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Ahead of the meeting of the AGRIFISH Council on 19-20 October, EPHA has joined four European health organisations and two Members of European Parliament in writing to EU agriculture ministers to ask them to put health above commercial interests when discussing a future EU-wide front-of-pack (FOP) nutrition labelling system.


To: Ministers responsible for Agriculture, members of the AGRIFISH Council

Brussels, 15 October 2020

Dear Ministers,

Subject: Call for a mandatory EU-wide Front of Pack nutrition labelling system with a public health mindset

Ahead of the 19th and 20th October AGRIFISH Council meeting and future Council Conclusions on the topic, the undersigned organisations and Members of the European Parliament want to express their support for the adoption of a harmonised, interpretative and mandatory EU front-of-pack (FOP) nutrition labelling system and ask the Ministers responsible for Agriculture to put public health perspectives above trade considerations or regional/local business preferences. Indeed, public health is the very reason for the Commission’s decision to put forward a proposal by end 2022. The Commission states in the Farm to Fork Strategy that it will propose such a scheme “to enable consumers to make health conscious food choices”.

The adoption of a formal and comprehensive system provides a unique opportunity to fully empower consumers to make the choices that are best for them; while creating a healthier food environment, improving dietary patterns and promoting healthy lifestyles.

Poor nutrition is a major well-known risk factor for chronic (non-communicable) diseases (see annex below). A well-designed mandatory FOP nutrition labelling system has the potential to assist greatly in prevention and lowering the risk of developing chronic diseases and obesity, the prevalence of which is growing across Europe. Many European countries have seen a dramatic increase in the consumption of ultra-processed foods in recent decades, with research estimating that these food products contribute to up to half of total daily energy intake. In the EU, over 950,000 deaths and over 16 million Disability Adjusted Life Years (DALYs) – lost years of “healthy” life – are attributable to dietary risks due to unhealthy diets, including high intake of sugar, salt and saturated fats. FOP nutrition labelling systems are effective evidence-based policy tools to address these modifiable risk factors.

The COVID-19 pandemic has further outlined the vulnerability of people living with chronic diseases and the importance of prevention and early action frameworks, designed to identify people at risk and lower the risks associated with modifiable factors. It is more than ever essential to adopt a “health-in-all-policies” approach in areas that can benefit and promote Europeans’ health, including food and agriculture.

Recently, seven members states submitted a “non-paper” for consideration by the Council that raises serious concerns from a health perspective. We would like to point at the following principles that we believe should be cornerstones of the future system:

  • The future FOP labelling system should be mandatory for all EU member states.
  • Mandatory schemes are preferable as these will ensure that all food and (non-alcoholic) drinks are covered and, thus, are more likely to help reduce the risks associated with modifiable, diet-related, factors contributing to the onset of chronic diseases and its complications.
  • Beyond health considerations, there is a need for a harmonised scheme across Europe to provide citizens with the same level of information, regardless of their country of residence. Currently, over ten different FOP labelling schemes exist in the EU. Extensive evidence shows that the presence of different competing FOP schemes may impair consumer understanding.
  • Consumers have the rights to access nutrition information presented in an easy and transparent way. Moreover, from an internal market perspective this would also create a simplified operating environment for food manufacturers.
  • Interpretative FOP labels appear to be preferred to FOP informative labels. FOP endorsement logo schemes, some of which have been established for long, have a high-level of recognition and trust. Interpretative FOP labels will help consumers make informed and healthy food and drink choices: available research shows that the majority do not have the time nor knowledge to compare the information among different food products. Studies highlight that consumers – regardless of their age, cultural background or socio economic status – find traditional nutrition information on the back or side of the package difficult to read and to interpret, especially when there are many numerical and technical details. Further, evaluative schemes incentivise food reformulation.
  • Exemptions will undermine the aim of the system to be implemented uniformly and consistently. Further, specific types of foods such as foods for infants and young children should not be exempted. This is a crucial age of development where quality nutrition plays a great role in health and wellbeing and many risks associated with unhealthy diet begin in childhood. Allowing certain food producers and products to opt out of using such a label would prevent consumers from having a full overview and would confuse or mislead them about the healthfulness of products.
  • Uniform reference values (e.g. per 100g or ml) should be indicated for all products. Any change to this principle will not aid citizens who may have to make calculations to compare the nutritional quality of different products.
  • A thorough FOP labelling policy monitoring and evaluation programme should be put in place to assess implementation and impact, such as purchasing and consumption changes, nutritional knowledge in consumers and potential health benefits.

Health is a fundamental right embedded in EU treaties, and a collective responsibility within the European Union. It is the backbone of strong and sustainable economies and societies. We therefore count on you to adopt an approach for the EU front-of-pack labelling system that will ensure a high-level of protection for European citizens and provide for better public health.

Thank you in advance for your consideration. The undersigned remain willing to contribute and provide our expertise to the discussion.

Yours sincerely,

Biljana Borzan, Member of European Parliament (S&D, Croatia)
Sarah Wiener, Member of European Parliament (Greens/EFA, Austria)
Prof. Em. Raymond Vanholder, Acting Chairman, European Chronic Disease Alliance (ECDA)
Sascha Marschang, Acting Secretary General, European Public Health Alliance (EPHA)
Emma Woodford, Chief Operating Officer, European Oncology Nursing Society (EONS)
Marco Greco, President, European Patients Forum (EPF)
Dineke Zeegers Paget, Executive Director, European Public Health Association (EUPHA)