Food reformulation
Ref. Ares(2021)6371767 - 18/10/2021
and product
innovation
POSITION PAPER
The EU Farm to Fork (F2F) Strategy, which is at the heart of the European Green Deal, aims
at making food systems fair, healthy and environmentally-friendly. In this context, the high
prevalence of (childhood) obesity and other noncommunicable diseases in Europe is of
serious concern and food and drink manufacturers have already taken their responsibilities
in contributing to address this challenge.
Finding and implementing solutions to this highly
Building on this experience, the European Snacks
complex and multi-factorial health and wellbeing
Association is looking forward to sharing its recipe
issue (e.g. physical activity levels, age, overall
for successful reformulation initiatives.
health, dietary preferences, etc.) requires a
whole of society effort and multistakeholder
ESA supports the Commission’s ambition to further
collaboration.
stimulate reformulation and would like to share the
following recommendations for a proportionate, fair,
National governments and food business
evidence-based but also more effective strategy:
operators (including industry, retail, catering,
bars and restaurants, etc.) have a joint interest
Summary of our
and responsibility in ensuring that consumers
have access to a wide range of food and
key recommendations
drinks that help them to achieve a healthy
and balanced diet.
Involving all concerned sectors to ensure a
1
balanced, goal-oriented and transparent process.
The Farm to Fork Strategy sets out a number
of measures to make that happen, including
Avoiding discriminatory interventions such as
2
launching initiatives to stimulate food
setting maximum limits for certain nutrients.
reformulation. Product formulation and innovation
Using robust methodology and data for setting
3
are important means, although not the only
realistic and balanced targets and ensuring proper
ones, to enhance the nutritional composition
monitoring and reporting of reformulation efforts.
of products, for example by reducing levels of
Considering past reformulation efforts/
salt, saturated fat and calories; by adding fibre,
4
achievements.
proteins, vitamins and minerals; or by adjusting
portion sizes, amongst others.
Considering the different barriers to
5
reformulation for each product category.
ESA members have a long-lasting involvement in
the nutrition and health debate, at both national
Considering actual contribution of food and drink
6
and European level, with a track record of
products to nutrient intake in order to optimise
successful reformulation efforts. Committed to act,
the potential health outcome.
we are supportive of a strengthened approach to
Allocating sufficient transitional periods for
better and smarter regulation at EU level in which
7
manufacturers to meet targets.
multi-stakeholder actions and self-regulation
come in useful.
1
Food reformulation and product innovation
Position paper
Activity and Health - to which ESA was an active
1 A sector with a strong
member since its inception
3 more than a decade
ago - has been instrumental in fostering voluntary
history in reformulation
activities, notably on food reformulation.
and product innovation
There are many examples of manufacturers’
achievements in reformulating popular
The European savoury snacks industry listens to
mainstream products, as well as developing the
the preferences of the millions of consumers who
market of healthier options, for instance using
enjoy our products every day. Our consumers
protein-rich pulses like lentils.
demand safe and great tasting snacks and treats,
excellent value for money, striving for improved
nutritional content and of course the highest-
FOCUS ON SALT REDUCTION
quality ingredients and finished products.
Savoury snacks taste salty because the salt is
applied to the surface; whilst other everyday
Responding to health concerns around
foods often contain higher amounts but taste
consumers’ diets, savoury snacks manufacturers
less salty as the salt is distributed throughout the
have worked very hard over the last decades
foodstuff.
to bring these great flavours and tastes to
market whilst ensuring lower overall salt levels,
Savoury snack manufacturers have responded
reducing saturated fat and also total fat
quickly to changing consumer preferences with
content in products. To meet these expectations
respect to salt and many ranges of lower-salt
manufacturers continually invest millions of
and no-salt products are now available; allowing
Euros into the reformulation of existing and
consumers to make the choices best suited to
development of new products, ingredients and
their individual lifestyles.
manufacturing methods.
France
The sector has a long history of participation
Between 2009 and 2013 (latest data
in reformulation programmes across the EU.
available), significant sodium reduction
The Members States survey unveiled in 2016
was achieved for coated nuts (-21%), breadsticks
by the Slovak Presidency titled “Best practices
and pastry snacks (-13%) and puffed snacks
for Member States in food reformulation
1”
(-9%). A reduction of 13% in salt in potato crisps
confirms that the savoury snacks sector has been
was also reported between 2009 and 2011
4.
successfully involved in reformulation programmes
in the past decades, notably on salt reduction.
UK
This demonstrates the commitment of the
Savoury snack manufacturers voluntarily
sector, its sense of responsibility and its ability to
reduced the amount of salt in crisps by
collaborate with authorities to address current
over 53% between 1990 and 2019. Latest Public
challenges on nutrition and health.
