Ref. Ares(2022)4201757 - 07/06/2022
Front-Of-Pack & Nutritional profiles Decathlon’s position
We welcome the European Commission's initiative concerning a mandatory front-of pack and the
establishment of nutritional profiles.
We expect that this initiative will ensure a
harmonization
across the EU and will lead to better choices by consumers. These proposals are coherent for a
balanced diet but not for those specific moments in life which require specific nutrients to stay in
good health. This is why
we also call for an exemption concerning products designed for intense
sport practice , as it is already the case for Nutri-Score in the European governance 1 .
We request an exemption for food intended for intense sport practice
WHY? During an intense sport practice, people can be vulnerable without a proper nutrition
It has been scientifically established for several years that high-intensity effort implies specific needs
regarding the diet of sportspeople before, during and after exercise. Without specific products and
formulations, serious health problems can occur. Front-of-pack and nutritional profiles are very useful for
better consumption within a balanced diet. They are not adapted for special moments, and namely in the
context of high intensity exercise .
Indeed, poor nutrition during exercise not only has an impact on performance but also, and above al ,
can
cause very serious physical problems during and after exercise 2 . In the literature, many undesirable effects
have been reported as a result of a diet that is not in line with the effort made.
Front-of-pack and nutritional profiles are designed and useful for the general population but such
recommendations don't make sense for athletes for whom some nutrients (like
sugar and salt) in specific
dosage are very important and vital, as proven by EFSA 3 , during training and competitions (only - please see
the below scheme).
Classical scheme of training, competition and recovery :
Training
Training
Training
Competition Recovery
=
Specific nutrition needed , exceptional consumption, namely carbohydrates & electrolytes (to
restore the muscle glycogen 4 )
=
Specific nutrition needed, exceptional consumption, namely carbohydrates & proteins (to restore
the damaged muscular tissues and restore muscle glycogen).
1 “Similarly, we do not recommend to use the Nutri-Score on products usually known as sport nutrition products. The
underlying nutrient profiling system of the Nutri-Score was developed in regard to the needs of the general
population, whereas sport nutrition must meet particular needs” (Q&A Nutri-Score III. Food covered)
2 For instance, on hyponatremia :
https://www.trainingpeaks.com/blog/the-dangers-of-hyponatremia/ .
3 Please see Annex 1
4 It is considered that the contribution of glycogen linked to a balanced and adapted diet can provide energy for 1 to
1.5 hours of effort at a sub-high intensity. After this time, the stock is severely depleted, it is necessary to provide an
exogenous, external energy supply such as an energy drink, bar or gel
WHY? People need to have adapted information and accompaniment when buying products
More and more people are challenging themselves in high intensity competitions or training. For example,
the practice of cross-fit is accelerating remarkably. In addition, more and more people are running
half-marathons or marathons. All these sportsmen or sports women are not professionals; they are not
accompanied by a nutritionist doctor or a dietician and they could be vulnerable during intense effort.
Thus, they need to have a clear information about:
1/ What they need to consume during intense exercise : Some nutrients are good during intense sport and
should be restricted in a daily diet. The front-of-pack aims to shed light on the nutritional quality of a
product consumed as part of a varied diet but could cause some confusion in consumer’s minds if it is
applied on products especial y formulated for sport. To affix the front-of-pack on products on those
products could prevent consumers from buying a product they physiological y need 5 .
2/ Why they need to consume more sugar or salt during exercise : Some health claims have been validated
to be used on products intended for sportspeople. These claims are linked to : Carbohydrates solutions &
carbohydrates, Creatine, Vitamin C, Protein 6 . These claims sometimes imply a formulation of the products
with high levels of sugar and salt. If nutrient profiles are adopted, some of these claims may no longer be
al owed even though they require a particular composition high in sugar and salt. However, they are
essential for users of sports products as they al ow them to know the expected beneficial effect.
Which products should be exempted from FoP and nutritional profiles?
An exemption should be granted for al the products which:
1/ are considered as
essential for sportspeople in the sense established by the EFSA’s report 7 on food
intended for sportspeople
AND
1/
fill the scientific conditions established in the EFSA report (SCF 2001 reviewed in 2015)
AND
2/
are marketed as products for intensive sport practice only (mention on the packaging concerning the
specific users or health claim related to sport).
