Brussels, 14 June 2005

Dear Ms Sharma,

I am writing with reference to the draft opinion you circulated for comments amongst the members of the 'European Platform for Action on Diet, Physical Activity and Health' that was launched under the aegis of the European Commissioner for Health and Consumer Protection, Markos Kyprianou, on 15 March 2005.

As you know, EURO COOP - the European Community of Consumer Co-operatives - is a founding-member of the European Platform. By joining the Platform, EURO COOP member-organisations across Europe have engaged themselves to exchanging best practices and committing to action for the years to come in order to tackle the current obesity epidimic. We should like to take this occasion to provide you with some comments on your draft document.

Firstly, we would like to congratulate you for the effort and the enthusiasm you are putting in drafting an opinion on the problem of obesity. Overall, EURO COOP finds your draft opinion is a comprehensive document as it maps out in detail all the economic and social determinants that are conducive to the obesogenic environment Europe is currently experiencing. Accordingly, we believe that your document complements the founding text of the European Platform, which largely focus on the need for action by its signatories.

We certainly share your view on the need to involve and push to action as many segments of the society as possible i.e., governments and local authorities, industry, schools and health services, etc. Indeed, at this stage the stakeholder model is commonly regarded as the only viable approach to curbing rising obesity levels.

We also agree that the 'blame culture' should stop, as it turned out to be a sterile approach1. Rather, positive actions and messages, in addition to raising-awareness initiatives, should be encouraged at every layer of society.

A far-reaching policy context is needed

Reversing obesity trends will require long-term strategies and engagements as this process implies changing established daily lifestyles. A combination of measures and initiatives should be investigated by European and national decision-makers. At this stage, we believe that a coherent policy framework for nutrition and health should be developed. This policy framework could include and encourage self-regulation as well as legislation on a case-by-case basis.

Against this background, we find that some policy options should deserve particular attention. Education, for instance, is a key element on which public authorities and all those who are in contact with consumers (e.g. retailers, restaurants) need to focus in order to change current unhealthy lifestyles. Appropriate education with regard to the importance of eating healthily should therefore be offered at school and, hopefully, all over the life span. Indeed, parents also need to be informed constantly and to be more and more involved in educational programmes for adults in order to be aware of the properties of the food they buy their children2 .

The same degree of awareness should be reached across the general population with regard to the health benefits stemming from practicing sports. Measures to move people from sedentary behaviours to regular exercise have to be considered3.

Data show that obesity levels are worryingly high amongst the poorest. Again in this respect, education may play a crucial role. Education, however, should be coupled by measures favouring accessibility, availability and affordability of healthy foods. It would be wise if policy-makers looked into the feasibility of increasing the consumption of fruit and vegetables4 through ad hoc measures such as economic incentives and free distribution in the schools' canteens.

The above said policy framework would ideally be developed in a coherent fashion both at EU and national level. The European Platform is working as a catalyst for action and similar initiatives mirroring the Platform composition have been or are being set-up nationally. Certain Member States (e.g. Spain, Ireland and France) have already presented their action plans against obesity. The European Commission is expected to present its own strategy in a Green Paper later this year. Co-operation between the supranational and the national levels needs to be ensured at this stage in order not to undermine the effectiveness of the proposed actions.

The responsibility of the business sector

Making healthy dietary choices is not only a responsibility of individuals. It is widely recognized that economic operators such as food manufacturers and retailers may play a crucial role in influencing consumer choice, primarily through marketing and advertising tools.

a) Food industry

With specific regard to the food-manufacturing sector, EURO COOP recognises that many operators have started to take seriously the obesity epidemic and are voluntarily planning to innovate their nutrition policy with a range of activities, including reformulation of products and responsible marketing and advertising techniques. However, given the current obesity levels, self-regulation will probably not suffice to ensure that consumers are in a position to make informed healthy choice.

