European Ice Cream Association
Euroglaces
Euroglaces is the voice of the ice cream industry in Europe.
ID: 31013503339-49
Lobbying Activity
Response to Setting of nutrient profiles
1 Feb 2021
Euroglaces, representing the European ice cream manufacturing industry, welcomes the opportunity to provide comments on the Inception Impact Assessment (IIA) on the Proposal for a revision of Regulation (EU) No 1169/2011 on the provision of food information to consumers.
Complementary to the comments provided by our umbrella organization FoodDrinkEurope, Euroglaces wish to highlight in particular following ice cream specific input:
1) in relation to front-of-pack nutrition labelling (articles 30-35)
Euroglaces invites the European Commission to implement article 33(5) of Regulation (EU) N°1169/2011 and to allow front-of-pack nutrition declaration per portion for foods sold in pre-packed portions which are clearly recognizable as the consumption unit by themselves. For these categories of foods, the pre-packed portion is the amount of the food actually consumed by an individual in a single consumption occasion.
As most of the pre-packed portioned foods are not offered in exact 100g/ml quantities, the nutrition declaration per portion is the only meaningful information for consumers to make an accurate and informed purchasing choice. Even more, a front-of-pack nutrition labelling per 100g/ml on pre-packed portioned foods will mislead consumers.
Some typical examples of pre-packed single portions are ice cream cones, ice cream sticks, ice cream sandwiches. These products are normally sold in quantities ranging from 40g to 80g or 50ml to 120ml but hardly any product will be a portion of exactly of 100g/ml.
Therefore, Euroglaces asks the European Commission to introduce for pre-packed portioned foods the expression of front-of-pack nutritional labelling per portion, since this is the only option in line with article 35 (a) not to mislead consumers, and in line with article 35 (c) the most appropriate and legitimate way to facilitate consumers’ understanding of the nutritional value of the unit of consumption both at the time of purchase and when actually consuming it.
2) in relation to the interplay FOPNL/Nutrient Profiles
Euroglaces requests the European Commission not to consider nutrient profiles as a basis for front-of-pack nutrition labelling.
Both initiatives pursue different objectives: the specific objective pursued by nutrient profiles is to prevent a positive health message on foods high in fats, sugars and/or salt content, whilst the specific objective pursued by front-of-pack nutrition labelling is to improve consumers’ understanding of the nutritional value of foods when purchasing them.
Nutrient profiles are a tool to classify foods according to their composition in only certain nutrients in the legal context of restricting the use of nutrition and/or health claims on certain foods under Regulation (EC) 1924/2006. Nutrient profiles are not intended or suitable to inform consumers about the nutritional value of prepacked foods in the legal context of Regulation (EU) No 1169/2011 on the provision of food information to consumers.
If nutrient profiles would be used for front-of-pack nutritional labelling, it would introduce a classification of “good” versus “bad” foods that has no scientific basis and that is contradictory to the “objective and non-discriminatory” requirement set under Article 35 (f) of Regulation (EU) No 1169/2011.
Moreover, if nutrient profiles are used in a broader context than Regulation (EC) 1924/2006, there is the risk that nutrient profiles could be used by Member States to justify additional discriminatory measures against those foods that do not meet the criteria, in the form of food taxes or advertising restrictions, for example.
For all above reasons, Euroglaces requests the European Commission to consider the setting of nutrient profiles only under Regulation (EC) 1924/2006 which aims to restrict the promotion via nutrition or health claims of foods high in fat, sugars and salt, and not for underpinning front-of-pack nutrition labelling or other regulatory frameworks
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