COPA AND COGECA’S
PROPOSAL ON THE USE
OF FRONT OF PACK (FOP)
NUTRITIONAL LABELLING
SYSTEMS
Brussels, 5th June 2020
Feed and Food
INTRODUCTION
In its Farm to Fork Strategy, the Commission states that
they will propose a harmonised mandatory front-of-
pack nutrition labelling, also referred to as the FOPNL
system, by 2020 to “enable consumers to make health
conscious food choices”. Furthermore, in its report
“regarding the use of additional forms of expression and
presentation of the nutrition declaration” published on
the same day, the Commission seems to give its favor
towards the use of a colour-coded system of FOPNL.
As farmers and also as consumers we welcome
the opportunity to support a measure improving
citizens’ health, transparency and food information
to consumers. More than that, we believe that the
high nutritional quality of the food we take pride in
producing can contribute to it. However, we are afraid
that a mandatory colour-coded FOPNL system would
not allow to achieve this objective and would penalise
hard working farmers by discriminating many quality
and highly nutritionally valuable products.
Therefore, EU farmers calls on the European Institutions
and on the Member States to take into account the
basic concept of “Informing without misleading” when
implementing a EU-wide FOPNL scheme.
Copa and Cogeca recognise the importance
stigmatisation of specific products that are
of the Front of Pack (FOP) nutritional labelling
historically part of our gastronomy and rural
topic in the current discussions taking place
traditions, and that, eaten in the appropriate
in the European institutions, as do European
amounts, can play a key role in a balanced diet.
consumers.
Therefore, we support a FOP labelling scheme
Many Member States have adopted some
that does not stigmatise any specific food
voluntary FOP nutritional labelling systems
products. In particular, an EU system should
within their territory, and the topic is in the
not endanger, neither directly nor indirectly,
spotlight as one of the priorities of the Farm
EU quality food products – e.g. PDOs, PGIs
to Fork strategy1. Therefore, Copa and Cogeca
and TSGs – that, unlike highly processed
would like to reiterate the following key
products, cannot be reformulated and have
principles that should underpin any future
to follow strict and traditional production
FOP labelling system:
disciplinary codes. Moreover, jeopardising EU
quality schemes would mean nullifying the
• Positive & non-discriminatory colour-
European Commission’s efforts to promote
coding systems
these products both within the European
Union and abroad.
The colour-coding systems that are currently
used discriminate against certain categories of
• Science-based & independent
food products because they divide foodstuffs
into those that are good or bad in a questionable
Nutrition is indeed a scientific discipline, thus
manner. While any labelling system should be
it should be addressed as an individual topic,
informative and easy to understand, it should
separately from other factors (e.g. personal
not be overly simplistic. Using a system that
beliefs). Copa and Cogeca is convinced that the
categorises food products as either good
role that the European Food Safety Authority
or bad risks high-quality and nutritious
(EFSA) plays in the field of nutrition is of the
products, such as olive oil, being shunned.
utmost importance in order to provide EU
Such products have beneficial consequences
policy-makers with solid, independent and
for human health and are recommended in
trustworthy input necessary to develop EU-
many diets that have been carefully studied
wide dietary guidelines. We cannot accept
from a nutritional point of view. This type of
FOP systems developed by private actors
contradictory FOP labelling also implies a
within the food chain. Independence is
1 - European Commission Communication on the Farm to Fork Strategy released on 20th May 2020:
https://ec.europa.eu/info/sites/info/files/communication-annex-farm-fork-green-deal_en.pdf
pivotal, as proper nutrition is the baseline for
the individual ingested nutrients alone cannot
preserving human health.
determine the health benefits of a product,
which are rather the result of synergies and
• Harmonised & EU-wide
connections within the overall “food matrix”2
of the product itself.
We are currently witnessing the emergence
of country-specific FOP labelling systems and
• Portion-based
as a result a proliferation of different national
algorithms that are disrupting the internal
People consume portions, the size of which
market. This situation is creating several
varies from one product category to another.
problems for the free movement of goods, as
Therefore, any FOP labelling scheme should
each label has to be adapted to each Member
address the portion concretely recommended
State in which the product is expected to be
by dietary guidelines for each product
sold. The lack of harmonisation is also a clear
category and in a way that is harmonised
sign of weakness of the FOP labelling schemes
across the whole European Union, clearly
currently in place. Any European FOP labelling
stating that the label is referring to a specific
system must be harmonised across the entire
amount of the product (e.g. “X” grammes).
EU territory and developed according to the
These portions should be established
science-based instructions laid out by EFSA.
by a scientific and independent agency,
such as EFSA, taking into account dietary
• Based on dietary guidelines
guidelines and consumers’ eating habits.
