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CIAA Position on Food information
15/05/2008 | Positions

Summary

CIAA welcomes EU harmonisation in relation to food information. We strongly believe that EU harmonisation is the only means to guarantee the single market and the free movement of goods whilst protecting the legitimate interests of producers and enabling consumers to make informed choices.

However, we do have some major concerns about the proposed National Schemes for achieving this (articles 37 to 47) and believe that it could, de facto, have an effect opposite to the one intended vis-à-vis the single European market and also potentially lead to the confusion of the consumer with various nutrition labelling schemes co-existing in the same Member State. Hence, we would rather favour a Regulation that goes for full harmonisation at the same time as providing more flexibility to operators particularly for the provision of additional voluntary information.

Nutrition Labelling

CIAA welcomes the recognition of its approach to nutrition labelling and in particular the Commission´s support of GDAs.

The efforts and achievements so far by industry should be encouraged. Thus, the implementation of the CIAA scheme should be encouraged by public authorities, notably through the adoption of a Regulation that is compatible with the implementation of the CIAA scheme.

Portion sizes are critical to improve consumer understanding and should be addressed appropriately by the Regulation based on propositions from industry.

A higher degree of flexibility is required to enable manufacturers to provide additional voluntary information.

CIAA would ask that a proportionate approach be taken to developing the legislation in this area. In particular, if mandatory nutrition labelling is adopted we believe such a requirement needs to consider the following:

• Legislation should always establish the minimum requirement;
• The energy content of foods and drinks is the most relevant nutrition information consumers are looking for on labels;
• Not all the other nutrients are relevant to all products;
• As the Commission’s recent White Paper articulated, the real issue of concern across the EU is growing levels of obesity, which means understanding the energy content of food and drinks will become the biggest issue for policy makers in the short term;
• EU-wide, most Member States have made little or no progress in developing nutrition labelling schemes;
• It takes account of the space constraints on smaller packs.

Eighteen months on from the adoption of the CIAA labelling scheme it is not surprising that different manufacturers are at different stages of implementation of the scheme, albeit all are aligned with regards to the route which they are following. Hence some, but not all, members support the principle of mandatory nutrition labelling compatible with the CIAA scheme. Others prefer that this should remain voluntary. Thus, taking into account the views of all of its members, it is not possible for the CIAA to express an opinion on mandatory versus voluntary nutrition labelling at this time.

Origin Labeling

Regarding the proposed origin labelling provisions, the key principle should remain not to mislead the consumer. Hence, there is no need for further legal requirements since law already requires origin labelling when the absence of such provision may mislead the consumer as to the true origin of the product. The same rule applies for the provision of information regarding the origin on a voluntary basis.

Clarity & Legibility of Labels

The implementation of the presentation of the mandatory particulars as proposed under article 14 of the proposed regulation is impractical and a disproportionate burden for manufacturers. To address both the issue of clarity/legibility of labels and the feasibility of any proposed approach, CIAA recommends the development of guidelines in this area. Such guidelines would not only be a more proportionate tool but also a more flexible tool enabling a case-by-case application.

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