Health England progress report on salt reduction
confirms that the sector has again met the
The different EU Framework for National Initiatives
average salt reformulation targets
5.
on Selected Nutrients
2 as well as the dynamic
generated by the EU Platform on Diet, Physical
1 https://ec.europa.eu/health/sites/health/files/nutrition_physical_activity/docs/2016euskpresidency_bestpractices_en.pdf
2 https://ec.europa.eu/health/sites/health/files/nutrition_physical_activity/docs/euframework_national_nutrients_en.pdf
3 ESA held three core commitments with the EU Platform for Action on Diet, Physical Activity and Health: improving the products’ nutritional
composition; helping consumers making informed choices and advertising responsibly, notably towards children.
4 https://oqali.fr/content/download/3444/33031/file/OQALI%202016_Synthese%20evolution%20secteur%20Aperitifs%20a%20croquer.pdf
5 https://www.gov.uk/government/publications/salt-targets-2017-second-progress-report
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Food reformulation and product innovation
Position paper
Italy
2
When product
Between 2010 and 2017, 19% reduction
reformulation
of salt in potato crisps and 10% reduction
reaches its limits
overall for savoury snacks (including snack nuts)
between 2013 and 2017. 35% reduction on
crackers between 2008 and 2017
6.
Product reformulation cannot be the silver bullet
The Netherlands
for entirely tackling nutrition and health issues,
The most recent governmental
partly because there are profound limitations.
reformulation programme (ended in 2018)
These were highlighted in 2016 by the Dutch
showed that within the savoury snacks sector,
Presidency in its Roadmap for Action on Food
an average of 74% of the products meet
Improvement
7, which clarify that:
the agreement
7.
Ireland
To maintain consumer
“
Between 2005 and 2012
8, 38% reduction
acceptance”
a gradual reduction
in salt for savoury snacks (incl. crisps,
of nutrients is required and that
chipped, fried & roasted potatoes, nuts & seeds,
herbs & spices, savoury snacks).
“technological possibilities, food
safety and sustainability goals can
Spain
influence the possible results of food
Between 2005 and 2016, savoury
product improvement”
snack manufacturers voluntarily reduced
30% of salt in potato crisps and 23% of salt for
savoury snacks. Additionally, in 2017 savoury
This is especially valid for the savoury snacks sector
snacks manufacturers joined the governmental
which has a long experience of reformulation and
reformulation programme which implied
product innovation. Consumer expectation has to
additional commitments: reduction of the
be considered as well as the realities of consumer
sectorial median of salt content (further 13,8%
behavior. Change cannot happen overnight and
in potato crisps and 5% in savoury snacks)
9.
time is needed to introduce a new recipe (R&D,
technology) onto the market and to get it known
FOCUS ON SATURATED
by the consumer.
FAT REDUCTION
But more importantly, the sector is reaching its
Over the past decade, manufacturers have
technological limits and further reducing salt for
invested into new technologies (e.g. equipment
instance might mean that some products simply
and cooking/baking techniques) and ingredients
cannot be manufactured anymore (e.g. baked
(vegetables oils with more unsaturated fats, e.g.
or extruded products) or organoleptic properties
shifting to sunflower or rapeseed oils) to reduce
might alter so much that consumers will stop
the level of saturated fat in savoury snacks,
purchasing products.
leading to up to 60% less saturated fat in the
final product. Most recent data in Italy showed a
Thanks to continuous improvements of product
drop of 44% in saturated fat content for potato
recipes over the past decades, some products
crisps between 2008 and 2018.
have already reached the limits of what can be
realistically achieved.
6 http://www.salute.gov.it/imgs/C_17_pubblicazioni_2426_ulterioriallegati_ulterioreallegato_0_alleg.pdf
7 https://www.rivm.nl/bibliotheek/rapporten/2019-0032.pdf
8 www.fdii.ie/Sectors/FDII/FDII.nsf/vPages/Publications~fdii-creme-global-reformulation-report?OpenDocument
9 https://www.boe.es/diario_boe/txt.php?id=BOE-A-2019-3634
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Food reformulation and product innovation
Position paper
MAIN BARRIERS TO PRODUCT
FORMULATION AND INNOVATION
Legal frameworks
Food safety
(e.g. limited possibilities to communicate
(e.g. preservation, shelf-life)
about gradual step-changes e.g. through
nutrition claims)
Consumer acceptance
Conflicting objectives
(e.g. taste, texture, price)
(e.g. food wastage)
Technological constraints
Contractual arrangements between
(e.g. production, function – salt
retailers and manufacturers for private
needed for expansion process)
label products
such as bread, meats and cheese. Figures are
3 Implementing efficient food
similar for saturated fat intake coming from
reformulation and product
savoury snacks.
Overall, across the EU, the
innovation strategies
average intake of energy, salt, fat and saturated
fat through the consumption of savoury snacks is
very low, ranging between 2-4% of overall intake,
depending on the nutrient and the country.