Assessing a product based on the standard
Although national and international dietary
100 grammes, when it is consumed in much
guidelines may differ slightly as regards
smaller quantities, is misleading and does
specific products, quantities and consumption
not allow for a clear understanding of the
patterns, there is broad consensus on the
dietary guidelines. Therefore, the nutritional
food groups considered essential for a proper
assessment of a product should be based
diet. It is worth mentioning that the science
on portions. Moreover, if the 100 grammes
of nutrition has increasingly expanded the
reference for nutrient content is still useful
knowledge and scientific literature available
for calculations related to cooking purposes
on the topic, which should therefore be
or very specific diets, it will still be provided
properly assessed and taken into account.
on the back of the packaging as required by
We are currently witnessing a proliferation
Regulation (EU) No 1169/2011.
of positive labels on food and drink products
that are not even included in the dietary
• Voluntary
recommendations. It is clear that some
food and drink categories are recognised
Any additional label may increase costs and
as necessary to sustain human health and
heighten administrative burdens for the
as irreplaceable, whereas others are not. A
operators in the food chain. In addition, some
positive label should only be allowed on food
products may vary slightly from one batch to
and drink products that fall within science-
another (given e.g. their nature or the farming
based dietary guidelines.
conditions) making it difficult to apply the
same FOP label to all the products within that
• Based on a complete assessment of
category. Therefore, it should be left to the
the “food matrix”
operator in the food chain to establish if it is
relevant and coherent to apply any FOP label
Each food and drink product contains different
or not, according to the added value that is
macronutrients and micronutrients. When
returned to the food chain.
establishing nutritional labelling, a complete
Copa and Cogeca would like to conclude by
evaluation of the food should be carried out,
underlying that consumers should not rely
without being based exclusively on certain
exclusively on labels in order to purchase
nutrients. Notably, recent studies show that
products. Taking care of their own diet is a
2 - “The food matrix may be viewed as a physical domain that contains and/or interacts with specific constituents of a food (e.g. a nutrient) providing
functionalities and behaviors which are different from those exhibited by the components in isolation or a free state” (Aguilera, 2018. https://doi.org/10.1
080/10408398.2018.1502743)
conditio sine qua non for taking care of their
own health.
Therefore, we reiterate that educating
consumers is pivotal to properly understand
the benefits of eating agricultural products,
when integrated into diets according to
the patterns and quantities specified by
internationally recognised guidelines, and
with the correct interpretation of any future
FOP labelling scheme. No label will ever be
able to overcome the lack of understanding,
knowledge and motivation needed to follow
dietary guidelines necessarily developed by
EFSA in the future. If we want consumers to
adopt healthy diets and eating habits, we
need large-scale nutrition education and
awareness-raising campaigns starting from
the earliest age possible.
Such campaigns should also underline that a
healthy diet is only one of several key factors
needed to enjoy good health. A balanced
diet should always be coupled with physical
activity and good general life-style habits.
Key points:
we end up setting aside nutritiously valuable
food products. Do we really want to end up
1.
A colour-coded nutrition labelling
with people disregarding honey, but feeling
system would end up presenting an over-
good about consuming aspartame based diet
simplistic classification of food products
soft drinks?
between those that are “good”, in green, and
those that are “bad”, in red. Such a dichotomy
5.
Farmers’ products are crafted and they
will stigmatise highly nutritious products
may vary slightly from one batch to another
which are praised for their nutritional value by
and over seasons, especially those containing
nutritionists all over the world,
natural ingredients like dairy products, meat or
such as olive oil.
fish, making it difficult to apply the same FOP
label to all the products within that category.
2.
A colour-coded system would be Only industrial processed products will have
catastrophic for Geographical Indications
the same exact nutrient content every time. A
products as the only solution for them not to
mandatory FOPNL would penalise those small
be discriminated against and to benefit from
actors who are in any case not those producing
a better “colour” would be reformulation.
the highly processed and unhealthy products,
However, in order to benefit from Geographical
but rather the ones offering consumers the
Indications or other quality schemes, those
best of the EU terroirs.
products have to respect very strict criteria.
This means that any reformulation would be
very complicated or simply impossible for
them. Having in mind that those products
represent an economical value of more than
77,15 billion euros per year, and 7% of the total
sales value of EU food and drink products, this
is highly concerning.
3.
The FOPNL system chosen should
be science based and designed by an
independent and scientific organisation
such as EFSA, following dietary guidelines
established in the same way. Moreover, it
must be based on recommended portions
harmonised at EU level If we start to base
nutritional information and the dietary
guidelines supporting it solely on plant-based
diets or environmental sustainability concerns
without taking health into account, we might
be putting people’s health at risk.
4.
A colour-coded FOPNL does not
take into account the complexity of food
products when establishing their nutritional
contribution. Indeed, each food and drink
product contains different macronutrients and
micronutrients. When establishing nutritional
labelling, a complete evaluation of the food
should be carried out, without being based
exclusively on certain nutrients. By focusing
solely on a very limited number of nutrients
(e.g. sugar, fat and salt) and the energy intake,
Copa and Cogeca are the united voice of
farmers and agri-cooperatives in the EU.
Together, they ensure that EU agriculture
is sustainable, innovative and competitive,
guaranteeing food security to half a billion
people throughout Europe. Copa represents
over 23 million farmers and their families
whilst Cogeca represents the interests
of 22,000 agricultural cooperatives. They
have 66 member organisations from the
EU member states. Together, they are one
of the biggest and most active lobbying
organisations in Brussels.
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