The European Federation of the Associations of Dietitians
EFAD
Mission: To improve nutritional health and promote sustainable diets in Europe by advocating the leadership role for dietitians in collaboration with our members and stakeholders.
ID: 99138006725-91
Lobbying Activity
Response to Setting of nutrient profiles
2 Feb 2021
The European Federation of the Associations of Dietitians (EFAD) and the European Specialist Dietetic Network in Public Health welcomes the opportunity to contribute to these consultations.
We fully support the adoption of the Farm to Fork Strategy, as well the proposal for a harmonized mandatory front-of-pack nutrition labeling, the revision of the FIC Regulation and strongly recommend the involvement of public health dietitians in the process.
It is a fact that consumers find difficulties in making healthy choices because they do not always understand the nutritional information provided or due to the high exposure to unhealthy foods or misleading information, however, this could be partially biased or at least does not capture the totality of the problem, as the lack of food literacy is at the base of such decisions. http://www.efad.org/en-us/specialists-networks/public-health/papers/ Consumers might not need a vast knowledge on nutrients, but a few clear questions on healthy and sustainable food that gives them informed autonomy to achieve the highest level of health possible.
Proliferation of labelling schemes would hamper consumer understanding and would be a barrier to take responsible decisions for health. The harmonization of a Nutrient Profile Systems in EU could be a way to facilitate a meaningful and consistent labeling scheme across EU, which reinforces Art. 4 RE 1924/2006. EFAD policy paper on NPs http://www.efad.org/en-us/specialists-networks/public-health/papers/policy-paper-on-nutrient-profiling/
Considering that none of the FOP schemes is perfect, it is important to regulate to harmonize the use of FOP stablishing the basis, rather than opt for one in particular. Despite the pressure made by some actors a bold, evidence based and practical consensus is expected on this matter.
Origin labeling – our vision: sustainable food systems (less greenhouse gas emissions, plastics and pesticides, more efficient use of natural resources and fairer) and healthy food pattern (plant-based diets, more fresh and minimally processed food). Information on origin of foods should be mandatory to give as much information as possible. 1 EU/non-EU level; 2 national level; 3 regional level.
To improve the expression and presentation of date marking tailored to the languages and consumer understanding, however, lack of food literacy is a challenge for health and although labeling has a role to play it is not the cornerstone. Actions on food marketing, pricing, reformulation, nutrition education, etc., are key for coherent policies to promote healthy and sustainable food systems.
Economic impacts - there is strong evidence that dietary approaches can be equally effective in both the prevention and management of diseases and reduce economic costs to NHS. http://www.efad.org/en-us/reports-and-papers/efad-reports/efad-white-paper/
Social impacts – leverage the food supply chain and actions across sectors to ensure coherence with health and harness the power of other sectors to improve nutrition governance and policy coherence.
Environmental impacts - Despite the potential of reducing negative environmental impact of the food system, lack of food literacy is a challenge to shift consumer-eating habits toward healthier and more sustainable alternatives. Once again, Public health dietitians are uniquely qualified to provide advice to promote healthier and more sustainable lifestyles and food systems
We suggest to include the human rights impact assessment - access to safety and healthy food. Inequality must be taken into account, as well as considering all people living in poverty and it is of great importance to ensure that healthy foods are accessible and affordable, either using incentives and/or subsides as a way to contribute to solve it.
We agree with transitional measures whenever it’s possible, as long as a time limit is established for the fulfillment of all requirements.
Public Health ESDN on behalf of EFAD
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