EURO COOP, 20 February 2004

During the stakeholder meeting of 27 January 2004, interested parties were invited to submit written comments on a consultation document on nutrition labelling. As expressed in its contribution to the consultation launched by the Commission last year , EURO COOP strongly supports the move towards mandatory nutrition labelling, which in its view will further increase consumer protection. European consumer co-operatives consider the forthcoming Commission proposal both as a key piece of legislation in its own right and also complementary to the previous proposals on nutrition and health claims and the addition of nutrients to food. We should like to take this opportunity to thank you for consulting the stakeholders on this important piece of legislation and offer the following comments as a contribution to the debate.

1. Mandatory versus Voluntary Nutrition Labelling

EURO COOP supports mandatory nutrition labelling and agrees consideration should be given to making a list of elements/nutrients mandatory for all pre-packaged food, subject to appropriate transition periods and derogations.

EURO COOP welcomes the proposal to identify a "short" list of elements/nutrients for mandatory declaration. We support the list put forward by the Commission comprising: Energy, fat, saturates, carbohydrates, sugars and salt/sodium represents those elements/nutrients consistent with nutrition related public health messages and in the reduction of risk of chronic diseases, particularly cardiovascular disease and obesity. These are the appropriate criteria identified by the Commission and for these reasons also correspond closest to those elements/nutrients for which the majority of consumers most frequently seek information. All EURO COOP member organisations support omitting protein from the current formats on the basis that this allows greater flexibility; moreover, a shorter list is more practical. On fibre, however, consumer co-operatives in some Member States believe it should be optional, allowing selective declaration on these products where fibre is important, whereas others believe it should be in the core, mandatory list.

In addition, we would urge that, as noted by the Commission in the accompanying report, and also our own research, consideration be given to the use of the term "Calories" instead of "energy" and "salt" in place of "sodium" and that the declaration of energy as kJ (in addition to kcal) be abolished to better reflect and respond to consumer understanding.

In terms of presentation (see also below), consideration should additionally be given to a reordering of the list of elements/nutrients to give prominence to those of key importance to consumers, again in response to the criteria put forward by the Commission listed above. We would suggest the following order which accords with research conducted by one of our members:

• Calories :
• Fat:
• of which saturates:
• Salt:
• Carbohydrates:
• of which sugars:
• Fibre:

2. Additional Nutrients/Components that may be declared

EURO COOP agrees with the proposal to continue to allow the additional voluntary declaration of certain nutrients or components including protein and fibre, if these are excluded from the mandatory format.

We also support the retention of the obligation to declare in the nutrition labelling nutrients in respect of which a claim is made. The list needs amendment to recognise additional micronutrients as foreseen in the recent proposal on fortification.

3. Transitional Periods and Derogations

EURO COOP agrees there is a case for derogations for certain foods or categories of food which make little contribution to energy/nutrient intakes, but this should be limited to a small number of foods and specified by the Commission. Spices, tea, coffee and water are good examples along with vinegar.

As regards transition periods, our member organisations would like to see a minimum period of three years to implement the new format. This would allow consumer co-operatives achieve implementation within the normal cycle of re-labelling products.

4. Reference Quantity

From the point of view of consistency and minimising derogations from mandatory nutrition labelling, EURO COOP member organisations support mandatory nutrition labelling on a 100g/100ml basis. There should additionally be a recommendation to provide the information both on the basis of per 100g/100ml and per serving. The 100g/100ml is supported because it is more useful in comparing one product with another.

EURO COOP does not think it is appropriate nor, indeed, necessary to have standardised serving sizes as in the States. Firstly, consumer cooperatives consider that this would have only limited value with regard to products like mayonnaise, sugar, fat spreads, etc. where packs contain many portions whose size may vary widely. Secondly, our experience suggests that consumers relate best to the "descriptive" measures which allow them to relate to the food they eat. For example, it is more meaningful to consumers to relate to the whole pack or a fraction of it than to the weight of that portion. Similarly, where products are composed of a number of pieces, they relate to them, e.g. a cake or slice of ham. The actual weight of the servings should, of course, be stated in addition so consumers can compare with other products using different portion sizes.

5. Additional Technical Issues

1. Consumer Understanding

   As stated earlier, EURO COOP agrees that, in the interests of consumer understanding and clear consumer communication "salt" should replace "sodium" and "Calories" should replace "Energy". Furthermore, kilojoules should be abolished.

2. Absence of Legal Definition for all Nutrients
   

   EURO COOP agrees that there is a need for the Commission to specify methods of analysis and tolerances. In particular, a method of analysis is long-overdue for fibre. Standard methods of analysis are important if consumers are to be able to rely on information to compare products. Similarly, it would be useful to specify tolerances.

3. Modification/Updating of the List of Convention Factors

   EURO COOP is not in favour of introducing a plethora of different conversion factors, for example, for different types of protein. Whilst we accept that this is important where accuracy is required, this is not the case in providing on-pack consumer information. It implies a level of accuracy that does not exist due to product variations etc.

4. Rounding Rules

   In general EURO COOP supports rounding to whole numbers for all nutrients except salt (sodium) which it believes should be rounded to one decimal place. The rationale again is that declarations to more decimal places implies an accuracy which does not apply. Normal rounding rules should apply.

5. Declaration of Vitamin and Mineral Content

   EURO COOP would draw attention to the discrepancy in the proposal which would apply different rules to the declaration of vitamins and minerals in single portion/small packs than in packs comprising more than 100g/100ml. Whatever the rules, they should be consistent irrespective of pack size. Our preference would be for the declaration of minerals and vitamins to be based on serving size, i.e. 15% RDA to be provided in a serving. This is most appropriate if consumers are to be guaranteed products contain a meaningful/effective amount of the declared micronutrient.

6. Presentation of Nutrition Information and Nutrition Labelling Formats
   

   We agree there is scope for improving the format and layout of nutrition information to help consumer use and understanding. We believe there is already a significant body of consumer research, including that of the UK Government and Institute of Grocery Research Distribution - IGD - (see previous comments of March 2003) on which to at least make some preliminary proposal. This might prompt further research. We should however like to point-out that addressing this issue is long overdue. Furthermore, additional changes at a later date would only add further costs to labelling and further uncertainty and confusion rather than improving consumer understanding. We urge that these issues be resolved as quickly as possible and adopted at the same time as other issues mentioned in this document.