These conditions should prevent any abuse of the exemption granted in order to protect the final
consumer.
5 Please see on Annex 2 some chosen passages about a study conducted on the Nutri-Score and its
relevance to sports nutrition.
6 Please see Annex 3
7
https://www.efsa.europa.eu/en/supporting/pub/en-871
We fully support the introduction of nutritional profiles and a nutritional score on
the front of packaging for general food products
We have a preference for the Nutri-Score which has proven to be very effective in terms of consumer
purchasing behaviour. We are ful y prepared to put it on al our products that are not intended for intense
sport practice. We want it to be :
>
Harmonized in order to enable free movements of goods into EU
>
Mandatory in order to guarantee the equity between al the food sector operators
>
Supported by science in order to achieve the original goal of reducing overweight and related diseases. In
that sense, exemptions should only be granted when justified on scientific grounds and not because of any
national food heritage.
>
Explained to consumers through broad public media campaigns in order so that the consumer knows how
to use this
tool optimal y and so that there is no confusion with other existing or future scores.
Who are we?
Weight problems and obesity are increasing at a rapid rate in most of the EU Member States, with estimates
of 51.6 % of the EU’s population (18 and over) overweight in 2014. Obesity is a serious public health
problem, as it significantly increases the risk of chronic diseases such as cardiovascular disease, type-2
diabetes and certain cancers 8 . The Farm-to-Fork strategy aims to ensure food security, nutrition and public
health, making sure that everyone has access to sufficient, safe, nutritious, sustainable food.
To fight
against these major problems, solutions exist. It is no longer a matter of proof: health is achieved, among
other things, through diet and physical activity .
Since 1976, Decathlon's mission is to sustainably make the pleasure and benefit of sport accessible to the
many. In this regard, our core food products have always been adapted to intensive sports practice
(isotonic drinks, proteins, carbohydrates, food supplements). Since 2021, Decathlon Nutrition also wishes
to propose accessible general food products adapted to every need which wil promote good health for
everyone.
Aware that the food transition is
one of the major challenges to be taken up by the World over the next few
years, Decathlon Nutrition signed the Code of Conduct for responsible business and marketing practices
and real y wishes to get involved in designing, producing and distributing sustainable and nutritious food
products.
8 https://ec.europa.eu/eurostat/statistics-explained/index.php/ Overweight_and_obesity_-_BMI_statistics)
ANNEX 1 - Specific Needs during intense sport practice
Sportspeople are not a category of population as such. They belong to the general population most of the
time and need to have a balanced diet, as everyone. But, during the effort, it is proven by science that some
specific needs have to be covered through specific products easily consumed during effort. In this regard,
the EFSA’s report previously mentioned highlights :
a) the essential role of carbohydrate intake in relation to physical performance, and particularly in relation
to the recovery of normal muscle function after strenuous exercise, and the role of vitamin B1 on
carbohydrate metabolism;
b) the role of hydration and carbohydrate supply in the maintenance of physical performance during
endurance exercise, as wel as
on the role of electrolytes (particularly sodium) in the maintenance of
adequate hydration during exercise and in post-exercise re-hydration;
c) the essential role of protein in the growth and maintenance of muscle mass, and the role of
vitamin B6 in
protein metabolism;
d) the essential role of micronutrients and long-chain polyunsaturated fatty acids on body functions which
may impact either athletic performance or specific health risks for athletes;
e) the ergogenic properties of caffeine in endurance exercise; and
f) the ergogenic effects of creatine in physical performance during short-term, high-intensity, repeated
exercise bouts.
Annex 2: Consumer’s study about Nutri-Score and Sport Nutrition
Study in French in attachment.
Annex 3: Authorized claims concerning sport nutrition
>
Carbohydrate-electrolyte solutions contribute to the maintenance of endurance performance during
prolonged endurance exercise
>
Carbohydrate-electrolyte solutions enhance the absorption of water during physical exercise
>
Carbohydrates contribute to the recovery of normal muscle function (contraction) after highly intensive
and/or long-lasting physical exercise leading to muscle fatigue and the depletion of glycogen stores in
skeletal muscle
>
Vitamin C contributes to maintain the normal function of the immune system during and after intense
physical exercise
>
Creatine increases physical performance in successive bursts of short-term, high intensity exercise
>
Protein contributes to a growth in muscle mass / to the maintenance of muscle mass