Ref. Ares(2021)6371767 - 18/10/2021
Nutrient Profiles
POSITION PAPER
The European Snacks Association (ESA)1 fully supports the ambitions of the Farm to Fork Strategy to
deliver sustainable food production and consumption and to help achieving the EU’s Green Deal
objectives towards climate-neutrality in Europe.
In May 2020, the European Commission adopted
be established based on science and evidence
the
Farm to Fork Strategy, aiming to make food
and should only be set following a holistic impact
systems fair, healthy and environmentally friendly.
assessment. Nutrient profiles should only relate
In this context, the Commission is proposing a
to diet, nutrition and the relation to health, and
revision of
Regulation (EU) No 1169/2011 on the
not to food safety which is regulated elsewhere
provision of food information to consumers and
in EU legislation. Moreover, it is also essential that
the establishment of nutrient profiles to restrict the
nutrient profiles are
not used in any other fields,
promotion (via nutrition or health claims) of foods
such as marketing or taxation, in order to avoid
high in fat, sugars and salt. The Regulation (EU)
potential discrimination of products.
No 1169/2011 already provides a high degree
of product transparency in respect of energy
Our recommendations
content and nutrient content of carbohydrates,
Nutrient profiles should:
sugar, fat, saturated fatty acids, protein, and salt.
The consumer is simultaneously being offered
complete information as a point of orientation,
not exclude any products a priori, i.e. not
1
discriminate against specific foods or ingredients,
not only Back-of-Pack (BOP) but also Front-of-
and be used in the context of the Claims
Pack (FOP).
The European savoury snacks industry
Regulation only.
has been at the forefront of voluntarily providing
be developed for all categories; as all categories
consumers with clear nutrition information (GDAs,
2
can provide options ranging from nutritious to
now Reference Intakes) FOP and fully supports a
indulgent.
voluntary, science-based, non-discriminatory and
be established based on science and evidence
informative labelling of food products.
3
and should only be set following a holistic impact
assessment.
According to art 4 (1) of Claims Regulation
2,
nutrient profiles are thresholds of nutrients such as
not be used in any other fields, such as
4
marketing or taxation, in order to avoid potential
fat, saturated fat, salt and sugars above which
discrimination of products.
nutrition claims are restricted and health claims
are prohibited.
In our opinion, nutrient profiles
take into account positive nutrition. In particular,
5
should not exclude any products a priori, i.e. not
potatoes should continue to classify as
contributing to vegetable content.
discriminate against specific foods or ingredients
and be used in the context of the Claims
be conducive and incentivise reformulation
6
Regulation only. Nutrient profiles should
and future innovation.
1 ESA is Europe’s only trade organisation dedicated to advancing the savoury snacks industry on behalf of member snack manufacturers and suppliers,
as well as national trade organisations. ESA members are involved in the manufacture of potato crisps, corn chips /tortillas, pellet snacks, baked snacks,
crackers, pretzels, savoury biscuits, popcorn, pork rinds, meat snacks, fruit snacks, peanuts, other snack nuts and various other savoury snacks in this
category.
2 Regulation (EC) No 1924/2006 of the European Parliament and of the Council of 20 December 2006 on nutrition and health claims made on foods
Nutrient Profiles
Position paper
Savoury snacks can be
As a priority for the snack industry, accurate
part of a healthy and
labelling helps consumers make informed choices
providing information on a wide variety of issues
balanced diet
including ingredient composition, nutritional value,
portion sizes and storage conditions
4.
All savoury snack products contain core nutrients
(carbohydrate, fat, protein), micronutrients in the
Innovation has always been
form of minerals, vitamins, and fibre, and offer a
at the heart of the European
quick source of energy. Among which:
savoury snacks industry
Pulse-based snacks, for example lentils-
based snacks, have on average 40% less fat than
regular potato crisps and a 13% protein content.
ESA members constantly invest in the reformulation
of existing products as well as in the development
Nuts are an important source of nutrients,
of new products, ingredients and manufacturing
including dietary fibre, copper, iron, magnesium,
methods to bring great flavours and tastes to
and potassium. They also contain many important
market whilst ensuring lower levels of salt,
minerals and vitamins, with their own benefits and
saturated fat and total fat. However, it is extremely
varying levels of nutrients. For instance,
challenging to continue changing product
recipes at this pace without considering what has
•
Almonds are a ‘high source’ of dietary fibre
been already achieved. In terms of salt and fat
and vitamin E, the latter which contributes
reduction, the industry is reaching its technological
to the protection of cells from oxidative stress.
limits and further reducing these nutrients might
They are also high in riboflavin (vitamin B2),
mean that some products simply cannot be
which contributes to the maintenance of
manufactured anymore (e.g. baked or extruded
normal skin and vision, and calcium, which
products) or organoleptic properties might alter so
helps maintain normal bones and teeth.
much that consumers will stop purchasing products
with an improved nutritional composition.
•
Cashews are high in copper and iron, which
contribute to the normal functioning of the
It is important that nutrient profiles do not stifle the
immune system.
ability of the food and drink industry to innovate
or reformulate – whether this is to make small
Savoury snacks products contribute very little to the
but meaningful positive contributions, or equally
average dietary salt and fat intake in the European
affect other positive nutritional contributors.
diet, taking also into account that they are usually
Communicating nutritional changes made on
eaten in small quantities.
According to the latest
foods is a form of nutrition claim and if nutrient
figures in the EU3, only 3% of the average overall
profiles are too restrictive, advising consumers
dietary intake of salt derives from savoury snacks.
about such beneficial changes could be
To further improve the nutritional composition of
impacted, which in turn impacts the overall
products and meet consumer preferences, where
health of consumers’ diets in a negative way.
possible, snacks makers also increasingly include
fibre- and protein-rich ingredients such as pulses to
develop the market for healthier options.
For more information, contact:
European Snacks Association asbl
Rue des Deux Eglises 26, BE-1000 Brussels
T: +32 (0) 25 38 20 39 E: xxx@xxxxxxxxx.xx
3 Euromonitor Nutrition Passport 2019.
@ESA_Snacks
4 ESA Consumer Information Factsheet
www.esasnacks.eu
