Document 11.1
Ares(2021)3392351 of 20/05/2021
GLOBAL HARMONIZATION INITIATIVE
20 May 2021
NUTRITION WORKING GROUP
Muthgasse 18
Vienna, Austria
www.globalharmonization.net
Dear Colleagues from the European Commission at the Directorate General SANTE,
Unit E1 Food information and composition,
Subject: Global Harmonization Initiative Nutrition Working Group opinion on the development of
harmonized mandatory front-of-pack nutrition labelling and the setting of nutrient profiles for
restricting nutrition and health claims on foods
The Global Harmonization Initiative (GHI) is an international non-profit organization, a network
of individual scientists working together to promote the harmonization of global food safety regulations
and legislation. The organization engages and empowers food scientists in industry, government and
academia to voice scientific consensuses and make recommendations on food safety laws and
regulations, globally. GHI is an academic stakeholder of EFSA. Members of GHI, however, never represent
their employers. Membership is individual and contributions to GHI are based on the scientific conscience
of the members.
The Global Harmonization Initiative has a working group on food nutrition (GHIWGN) and could
be considered as an impartial stakeholder regarding the food legislation harmonization process, at the EU
and international level. The WGN, one of the organization’s 16 working groups would like to provide their
expert view regarding nutrition labelling and nutrient profiles and health claims on foods.
Addressing the EFSA Mandate M-2021-0007 (EFSA-Q-2021-00026) “Request to the European
Food Safety Authority for scientific advice on the development of harmonized mandatory front-of-pack
nutrition labelling and the setting of nutrient profiles for restricting nutrition and health claims on foods”,
the GHIWGN is of the opinion that:
Nutrition labelling needs to serve the final consumer in daily food selection towards healthier
food choices for its particular age, gender, health status, preferences, eating habits etc.
GHI-Association – c/o Universität für Bodenkultur, Department für Lebensmittelwissenschaften und –technologien,
z.Hd. Hr. Dr. Gerhard Schleining, 1190 Wien, Muthgasse 18, Österreich - ZVR-Zahl / Reg. Number: 453446383
Also, the front-of-pack label ing needs to boost the fair global food industry and trade system
development in direction of the better nutritional food compositions and tailored food formulation for
special nutritional needs.
The GHIWGN recommends that the issues to be preliminarily considered in implementing the EU
harmonized front-of-pack nutrition label ing should include the fol owing:
I.
The FOP harmonised mandatory food information, as fol owing:
Food identity: descriptive name, country of origin (pictorial logo or descriptive), business producer
name (pictorial logo or descriptive), a fair pictorial food image, the net quantity, number of portions
per package(pictorial logo or descriptive);
Food composition: List of up to three ingredients, inclusive of the primary ingredient
Food nutrient nature (vegetable, animal, substitute/imitation/formed/cultured: chemical,
GMO/non GMO, lab-cultured from stem cel s);
Mandatory nutrition declarations: Energy value, amount of energy % from Dietary Reference
Values (DRV);
Nutrition and health claims: up to three nutrition and health logos;
Safe condition of food use: al ergens or intolerance-inducing ingredients, date of minimum
durability, pictorial of use instructions.
II.
The FOP harmonised additional form of expression and presentation should accomplish the
seven requirements established in Article 35 from Chapter IV of the EU Regulation No.
1169/2011, as fol owings:
“a) they are based on sound and scientifical y valid consumer research and do not mislead the
consumer as referred to in Article 7;
(b) their development is the result of consultation with a wide range of stakeholder groups;
(c) they aim to facilitate consumer understanding of the contribution or importance of the food
to the energy and nutrient content of a diet;
(d) they are supported by scientifical y valid evidence of understanding of such forms of
expression or presentation by the average consumer;
(e) in the case of other forms of expression, they are based either on the harmonised reference
intakes set out in Annex XII , or in their absence, on general y accepted scientific advice on
intakes for energy or nutrients;
(f) they are objective and non-discriminatory; and
(g) their application does not create obstacles to the free movement of goods.”
GHI-Association – c/o Universität für Bodenkultur, Department für Lebensmittelwissenschaften und –technologien,
z.Hd. Hr. Dr. Gerhard Schleining, 1190 Wien, Muthgasse 18, Österreich - ZVR-Zahl / Reg. Number: 453446383
