Euro Coop Feedback – Roadmap on the evaluation of Regulation (EC) No 1924/2006 with regards to nutrient profiles

Euro Coop Feedback – Roadmap on the evaluation of Regulation (EC) No 1924/2006 on nutrition and health claims made on food with regards to nutrient profiles 

Euro Coop welcomes the opportunity to comment on the Roadmap for the evaluation of Regulation (EC) No 1924/2006 on nutrition and health claims made on food with regards to nutrient profiles, which was published by the European Commission in October 2015.

Euro Coop deems that Regulation (EC) No 1924/2006 was a positive legislative development in terms of consumer information and market harmonization, by setting scientifically substantiated criteria for nutrition claims and a positive list of authorized health claims. However, Euro Coop is of the view that without nutrient profiles the work that has been carried out until now under this Regulation would not be complete.

Consumers shopping at consumer co-operatives have in the past expressed concerns regarding nutrition and health claims made on products that would otherwise be qualified as unhealthy. The example taken was that of a chocolate spread which was high in calcium, vitamins, and magnesium, but which was composed by 1/3 of fat and which contained high amounts of sugar. When asked, about half of these consumers (47%) wanted to ban claims from unhealthy products, while slightly less (45%) stated that if claims are to be allowed for calcium, vitamins, and/or magnesium on a product such as this, they should at least be balanced with clearly identifiable information related to the high levels of fat and sugar[1].

As per Article 4(1) of this Regulation, the Commission should have established nutrient profiles by the 19th of January 2009. Without nutrient profiles, the situation described in recital 11 of this Regulation is not avoided, i.e. nutrition or health claims may still mask the overall nutritional status of a food product, thus potentially misleading consumers when trying to make healthy choices in the context of a balanced diet.

In addition, Euro Coop members constantly promote healthy eating among their consumers. In order to distinguish between the healthy and unhealthy categories of foodstuffs, reference is made to members’ own healthy choices range or to nutrient profiling models used at national level (e.g. the UK Food Standards Agency nutrient profiling model developed for OFCOM, the broadcast regulator).

Euro Coop is in agreement with the consideration made in Recital 10 of this Regulation, namely that using criteria such as nutrient profiles at national level “is likely to result in barriers to intra-Community trade and should therefore be harmonised at Community level”.

Therefore, we deem EU harmonized nutrient profiles to be an essential legislative step to take in order to (1) guarantee consumer protection and their adequate information, and (2) avoid the existence of 28 different nutrient profile schemes which would represent an obstacle for the free movement of goods on the market. 

Euro Coop is a firm supporter of scientifically-substantiated policy decisions and therefore encourages the European Commission to liaise with the European Food Safety Authority (EFSA) if in need of scientific data when setting nutrient profiles. The nutrient profiles should in any case be set in a transparent way, in close collaboration with Member States and stakeholders.

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The paragraphs below provide feedback regarding the issues to be examined under point C2 of the roadmap.

Coherence/ Effectiveness/ Efficiency

Nutrition and health claims may be displayed on a voluntary basis on food products. The fact that nutrition and health claims are effectively displayed on foodstuffs shows that there is an incentive for Food Business Operators (FBOs) to do so. Nutrient profiles would only restrict the type of food product that claims could appear on, thus making sure that consumers are not misled by the healthiness of a certain product and do not risk overconsuming products high in salt, sugar and/or fat. In the context of the obesity epidemic and the continuous rise of related chronic diseases,FBOs have a social responsibility to be transparent as to the healthiness of the food products they put on the market.

Also, it would be interesting to assess the extent to which consumers are misled by nutritional and/or health claims related to a certain nutrient that has positive effects on health, and made on products which would otherwise be considered as unhealthy.

Relevance

The fact that the nutrition declaration will be mandatory as of December 2016 as per Regulation (EU) No 1169/2011 on the provision of food information to consumers is certainly welcome, but does not replace the need for nutrient profiles at EU level. Indeed, even with a nutrition declaration, FBOs would be able to display health claims on products that are high in salt, sugar, and/or saturated fats. Nutrient profiles are needed in order to prevent this practice.

EU added value

The EU added value is clearly that of a harmonised nutrient profiling system. The absence of such a harmonised system may have an impact on the movement of foodstuffs in the European market, with the same product potentially being allowed to carry a certain claim in one Member State but not in another.

For more information, please contact:

Silvia Schmidt, Policy Officer for Food and Retail

[email protected]

Tel: + 32 2 285 00 74

Fax: +32-2-231-07-57