT329
Annex I: Nutriscore – category of “Added fats and oils”
Fruits and vegs,
Fibres
Proteins
Energy
SAFA
Sugar
Salt
legumes, nuts,
(ratio SAFA/total fat content)
rapeseed oil,
walnut oil and olive
oil
5 positive points for 0 positive
0 positive
>3,350 kJ
<10: 0 negative point
0 negative point
0 negative
bottled rapeseed
point for
points for
=10 negative
<16: 1 negative point
for bottled
point for
oil, walnut oil and
bottled
bottled
points
<22: 2 negative points
vegetable oils
bottled
olive oil
vegetable
vegetable
<28: 3 negative points
and fats
vegetable oils
oils and
oils and
<34: 4 negative points
and fats
fats
fats
<40: 5 negative points
<46: 6 negative points
<52: 7 negative points
<58: 8 negative points
<64: 9 negative points
≥64: 10 negative points
Differentiation
Bottled
Bottled
Bottled vegetable
Differentiation between
Bottled
Bottled
between bottled
vegetable
vegetable
oils and fats all
bottled vegetable oils and
vegetable oils
vegetable oils
vegetable oils and
oils and
oils and
contain the same
fats are mainly possible
and fats do not
and fats do
fats is possible
fats do not fats do not amount of energy
here.
contain sugar.
not contain
here.
contain
contain
of 3,700 kJ or
But this is not enough to
Hence, all will
salt.
But this is not
fibres.
proteins.
900 kcal per 100
enable a more
have the same
Hence, all
enough to enable Hence, all Hence, all
g.
differentiated comparison
zero score.
will have the
a more
will have
will have
Hence, all will
within the vegetable oil
same zero
differentiated
the same
the same
get 10 negative
and fat category.
score.
comparison
zero
zero
points.
within the
score.
score.
vegetable oil and
fat category.
All bottled vegetable oils and fats assessment will only vary depending mainly on the characterisation under the ratio
SAFA/total fat content and the positive points. They will hence fall in categories ranging from C (light orange), D
(orange) or E (dark orange) and despite the positive points, they will never reach A (dark green) or B (light green).
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27 September 2019
19NUT329
Annex II: FEDIOL Proposal to adapt the Nutriscore for bottled vegetable oils
and fats: Adding a new positive “P” criterion of unsaturated fat and
modifying the existing positive criterion
The negative “N” criteria of energy and saturated fat ratio are kept as per the existing
Nutriscore for the category added fats and oils.
The FEDIOL proposal can be summarised as follows:
(Original Energy + Adapted Saturated fat ratio*) – (Extended positive criteria + NEW
positive criteria of Unsaturated Fat)
* only applicable for olive oil
1.1. Extending the existing positive criteria of “fruits and vegetables”
What it entails:
Building upon the French government decision to include rapeseed, olive and walnut oils
in the positive category “Fruits and vegetables, legumes, nuts, rapeseed oil, walnut oil
and olive oil”, FEDIOL suggests broadening the category to include “vegetable oils high
in omega 3”. This would cover those vegetable oils “high in omega 3”, as defined by the
EU health claim “high omega 3 fatty acids”13 as follows: camelina oil, linseed oil, corn
oil, soybean oil, mustard oil and avocado oil. This will enable to further differentiate
between vegetable oils and fats whilst taking into account the recognised benefits of
omega 3 fatty acids.
Rationale: Following EFSA assessment14, health benefits of alpha-linolenic acid (ALA)
have been recognised as contributing to the maintenance of normal blood cholesterol
levels15, with a daily intake of 2 g of ALA, for food being at least a source of ALA as
referred to in the claim “source of omega 3 fatty acids” as listed in the Annex to
Regulation (EC) No 1924/2006.
In addition, a nutrition claim of “high omega 3 fatty acids” is authorised under EU law16.
FEDIOL is therefore suggesting adding in the positive “P” category those
vegetable oils, which are meeting the criteria of “high omega 3 fatty acids” as
listed in the Annex to Regulation (EC) No 1924/2006. Those oils would be
attributed 5 positive points.
1.2. Adding a NEW positive criterion of “Unsaturated fat”
What it entails:
FEDIOL considers that the content of unsaturated fat should be further used as a criteria
to differentiate between vegetable oils and fats, given the recognised benefits of
unsaturated fat.