That is why proposals such as the EU regulation on nutrition and health claims on foodstuffs5 need to be firmly supported. The proposed regulation means harmonizing the use of certain nutrition and health claims across Europe and, by doing this, will avoid consumers being misled while shopping.

Additionally, the Commission and the Member States in the Council are of the view that only those foodstuffs that meet a 'desirable' nutrient profile should be allowed to bear nutrition or health claims. That would prevent, for instance, a breakfast-cereals producer from claiming that its product is rich in vitamins and minerals, while ignoring a high content of sugar and fats. EURO COOP believes that at this stage this is the only path to follow to avoid the scenario that yourself envisage in your opinion6 , i.e. that some industries may benefit from the growing consumers' interest in public health issues by using unsubstantiated claims as marketing tools.

EURO COOP would therefore invite you to include a reference to, and to express support for, such a proposal in your opinion. On the other hand, the European Commission itself looks at this regulation as a measure that is complementary to the actions taken by the Platform members. Likewise, if an adequate level of consumer protection is to be achieved, the development of scientific-based nutrient profiling as a pre-requisite to making a claim is an element of the proposal that cannot be neglected.

b) Retail sector

Reading through your document, we feel that most of the segments of the society that can play role in the obesity issue are fully covered except the retail sector.

Being consumer-owned retail organisations, EURO COOP member-organisations are aware of the role that the distribution sector can play in changing current unhealthy lifestyles. Retailer behaviour can be tremendously influential with regard to consumer choice as retailers are directly in contact with consumers and, therefore, an ideal dissemination channel of nutrition information e.g. via product labelling, magazines and in-store information points. Retailers also can play a crucial role vis-à-vis the composition of foods when they have their own product line. Finally, it is a fact that sometimes retailers, especially the biggest ones, may be able to exercise pressure on food manufacturers in order to offer their customers a range of products of better quality such as foods with reduced levels of fats, sugar and salt.

EURO COOP member-organisations are fully devoted to provide consumers with accurate, understandable and objective information. Across Europe our members label their food products with detailed nutritional information often going beyond what is required by law. The Co-op Group, EURO COOP British member, for instance, is using the graphical descriptors 'HIGH, MEDIUM, LOW' in reference to the content of sugar, fats and salt. Consumers may therefore easily understand to what extent a given food is unhealthy. We believe that this practice may represent a viable alternative to the 'traffic lights system' that is under development in some European countries (e.g. UK)7 and we would therefore invite you to take it into consideration amongst the best practices currently available.

In addition to the information tools, some EURO COOP members concentrate on educational programmes for schoolchildren. FDB, our Danish member, has been issuing teaching materials on healthy eating to distribute in schools for over 20 years. ANCC/Coop Italia, our Italian member, has likewise established a sound experience in organising training sessions for children in schools and in its outlets.

More details on the initiatives that our members carry-out at national level are included in the baseline activities' document EURO COOP submitted in the context of the European Platform for Action. The document is attached for your information.

Should you require further details on our activities as a background to the handbook of best practices you plan to compile over the summer, we would be very pleased to provide you with the necessary information. In this respect, please do not hesitate to contact Mr Francesco Montanari, EURO COOP Food Policy Officer (Tel. +32 (0)2 285 00 74, fmo@eurocoop.coop).

I should like take this opportunity to wish you every success for the forthcoming discussion of your opinion.

In the meanwhile, I remain at your entire disposal for any clarification you may need on the content of the present letter.

Yours sincerely,

Dónal Walshe

EURO COOP Secretary General

1. See paragraph 3.
2. See, for instance, paragraphs 2.3 and 5.4.2.
3. See, for instance, paragraphs 5.2.5, 5.3.1 and 5.6.2 respectively for the EU, the Member State and the local level.
4. See, for instance, paragraphs 5.2.7 and 5.3.1 respectively for the EU and the Member State-levels.
5. COM(424) 2003.
6. See paragraph 5.8.5.
7. See paragraph 5.8.3