We believe that different strategies can prove
effective in stimulating reformulation and driving
It should also be acknowledged that there are
food innovation forward. As demonstrated
no unhealthy foods per se, but only unbalanced
above,
self- and co-regulation approaches are
diets. Considering the amount, combination
efficient tools to incentivise reformulation and
and frequency of food intake is a fundamental
product innovation since it usually allows for
parameter to maintain a healthy and balanced
the setting of realistic objectives (both in terms
diet. Savoury snacks are typically not consumed
of nutrient reduction and timing), considering
every day and a recent publication from the
manufacturers constraints, especially Small and
European Office of the World Health Organisation
Medium Enterprises (SMEs).
(WHO Europe) found that 94.8% of children do not
eat savoury snacks on a daily basis and close to
We also believe that in order to be fully
2/3 never or rarely eat savoury snacks throughout
effective, with potentially measurable impact
the week
11.
on consumers’ intake, reformulation initiatives
should consider actual products’ contribution
Stimulating the addition of nutrients contributing
to salt, sugar, fat or calorie intake.
The savoury
to a healthy diet should not be overlooked
snacks sector is, in the present case, a minor
in product reformulation strategies but rather
contributor to European diets. According to the
complement reduction of nutrients of public
latest figures in the EU
10, only 3% of the average
health interest. Savoury snacks manufacturers
overall dietary intake of salt derives from savoury
increasingly include grains, fibre- and protein-rich
snacks (less than 2% to in the UK, and 1% in France
ingredients to improve the nutritional composition
and Spain). Savoury snacks are not among the
of the products and can further contribute to the
top 5 largest contributors to dietary salt intake
uptake of these nutrients in the European diet.
which includes other common everyday foods,
10 Euromonitor Nutrition Passport 2019
11 “How healthy are children’s eating habits? – WHO/Europe surveillance results”, 2020. https://www.mdpi.com/2072-6643/12/8/2481/htm
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Food reformulation and product innovation
Position paper
We are therefore strongly concerned by the
ESA supports the Commission’s ambition to further
European Commission’s proposal to set maximum
stimulate reformulation and would like to share the
levels of certain nutrients in certain foods as
following recommendations for a proportionate,
indicated in the F2F Strategy:
fair but also more effective strategy:
•
It could lead to the disappearance of
Our recommendations
consumers’ favourite food (as well as some
traditional foods) and seriously hamper food
innovation in the long term.
A transparent process: Involvement of
1
concerned sectors is essential since they own
•
This approach implies that no further reduction
the knowledge and can share detailed technical
is needed for products which already meet
inputs about the feasibility of reduction in certain
the maximum limits and consequently
categories of products.
discourage future reformulation efforts.
Opting for the most efficient approach: Setting
2
•
It may prevent new players/new products from
maximum limits is the most discriminatory as it
emerging in the market even if the volumes
stifles innovation and can seriously impact the
sold are low and are having nearly zero impact
competitiveness of the European food and drink
on population intake of certain nutrients.
industry. We suggest working against sale
weighted average.
•
It therefore represents a strong barrier to
market access, especially for SMEs for both
Robust methodology and data: Indispensable
3
locally produced foods and imports.
prerequisite for setting realistic and fair targets as
well as to ensure proper monitoring and reporting of
•
It fails to inform about the actual reduction
reformulation efforts.
of the concerned nutrient across the category.
Hence, positive impact on the overall intake
Factor-in past efforts/achievements: Necessary to
4
in the population is difficult to predict.
discuss fair and realistic objectives for each product
category. Benchmark (T0) should be set between 5
to 10 years ago.
Moreover, any unnecessary and unjustified
Fully consider the different barriers to
5
regulatory intervention on food composition, such
reformulation for each product category: Because
as setting maximum limits for certain nutrients,
of the vast variety of products and associated
would pose serious questions in regard to the
reformulation challenges, defining well the different
compatibility with the European Commission’s
product segments is key (e.g. targets/time can’t be
“Better Regulation” approach as well as with EU
the same for salty sticks than regular potato crisps).
trade and competition law.
Consider actual contribution of food and drink
6
Using other proven methods, such as the Sales
categories to nutrient intake: In order to concentrate
Weighted Average (SWA) approach as applied
efforts where it matters and optimise the potential
in the UK
12, with realistic targets and timing, is
health impact linked to reduced nutrient intake.
probably the most interesting and effective one
Sufficient time must be allocated to manufacturers
as it really captures what is happening on the
7
to reformulate their products: Changes do not
market at consumer level and also allow for a
happen over-night and requires a lot of financial
better tracking of the nutrient intake impact
and human resources (esp. for SMEs).
on consumers.
In all cases,
any successful reformulation
programmes must be based on accurate data
For more information contact:
European Snacks Association
and evidence since it will form the basis for setting
Rue des Deux Eglises 26, BE-1000 Brussels
the ambition (targets, time) and ensure proper
T: +32 (0) 25 38 20 39 E: xxx@xxxxxxxxx.xx
monitoring and reporting of reformulation efforts.
@ESA_Snacks
12 New UK Roadmap for salt reduction: https://www.gov.uk/government/
www.esasnacks.eu
publications/salt-reduction-targets-for-2024
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