Document 35.2
27 September 2019
Ref. 19NUT329
FEDIOL position
Towards an adapted Nutriscore for bottled vegetable oils and fats
Context
FEDIOL has been engaged in discussions and has followed the developments on nutrient
profiles for many years.
FEDIOL understands the need to introduce a food labelling system such as the Nutriscore
to push consumers to fav
Hence, FEDIOL can support such initiatives as long as:
1) it provides meaningful information to consumers;
2) it enables bottled vegetable oils and fats to get a scoring across the
whole possible range
;
3) it enables all food products including vegetable oils and fats - to
even if challenging, through reformulation.
FEDIOL has therefore assessed such system in detail1, including the last modifications
introduced in September 20192. For bottled vegetable oils and fats, the scoring is
anation is available in Annex I.
FEDIOL welcomes the recent modifications of the Nutriscore3, which recognises positive
effects on health from rapeseed oil, walnut oil and olive oil, by including them in the
es, nuts, rapeseed oil, walnut oil and
4. As a result, olive oil and walnut oil can now bear a
whilst
Whilst FEDIOL welcomes this approach as a step in the good direction, it has limited
impact on the differentiation of bottled vegetable oils and fats. Indeed, it still
classifies all vegetable oils and fats only
, and none under
B .
However, by this change, it will be possible to have a positive impact on a processed
composite food product containing oil/
oils/fats with
and fats and thereby improve its final score.
1 FEDIOL position on Nutriscore, April 2019, 19NUT079.
2 Arrêté du 30 août 2019 modifiant l'arrêté du 31 octobre 2017 fixant la forme de présentation complémentaire à
la déclaration nutritionnelle recommandée par l'Etat en application des articles L. 3232-8 et R. 3232-7 du code de
la santé publique, JORF n°0206 du 5 septembre 2019 texte n° 6.
3 Ibidem footnote 2.
4 By this, olive, rapeseed and walnut oils benefit from 5 additional positive points.
T H E E U V E G E T A B L E O IL A N D P R O T E IN M E A L I N D U S TR Y
168, avenue de Tervuren (bte 12) B 1150 Bruxelles Tel (32) 2 771 53 30 Fax (32) 2 771 38 17 Email : xxxxxx@xxxxxx.xx ht p://www.fediol.eu
Ets n° 0843946520 Transparency Register n°85076002321-31
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19NUT329
Why the Nutriscore does not fit bottled vegetable oils and fats in practice
The current Nutriscore does not fit bottled vegetable oils and fats for the following main
reasons:
1) It does not offer consumers a better bottled vegetable oil/fat alternative
Despite the positive points, the system does not enable to re-balance the other negative
components. Vegetable oils will hence fall in categories C (light orange), D (orange)
or E (dark orange), but never in the green categories A or B .
Therefore, the existing Nutriscore system does not enable to sufficiently
differentiate botted vegetable oils and fats within the entire category and
across the sub-categories defined by the current scoring.
2) It suggests to eat
, which should be on the contrary favored according to WHO and
national nutrition guidelines.
WHO recommends replacing butter, lard and ghee with oils rich in polyunsaturated fats,
such as canola (rapeseed), sunflower, soybean, corn and safflower oils to lower the risk
of developing non-communicable diseases5.
It further contradicts what WHO considers as core/basic products6 whereby vegetable
oils and fats are recommended to be consumed as part of a healthy diet in most national
nutrition guidelines.
And hence, it is not in line with national nutrition guidelines such as in France7, which
recommend to favour olive, rapeseed and walnut oils
means that such vegetable oils are to be eaten
.
3) It does not create a suitable environment for consumers to favour
polyunsaturated fat content in the diet.
Polyunsaturated fats (PUFA) are recognised for having proven benefits in a healthy diet.
They can come from different sources, one of the main contributors in several
countries is vegetable oils and fats high in PUFA. This is why they are
recommended by national nutrition guidelines in the context of a healthy diet.
Ranking as
known vegetable oils high in PUFA as defined under EU health
claim8 will not result in consumers favouring a vegetable oil high in PUFA over another
one.
4) It creates a discrimination for bottled vegetable oils and fats vs. vegetable
oils and fats used as an ingredient in processed food products.
