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L'Alliance 7

Etude et défense des intérêts matériels et moraux communs à l’ensemble des membres adhérents : - Syndicat du Chocolat - Confiseurs de France - Syndicat français du Café - Les Fabricants de Biscuits, Gâteaux et Panification de France - Syndicat du Thé et des Plantes à Infusion - Syndicat des Apéritifs à croquer - Syndicat national des Fruits Secs - Syndicat des Céréales du Petit-Déjeuner - Syndicat français de la Nutrition spécialisée, composé des secteurs des Aliments de l’enfance, de la Nutrition clinique et de la Nutrition Experte, Santé et Bien-Etre

Lobbying Activity

Response to Setting of nutrient profiles

25 Jan 2021

• Front-of pack nutrition labelling (FOP) & nutrient profiles (NP) SFNS supports science-based policy initiatives that aim to improve public health by promoting healthy nutrition & helping consumers understand nutrition labelling & make informed decisions. Foods covered by the specialised nutrition sector are tailor-made dietary solutions for populations with very specific nutritional needs including infants & young children, patients under medical supervision, sportspeople, overweight & obese consumers, & those suffering from coeliac disease. They are regulated with specific requirements on composition, labelling, hygiene, packaging, etc. These requirements are based on science, incl. the dietary recommendations of recognised authoritative scientific bodies. Therefore, SFNS supports a general exclusion for specialised nutrition from FOP schemes & NP developed for general foods (i.e., for population above 36 months). This includes the following product categories: Foods for Specific Groups (Regulation (EU) 609/2013); Meal Replacements for weight control (Regulation (EU) 2016/1413); Young child formulae; Foods intended for sportspeople. FOP schemes for general foods adopt calculation methods which are not suitable for specialised nutrition products, as they are developed for the healthy adult population. These schemes unjustifiably discriminate specialised nutrition foods: - They do not consider the ratio between macronutrients & micronutrient density. - Rate foods with a high fat content negatively. However, some specialised nutrition products, such as infant nutrition, have a fat content required by law, in adequacy with infants’ specific nutritional needs. - Ignore the reformulation constraints of gluten-free foods. - Some express a score per 100 grams of finished products, which is illogical for some specialised nutrition products as sports nutrition or slimming foods (formulation linked to the quantity of consumption recommanded by the manufacturer) • Origin Labelling SFNS remains fully committed to transparency, i.e., by providing origin information when relevant. SFNS considers that specific requirements currently in place provide sufficient information, & therefore support “Option O - Baseline (‘business as usual’)” for all specialised nutrition products. Specialised nutrition products contain several ingredients of both animal & non-animal origin to satisfy the nutritional needs of specific groups of consumers. There are various dairy ingredients added, e.g., skimmed milk powder, milk protein hydrolysate, whey protein concentrates or lactose. Consumer’s purchasing decision is likely not be substantially affected by the lack of origin indication for milk & milk ingredients in these foods. Moreover, specialised nutrition products have to display several additional particulars in addition to those required by FIC Regulation. Providing additional information could lead to an overload of information & could distract consumers’ attention from important information specific to specialised nutrition. Lastly, as for all products, it is important to accommodate flexibility to enable SFNS manufacturers to respond to unforeseen challenges due to fluctuations in seasonal availability, quality differences, costs, & sustainability of raw materials. • Date Marking Specialised nutrition products are nutrient-dense foods specifically formulated to respond to the needs of specific consumers. By their specific mandatory composition requirements, these products are usually fortified with vitamins & minerals, whose content can decrease over the product shelf-life. The ‘best before date’ is an essential element to ensure that specialised nutrition products contain a sufficient amount of nutrients along the shelf-life. SFNS is of the view that the current EU rules provide adequate quality and safety parameters for specialised nutrition products.
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