26 Feb 2021
ICOS Submission on the EU Legislative Review on Food Information to Consumers
Within the context of the EU Farm to Fork Strategy, the European Commission is undergoing a review of Regulation 1169/2011 on food information to consumers.
The review includes a proposed revision of origin labelling rules for milk and milk ingredient products as well as meat ingredient products, the introduction of mandatory front of pack nutritional labelling, a revision of date marking rules and the establishment of nutrient profiles with a view to ensuring that products cannot promote misleading health and nutritional claims.
The first step in this review was the publication of an inception impact assessment, which outlined the different options being considered by the Commission, and sought stakeholder feedback on which options to pursue. ICOS provided feedback in this consultation, which you can read in full here. In it ICOS highlighted the following:
- Origin labelling: ICOS opposes the introduction of mandatory national origin labelling of dairy products and dairy ingredient products given it would create new barriers to trade within the EU Single Market and would give preferential treatment to domestically produced products. Additionally, despite the Commission’s aims it would not offer any additional advantages to consumers beyond the benefits already provided through the existing voluntary system, rather it would lead to increases costs for businesses, and consumers and limit options for innovation and product development. Finally, ICOS believes that it would fail in its objective to support sustainable production, rather it would promote national self-sufficiency over productivity. There is however a strong lobby from a number of large EU member states and a high level of pressure for some level of mandatory origin labelling for dairy products – with the possibility that at a minimum mandatory EU/non-EU will be introduced.
- Nutrient Labelling: ICOS believes that front of pack nutritional labelling, such as the traffic light system commonly used in Ireland, can lead to overly simplistic classification of foods being good or bad, while in reality all foods can be enjoyed as part of a healthy and sustainable diet. Existing systems fail to account for the full nutritional value of foods, specifically for the provision of fundamental vitamins, proteins and minerals, rather they focus on calories, fat, sugar and salt content. This is why a sugar free soft drink is awarded a higher score than a glass a milk according to the traffic light system or French nutri-score. Therefore, ICOS firmly believes at any EU scheme should be based on sound dietary guidelines to avoid the promotion of nutritionally deficient foods. Additionally, we do not believe that such labelling should be applied to single ingredient food products that are used as part of healthy cooking (such as butter, milk, cheese, meat etc), as the nutrient content of food changes during cooking and preparation. The best way forward, we believe is the development of endorsement logos, which could be applied to certain food product.
- Date Markings: ICOS supports the Commission proposal to improve the expression and presentation of date markings. Correct use of date marking by processors and in particular the understanding of terms by consumers is an important factor in managing food waste. We believe that more can be done to improve consumer awareness to improve effectiveness.
- Nutrient Profiles: The proposal from the Commission is to set maximum thresholds for specific nutrients such as fat, sugar, and salt, in order to ensure that product with health and nutrition claims are not misleading. However, ICOS is concerned that such an approach would favour highly processed food products, which can be easily reformulated or nutritionally deficient food products, over unprocessed foods.
A number of additional public consultations are expected on these elements in the coming weeks and will be followed by a legislative proposal by the end of 2022.
Alison Graham – European Affairs Executive