Brussels, 15th June 2006

Euro Coop is the European Community Of Consumer Cooperatives, Whose members are the national organisations of consumer cooperatives in 17 european countries. Created in 1957, Euro Coop today represents over 3,200 local and regional cooperatives, the members of which amount to more than 22 million consumers across Europe.

GENERAL COMMENTS

EURO COOP welcomes the initiative of the European Commission to review the current legal framework on labelling.

EURO COOP thinks that this stakeholder consultation is a key opportunity for rethinking product labelling in a 'consumer-friendly' manner. That means that labelling has to be first of all informative for consumers and provide them with those pieces of information that are essential to make informed choices. Other non-essential information can be always provided by food manufacturers directly on the pack, where space allows it, or via other communication channels such as customer lines, leaflets and information at the point of sale.

We should bear in mind that this consultation also represents an opportunity to make the current EU rules governing labelling more 'labeler-friendly'. Whatever framework will be developed, it is of utmost importance that it is practical and proportionate. In principle, the information to be put on the packaging should be readily available and not imply excessive costs for producers. In doing this, we can make sure that labelling rules will be appropriately implemented by all the manufacturers, including small and medium enterprises. Consumers, economic operators and, ultimately, the internal market will greatly benefit from this approach.

Regarding the approach that the EU legislator should take in regulating labelling, we think that a certain degree of flexibility should be ensured. This means that the EU institutions should avoid being overly prescriptive and rather try to strive a balance between mandatory rules and self-regulation initiatives. If everyone recognizes that it is necessary to have a mandatory framework for labelling, at the same time it is also crucial not to prevent food operators from providing consumers with additional information on a voluntary basis.

SCOPE

Overall, EURO COOP believes that food labelling should be dealt with separately from the labelling of other products. Regarding food labelling, we think that the future EU legal framework should be structured as a horizontal piece of legislation and containing the main requirements concerning labelling in a broad sense.

In our view, in fact, labelling is not only the information covered by the Directive 2000/13, but it is all that you can place on a packaging. In this sense, we welcome the importance that the Commission is attaching to nutrition information in the framework of this consultation. Nevertheless, we think that the proposed EU rules on health and nutrition claims and also the marketing directives for products such as eggs and poultry meat should be taken into account in the context of this review.

The remaining legislation may be contained in vertical regulations or directives.

NUTRITION LABELLING

EURO COOP thinks that the mounting public interest in nutrition and diet requires making nutrition labelling mandatory. As we have already pointed out on several occasions, EURO COOP member organizations think that on-pack information should be given to consumers with regard to the following nutrients and in the following order: calories, fat, of which saturates; salt; carbohydrates, of which sugar and, possibly, fibre.

EURO COOP agrees there may be room 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. Spices, tea, coffee and water are good examples along with vinegar.

As regards implementation of the new format, EURO COOP believes that a minimum period of three years would be necessary, a time which corresponds to the normal cycle of re-labelling products. Longer transitional periods might be considered for SMEs.

In addition, EURO COOP looks favorably at providing consumers with simplified nutrition messages i.e. food signposting. However, at this stage we think there is no actual need of a EU-wide scheme. Consumers' expectations in terms of nutrition greatly vary according to national, regional or even local cultures and dietary habits. We think that this variety needs to be respected at best. Against this background, therefore, we would be supportive of the development of voluntary government schemes or guidelines at national level in order to create a level-playing field amongst food operators and, ultimately, make sure consumers benefit from convergent and meaningful messages.

Overall, we think any food signposting, besides having to be based on sound consumer research, should comply with the commonly agreed principle according to which in nutrition there are no bad and good foods, but only bad and good diets. We would therefore look favorably at the development of signposting schemes that do not make inappropriate distinctions between good and bad foods, but rather provide consumers with objective information and, in so doing, enable them to make informed choices. For instance, our British member, the Co-operative Group UK, is intending to develop a signposting scheme on the front of the product, providing separate information on fat, satured fat, sugar and salt, but also using colour coding to indicate whether levels of these nutrients are high or low. We also think that the labelling of Guideline Daily Amounts (GDAs) for key nutrients, for instance, may be particularly effective in performing this task by allowing consumers to put a single food in the context of an overall diet.

ANIMAL WELFARE LABELLING

EURO COOP recognizes the importance of the political debate revolving around animal welfare. Nevertheless, EURO COOP member organizations do not see animal welfare as a priority issue within the present labelling review and perceive animal welfare-related messages as not being essential information to communicate to their consumers.

Against this background, EURO COOP believes that currently there is no need to establish a EU-wide labelling scheme for animal welfare. Should the proliferation of private labelling schemes have worrying consequences on consumer protection, the Commission may consider developing guidelines in this area. Nevertheless, we acknowledge that, before deploying any initiative in this field, more research is needed with a view to elaborating a trustable and scientific-based animal welfare measurement system.

HEALTH WARNINGS ON ALCOHOLIC BEVERAGES

EURO COOP recognizes the importance of providing consumers with advice about sensible consumption of alcohol. Some EURO COOP members already label their alcoholic beverages by informing consumers about the recommended daily intake or when it is necessary to moderate or avoid alcohol consumption (e.g. pregnancy, driving, operating machinery). Other consumer co-operatives are considering taking similar steps.

EURO COOP members believe that information about responsible drinking is useful to consumers, but, nevertheless, not essential. We therefore think that, where national rules do not provide for this particular labelling to be mandatory, food operators should be allowed providing it on a voluntary basis.

ORGANIC FARMING LABELLING

EURO COOP would like to draw the attention of the Commission services on the current review of the EU rules on organic farming. In this respect, EURO COOP thinks that the proposed label 'EU-organic' may risk being misleading to consumers.

With such a label consumers may be in fact led to think that a given product has been produced in Europe, whereas the organic label would be simply aimed at attesting the full compliance with EU rules. EURO COOP thinks that, in order to avoid conveying a misleading message to consumers of organic products, DG SANCO should better co-ordinate on this point with DG AGRI which leads the dossier.

FAIR TRADE LABELLING

EURO COOP should finally take this opportunity to recall that labelling is more and more used to communicate to consumers the compliance with core labor standards across the food production chain. EURO COOP attaches great importance to the promotion of fair trade products and, all over the time, has established a regular dialogue with the fair trade organizations and the relevant Commission's services.

As for animal welfare and food signposting, the need of a EU-wide scheme has been sometimes voiced. In this respect, EURO COOP and the fair trade movement both think that currently there is no need for such an action to be taken at EU-level. The existing labelling schemes, of private nature, have in fact proved to work in a transparent and accountable way and gained legitimacy in the eyes of consumers and national and European authorities. In this particular area EURO COOP therefore thinks that the EU institutions may play a greater role in monitoring the internal market and stopping abuses by those unscrupolous businesses that pretend to practice fair trade.

ECO-LABEL

The serious problems experienced by the "Flower" since its inception should be discussed in the framework of its ongoing revision. The number of eco-labeled products is still insignificant and in some Member States they can be bought in just a few outlets and the logo is unknown for consumers in most Member States. The result of this is that some national and regional initiatives such as the Nordic Swan and the Blue Angel are more popular that the eco-label.

The decision-making system needs to be improved. The current set up can create huge amounts of bureaucracy. It should be improved in order to include marketing and infomation oriented people and with a priority from the Commission on coordinated information campaigns.

It is hard for Consumers to know the difference in terms of respect of more strict environmental criteria about a product labeled at national level and an eco-labeled product. A platform to dialogue should be established in order to approach the basic requirements for eco-labeling.

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