Brussels, 19 December 2022
Dear Executive Vice-President,
We the undersigned public health and consumer organisations are writing to you with regard to the upcoming proposal for the revision of the Food Information to Consumers Regulation. We would like to highlight our concerns regarding a potential delay for this important legislation as well as the debate around front-of-pack nutritional labelling becoming increasingly polarised and less grounded in scientific evidence or public health concerns.
As highlighted by the recent Health at a Glance: Europe 2022 report, over half of adults are now overweight or obese in most EU Member States, placing these citizens at significant risk for various non-communicable diseases such as diabetes, cardiovascular disease and certain cancers. At the same time, one in three children in the EU are already overweight or obese with the Covid pandemic exacerbating rates in some countries. Evidence has also shown that children from low-income households are much more likely to be living with obesity than those from high-income households.
It is clear that urgent action is required to halt and reverse these worrying trends. While no policy tool can solve the issue of unhealthy food environments by itself, front-of-pack nutritional labelling, underpinned by robust independent scientific evidence, is an intervention which has been clearly recognized by health experts as one which can tangibly help make the healthier choice the easier choice for consumers.
We, therefore, welcomed the European Commission’s commitment to the Farm to Fork Strategy to promote healthier and more sustainable diets, including by introducing a mandatory and harmonised front-of-pack nutrition label (FOPNL) by the end of 2022. Since the publication of the Strategy however, the debate on such labelling has regrettably moved beyond a discussion based on scientific evidence and we are concerned that the public health objectives of this tool are becoming increasingly overlooked.
We would like to underline that it is essential that any potential delays for the publication of the proposed FOPNL are kept to a minimum to ensure that we do not risk missing a rare and crucial opportunity to approve an EU-wide FOPNL during the current legislature. Furthermore, it is vital that the future EU FOPNL fulfils certain criteria which respond to the needs of the consumer and which is proven to steer shoppers towards healthier choices. It should; be mandatory, use interpretive colour-codes, be based on uniform reference amounts (100 g or 100 ml), allow consumers to compare products according to their amounts of critical nutrients notably saturated fat, sugars and salt and; be seen as a complementary tool to consumer education and dietary recommendations. We attach in annex further information on these key criteria.
We thank you in advance for considering our comments and remain at your disposal for any questions you may have.
This letter has also been sent to Commissioners Kyriakides and Wojciechowski.