5
WHO factsheet on healthy diet, updated October 2018. https://www.who.int/news-room/fact-
sheets/detail/healthy-diet
6 Kelly B and Jewell J. What is the evidence on the policy specifications, development processes and effectiveness
of existing front-of-pack food labelling policies in the WHO European Region? Copenhagen: WHO Regional Office
for Europe; 2018 (Health Evidence Network (HEN) synthesis report 61).
7 Les matières grasses ajoutées huile, beurre et margarine peuvent être consommées tous les jours en petites
physique et à la sédentarité pour les adultes. Saint-Maurice : Santé publique France, 2019. 62 p.
8 A claim that a food is high in unsaturated fat, and any claim likely to have the same meaning for the consumer
may only be made where at least 70% of the fatty acids present in the product derive from unsaturated fat under
the condition that unsaturated fat provides more than 20% of energy of the product. Regulation (EU) No 1924/2006.
2
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19NUT329
With the new changes introduced to the Nutriscore in September 20199, a processed
food product such as a biscuit for example can benefit from a better score when
using a vegetable oil with a better fatty acid profile like rapeseed oil for example instead
.
d fats will never be possible through
reformulation, as none of the individual vegetable oils and fats have a better
Towards an adapted Nutriscore for bottled vegetable oils and fats :
FEDIOL proposal
For the above reasons, FEDIOL has further looked at how to enhance the comparability
of bottled vegetable oils and fats, based on scientifically recognised criteria.
FEDIOL proposes to keep the existing Nutriscore and to add the following 2 elements in
the calculation of the scoring system,
1) An extension of the recognized health benefits of those vegetable oils
and fats with a high omega 3 fatty acid10 profile,
2) The consideration of the unsaturated fatty acids content of vegetable oils
and fats for those oils and fats
11 .
In addition, to ensure alignment with existing national nutrition recommendations
whereby olive oil, rapeseed oil and walnut oil are recommended in a healthy diet,
FEDIOL proposes an adaptation of the negative saturated fat ratio. Such adaptation
covers olive oil only.
The detailed proposal and calculations are available in Annex II.
By this proposal, bottled
id
proposal does not introduce changes in the scoring system for other vegetable oils and
fats not meeting such criteria.
Such FEDIOL approach:
is in line with EU nutrition and health claims12 as it proposes criteria from
such EU Regulation, which have been subject to EFSA positive
assessment,
enables to offer consumers with a range of bottled vegetable oils and
consumer
choice,
is aligned with the existing national and international nutritional
recommendations.
FEDIOL stands ready to further discuss with relevant authorities.
9 Ibidem footnote 2.
10 A claim that a food is high in omega-3 fatty acids, and any claim likely to have the same meaning for the
consumer, may only be made where the product contains at least 0,6 g alpha-linolenic acid per 100 g and per 100
kcal, or at least 80 mg of the sum of eicosapentaenoic acid and docosahexaenoic acid per 100 g and per 100 kcal.
Regulation (EC) No 1924/2006 on nutrition and health claims made on food.
11 Ibidem footnote 8
12 Regulation (EC) No 1924/2006 on nutrition and health claims made on food as further amended.
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27 September 2019
19NUT329
Annex II: FEDIOL Proposal to adapt the Nutriscore for bottled vegetable oils
and fats:
modifying the existing positive criterion
Nutriscore for the category added fats and oils.
The FEDIOL proposal can be summarised as follows:
(Original Energy + Adapted Saturated fat ratio*) (Extended positive criteria + NEW
positive criteria of Unsaturated Fat) * only applicable for olive oil
1.1.
s
What it entails:
Building upon the French government decision to include rapeseed, olive and walnut oils
and oliv
broadening
by the
omega 3 fatty acids 13 as follows: camelina oil, linseed oil,
soybean oil and mustard oil. This will enable to further differentiate between vegetable
oils and fats whilst taking into account the recognised benefits of omega 3 fatty acids.
Rationale: Following EFSA assessment14, health benefits of alpha-linolenic acid (ALA)
have been recognised as contributing to the maintenance of normal blood cholesterol
levels15, with a daily intake of 2 g of ALA, for food being at least a source of ALA as
referred to in the claim
as listed in the Annex to
Regulation (EC) No 1924/2006.
In addition
omega 3 fatty acids
authorised under EU law16.
FEDIOL is therefore suggesting adding
vegetable oils, which are meeting the criteria of
omega 3 fatty acids
listed in the Annex to Regulation (EC) No 1924/2006. Those oils would be
attributed 5 positive points.
