The rights and wrongs of nutrition labelling

It appears that the confectionery industry generally prefers a common EU-wide system to national variants, such as the UK’s voluntary traffic lights labelling system that can cause unwanted difficulty for labelling. Nutritional labelling on chocolate, biscuits and sweets is present on most of these products already, said Laurence Vicca, communications and project manager of the Association of Chocolate, Biscuits and Confectionery Industries of Europe (Caobisco). She was speaking as the deadline to note nutrition declarations on energy value, fat, saturates, carbohydrates, sugars, protein and salt on food labels under the EU’s food information to consumers (FIC) regulation (1169/2011) draws nearer.

“Members that had put nutritional tables on their packs voluntarily before December 2014 already had to meet the new mandatory requirement before 13 December 2014, when the regulation came into force,” Vicca told Confectionery Production. “Only those that didn’t have nutritional information before FIC was published will have to comply before the end of this year – and the five-year transitional period left them time to do it.”

However, she said that any company that had not done so would find meeting the new labelling requirements tough, involving “huge financial costs as well as extensive bureaucratic requirements. Changing over to the new European labelling requirements of FIC proved to be a huge feat, especially for medium-sized companies. However, the industry mastered this task very well.”

One challenge has been putting all the necessary information on smaller packages – although those less than 24cm2 are exempt from the rule. “This limitation is taken into account in provisions on what information must be provided and in what font size. So members can provide more comprehensive nutrition information on websites, or via QR – quick reference – codes (smartphone readable, optical labels containing product information).” She said another complex issue for many small and medium-sized enterprises (SMEs) was to obtain the nutritional value of their products by analysing or calculating them from the official food composition table.

Above and beyond

Meanwhile, Mars, Nestlé and Mondelez International all told Confectionery Production their products complied with the new rule. “FIC requirements are welcome,” Vicca said. “Providing clear and fact-based nutrition information enables consumers to make informed dietary decisions.”

Indeed, some manufacturers already go above and beyond the EU-mandated minimum. As well as the mandatory nutrition table providing the content per 100g of energy in k-joules and k-calories, total fat, saturated fat, total carbohydrates, sugars and salt, “most Caobisco members give voluntary information to their consumers, such as energy per portion and percentage of reference intake (RI) for the different nutrients on the front-of-pack,” Vicca explained.

Industry association FoodDrinkEurope, that launched a website in 2014 to help consumers understand the new labelling rules, also emphasised “the vast majority of companies provide nutrition declarations” as well as voluntary information on reference intakes – “allowing the consumer to see directly the amount of energy or nutrient contained in the portion so you can consider it in the context of your daily diet.”

A Mars spokesperson said “We highlight allergens within the legal text by using bold font to make their presence clear and visible to the consumer.” Nestlé’s Bart Vandewaetere, head of relations with European institutions, spoke proudly of the Nestlé Nutritional Compass. As well as the standard nutrition box, this includes ‘good to remember’ information (eg cooking tips), ‘good to know’ data (additional information such as ‘no artificial colours’ and ‘no artificial preservatives’) and ‘good to talk’ (contact numbers and website) boxes.

“Nestlé places a high priority on providing consumers with information on which to make informed dietary choices,” said Vandewaetere. “To this end, a few years ago, we have introduced worldwide the Nutritional Compass which includes nutrient labelling to guide consumers on the path to nutrition health and wellness. This was displayed on 92.8% of our foods and beverages by the end of 2014.

“In this context, we were really prepared for the implementation of the mandatory labelling requirement. The nutritional information is already present in almost all our products and already provided in the format requested by the FIC.” Nestlé also provides ‘Guideline Daily Amount’ labelling on the front of pack “believing this provides consumers with factual and objective guidance on the daily intake of energy and key nutrients such as fat, sugars and salt/sodium per portion.”

Mondelez International told Confectionery Production that all its European products, including Cadbury, complied with the FIC regulation. In addition, its director for public affairs Francesco Tramontin said, “We provide front-of-pack calorie information for most of our products. Consumer research shows that calories/energy are a top item of interest for consumers.