Rationale: Following EFSA assessments, the following health benefits have been
recognised for unsaturated fatty acids and authorised by EU law as follows:
-
Replacing saturated fats with unsaturated fats in the diet contributes to the
maintenance of normal blood cholesterol levels.17
13 Ibidem footnote 11.
14
http://www.efsa.europa.eu/en/efsajournal/doc/2203.pdf;
http://www.efsa.europa.eu/en/efsajournal/doc/1252.pdf
15 EU health claim recognised under Commission Regulation (EU) 432/2012 of 16/05/2012.
16 Ibidem footnote 11.
17
https://efsa.onlinelibrary.wiley.com/doi/epdf/10.2903/j.efsa.2011.2203 ;
https://efsa.onlinelibrary.wiley.com/doi/epdf/10.2903/j.efsa.2011.2069
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27 September 2019
19NUT329
-
Replacing saturated fats with unsaturated fats in the diet has been shown to
lower/reduce blood cholesterol. High cholesterol is a risk factor in the
development of coronary heart disease.18
-
Replacing saturated fats in the diet with unsaturated fats contributes to the
maintenance of normal blood cholesterol levels. Oleic acid is an unsaturated fat.19
FEDIOL therefore proposes to further consider the benefits of unsaturated fats to
differentiate between vegetable oils and fats, in allocating them the following points:
Unsaturated in line with " high unsaturated fat" nutrition claim
Points allocated
UFA (UFA content per 100 g)
0
content ≤ 70
1
70 < content ≤ 75
2
75 < content ≤ 80
3
80 < content ≤ 85
4
85 < content ≤ 90
5
90 > content
1.3. Adapting the existing negative saturated fat ratio for olive oil
What it entails:
The existing Nutriscore criteria for saturated fat ratio is adapted, insofar as no negative
point is allocated in case the vegetable oil or fat has a ratio of saturated fat content
below 17%. As such it broadens to <17 instead of <10 the threshold for which no
negative point is allocated for vegetable oils and fats. In practice,
it only affects olive
oils, for which no negative point from the saturated fat ratio would be allocated
(currently 1 to 2 negative points can be allocated to olive oils).
Rationale: National nutrition guidelines recommend the consumption of olive oils,
rapeseed oils and walnut oils20 in a healthy diet. It is therefore important that all those
oils get the same score. Because of the existing saturated fat ratio threshold, olive oil
gets negative points, despite its low content in saturated fat. The below proposal
therefore suggests to re-equilibrate this point.
ADAPTED saturated fat ratio
Number of points allocated
Ratio saturated fat/total fat
0
<17 (instead of <10)
2
<22
3
<28
4
<34
5
<40
6
<46
7
<52
8
<58
9
<64
10
≥64
18
https://efsa.onlinelibrary.wiley.com/doi/epdf/10.2903/j.efsa.2011.2168
19
https://efsa.onlinelibrary.wiley.com/doi/epdf/10.2903/j.efsa.2011.2043
20 Ibidem footnote 7.
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27 September 2019
19NUT329
1.4. Outcome of FEDIOL proposal in terms of Nutriscore scoring
With the FEDIOL proposal, vegetable oils and fats can be differentiated within their
category, taking into account their intrinsic characteristics based on scientifically
recognized evidence and in line with EU authorized health and nutrition claims.
Nutriscore
(incl.
September
2019
modifications) with FEDIOL
the “P” component
for olive oils, nut proposal
oils and rapeseed
oils
Rapeseed oil
C
B
C
C
Sunflower oil*
D
High oleic sunflower oil*
C
C
Olive oil
C
B
C
B
Soybean oil*
D
Coconut oil
E
E
C
B
Corn oil*
D
Palm oil*
D
D
Walnut oil*
C
B
Butter
E
E
Lard
D
D
Linseed oil*
C
B
C
C
Grapeseed oil*
D
C
C
Sesam oil*
D
Avocado oil*
C
B
Peanut oil*
D
C
Camelina oil*
C
B
Mustard oil*
D
B
*
It should be noted that the fatty acid profile of each oil naturally varies depending on their
botanical origin, as well as climate and environment. Instead of a fixed number, the Codex
alimentarius standard on named vegetable oils and fats provides for ranges. Depending on
the exact numbers used for the fatty acid profile of vegetable oils and fats, the rating can
vary and hence, change the scoring.
7
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