1.2. Adding a NEW positive criterion
What it entails:
FEDIOL considers that the content of unsaturated fat should be further used as a criteria
to differentiate between vegetable oils and fats, given the recognised benefits of
unsaturated fat.
Rationale: Following EFSA assessments, the following health benefits have been
recognised for unsaturated fatty acids and authorised by EU law as follows:
-
Replacing saturated fats with unsaturated fats in the diet contributes to the
maintenance of normal blood cholesterol levels.17
13 Ibidem footnote 11.
14 http://www.efsa.europa.eu/en/efsajournal/doc/2203.pdf;
http://www.efsa.europa.eu/en/efsajournal/doc/1252.pdf
15 EU health claim recognised under Commission Regulation (EU) 432/2012 of 16/05/2012.
16 Ibidem footnote 11.
17 https://efsa.onlinelibrary.wiley.com/doi/epdf/10.2903/j.efsa.2011.2203 ;
https://efsa.onlinelibrary.wiley.com/doi/epdf/10.2903/j.efsa.2011.2069
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19NUT329
-
Replacing saturated fats with unsaturated fats in the diet has been shown to
lower/reduce blood cholesterol. High cholesterol is a risk factor in the
development of coronary heart disease.18
-
Replacing saturated fats in the diet with unsaturated fats contributes to the
maintenance of normal blood cholesterol levels. Oleic acid is an unsaturated fat.19
FEDIOL therefore proposes to further consider the benefits of unsaturated fats to
differentiate between vegetable oils and fats, in allocating them the following points:
Unsaturated in line with " high unsaturated fat" nutrition claim
Points allocated
UFA (UFA content per 100 g)
0
1
2
3
4
5
90 > content
1.3. Adapting the existing negative saturated fat ratio for olive oil
What it entails:
The existing Nutriscore criteria for saturated fat ratio is adapted, insofar as no negative
point is allocated in case the vegetable oil or fat has a ratio of saturated fat content
below 17%. As such it broadens to <17 instead of <10 the threshold for which no
negative point is allocated for vegetable oils and fats. In practice, it only affects olive
oils, for which no negative point from the saturated fat ratio would be allocated
(currently 1 to 2 negative points can be allocated to olive oils).
Rationale: National nutrition guidelines recommend the consumption of olive oils,
rapeseed oils and walnut oils20 in a healthy diet. It is therefore important that all those
oils get the same score. Because of the existing saturated fat ratio threshold, olive oil
gets negative points, despite its low content in saturated fat. The below proposal
therefore suggests to re-equilibrate this point.
ADAPTED saturated fat ratio
Number of points allocated
Ratio saturated fat/total fat
0
<17 (instead of <10)
2
<22
3
<28
4
<34
5
<40
6
<46
7
<52
8
<58
9
<64
10
18 https://efsa.onlinelibrary.wiley.com/doi/epdf/10.2903/j.efsa.2011.2168
19 https://efsa.onlinelibrary.wiley.com/doi/epdf/10.2903/j.efsa.2011.2043
20 Ibidem footnote 7.
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19NUT329
1.4. Outcome of FEDIOL proposal in terms of Nutriscore scoring
With the FEDIOL proposal, vegetable oils and fats can be differentiated within their
category, taking into account their intrinsic characteristics based on scientifically
recognized evidence and in line with EU authorized health and nutrition claims.
Nutriscore
(incl.
September
2019
modifications) with FEDIOL
for olive oils, nut proposal
oils and rapeseed
oils
Rapeseed oil
C
B
C
C
Sunflower oil*
D
High oleic sunflower oil*
C
C
Olive oil
C
B
C
B
Soybean oil*
D
Coconut oil
E
E
C
C
Corn oil*
D
Palm oil*
D
D
Walnut oil*
C
B
Butter
E
E
Lard
D
D
Linseed oil*
C
B
C
C
Grapeseed oil*
D
C
C
Sesam oil*
D
Avocado oil*
C
C
Peanut oil*
D
C
Camelina oil*
C
B
Mustard oil*
D
B
*It should be noted that the fatty acid profile of each oil naturally varies depending on their
botanical origin, as well as climate and environment. Instead of a fixed number, the Codex
alimentarius standard on named vegetable oils and fats provides for ranges. Depending on
the exact numbers used for the fatty acid profile of vegetable oils and fats, the rating can
vary and hence, change the scoring.
7