“Furthermore we make nutrition claims such as reduced fat, light and sugar free and we have one proprietary health claim for our belVita biscuits.”

He welcomed the fact that the regulation created an EU harmonised system: “We believe that an industry-wide, uniform approach to front-of-pack labelling is one of the best ways to help consumers make informed choices,” Tramontin said.

Mixed opinion

But there is mixed opinion however on voluntary systems such as the UK’s ‘traffic light labelling’, where coloured labels at the front of the pack show at a glance if the food has low (green), medium (amber) or high (red) amounts of fat, saturated fat, sugars and salt. This system is voluntary but has been promoted by Britain’s Food Standards Agency (FSA) and is still present on 60% of products in the UK. Big name users include Mars and Nestlé, as well as Tesco, Sainsbury’s, Asda and Waitrose.

However, Mondelez, along with Coca-Cola, choose not to use it.

“We believe it does not adequately reflect better choices in many product categories or tell the whole story to consumers,” Tramontin emphasised. “Furthermore, we do not support labelling solutions for one European market only, as it could cause significant complexity and confusion for consumers.”

At an EU agriculture Council of Ministers meeting in Brussels in March, concerns were also raised over the system by a group of seven southern member states who said that it was a potential trade barrier and not, as the UK FSA proclaimed launching the scheme in June 2013, “a clear and consistent system to make healthier choices easier.”

Moreover, European meat processing industry organisation Clitravi has vehemently criticised such labelling, saying that if used universally, nearly all processed meat products imported into the UK, valued at around €1.5 billion in 2012, would carry the red label and lead to a 20 per cent reduction in sales, a potential €300 million loss per year. FoodDrinkEurope’s communications director Florence Ranson took a more measured view, pointing out that “mandatory traffic light labelling would not be allowed under the FIC regulation.”

What is more, the European Commission is examining whether the UK system is so specific that it breaks EU free trading rules, as Caobisco’s Vicca said, “It is up to the Commission to evaluate if and to what extent the traffic light system could create obstacles to trade. An infringement procedure is still open against the UK to this effect, but a final decision has not been taken.”

However, she explained that “voluntary, additional front-of-pack nutrition labelling systems are allowed under article 35 of FIC under certain conditions, including that they should not be discriminatory or create obstacles to trade.” This meant that it was up to individual Caobisco members to decide “if it is appropriate to use the traffic light labelling system on their products in one or more EU countries.”

In any case, “Caobisco products are normally consumed as ‘treats’, therefore in moderation, and consumers are fully aware of their sugar and fat content when they decide to purchase them,” Vicca made clear. “For our part, we ensure they find all the nutrition information they need to make informed choices and to advertise our products responsibly, particularly if children are involved.”

As for the fear of bearing a ‘red label’, she does not share Clitravi’s concerns, underlining “the UK traffic light is a nutrient-based informative system, not a global evaluation of the product, meaning that the ‘red label’ does not concern the overall product, but rather the levels of the individual nutrients it contains.”

A new approach by RSPH

Britain’s traffic light system is unlikely to be the only additional labelling appearing on EU confectionery – whether by a company’s choice or encouraged by national regulators. A good example of the former is Nestlé’s “green [wheat] symbol” showing “the importance of whole wheat in a balanced diet”. And only this week, the UK’s Royal Society for Public Health (RSPH) recommended a new ‘activity’ label featuring a running man with a number underneath, representing the amount of minutes needed to burn off the calories contained in the product.

“This labelling will immediately give people the information they need – so they might choose a banana instead of the muffin, if they know it will take them 48 minutes to walk it off,” RSPH chief executive Shirley Cramer told BBC Radio 4’s Today programme on 7 April.

Somewhat depressingly, given the industry’s efforts to inform the consumer, “Some people find nutrition labelling helpful, but almost half don’t as the information is very dense and most people only take six seconds looking at it,” Cramer said. “This label would be a very easy reference tool.”

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