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EU: Revision to the Food Information to Consumers (FIC) Regulation

12/05/2022 - François-Xavier Branthôme
Front of Pack Nutrition Labeling (FOPNL), mention of place origin
For several years, supporters of the Nutri-Score and other front-of-pack nutrition labeling models, such as the NutrInform system promoted by Italy, have been fighting over the choice of a single, harmonized system at a European level.

In May 2020, a report on the use of complementary forms of expression and presentation of the nutrition information declaration was published by the European Commission in order to adopt, before the end of 2022, a mandatory nutrition logo on the front of foods, which would be applicable in all European countries. The goal was to have a unique and harmonized logo in Europe (since there are currently a large number of logos on the front of food at the European level).

 Since the publication of this report, press articles and arguments have appeared defending different viewpoints, most often based on technical arguments or the need to protect traditional products.  In March 2021, Nutri-Score advocates launched an appeal to the European Commission to adopt the Nutri-Score as soon as possible as a nutrition logo complementary to the nutrition declaration in a harmonized and mandatory way throughout Europe.

Italy is the main country opposed to the Nutri-Score, and has rallied to its cause other European countries such as Greece, the Czech Republic and Romania. It officially introduced its own front-of-pack labeling system for food in August: the NutrInform Battery.
Like the Nutri-Score, this system is voluntary for Italian food companies and proposes a logo that indicates the amount of energy, fat, saturated fatty acids, sugars and salt contained in a portion of product. The battery symbol indicates the percentage of energy and nutrients provided by a serving of product in relation to their daily nutritional recommendations.

Finally, it is important to note that within the countries that have adopted the Nutri-Score, there persist a number of divergences, particularly in Spain. Many Spanish food sectors are totally opposed to the Nutri-Score, especially those whose activity involves, as in Italy, traditional products (olive oil, hams, cheeses, etc.). These sectors have requested that the algorithm for calculating the Nutri-Score be adapted.

In February 2022, the Italian Ministry of Foreign Affairs and International Cooperation, in collaboration with Federalimentare (the Italian Federation of Food Industries), published a communiqué in which it explains how the NutrInform system is a guide for healthy eating.

Based on the need to fight against diet-related disorders at a global level and on Italian technical and cultural know-how in the field of food, the press release justifies and details the elements of the strategy carried by the NutrInform Battery system in terms of knowledge provided to consumers, assistance to choices and responsibility. The Ministry emphasizes the strengths of the Italian approach, particularly in solving some of the problems or shortcomings of competing systems, stating that the system "has been designed to focus on the balance of the overall diet and not on particular foods, with specific reference to the nutrients considered relevant by the World Health Organization." The official statement "stresses that the Italian system is linked to real consumption patterns such as portions and not to abstract parameters such as quantities (100 grams), which have a completely different effect depending on whether it is a food consumed in significant quantities (such as pizza), or a food normally consumed in very limited portions (such as olive oil). It is [...] a system that does not discriminate between products but indicates their calorie and nutrient content per serving, highlighting the impact on daily requirements according to the reference intake established by EFSA through the graphic symbol of the battery. The data expressed are purely objective." The press release from the Italian Ministry (see additional information at the end of this article) concludes by recalling that after having received a positive response from a representative sample of Italian families "the NutrInform battery, fully compliant with art. 35 of EU Regulation 1169/2011 on correct consumer information, has been approved by the European Commission and officially adopted as the Italian system from January 2021, [...] and can be identified as a useful, fair, educational, effective and adaptable system to the nutritional guidelines of all countries. »


In this tense environment, the European Commission on December 13, 2021, launched a public consultation period for the upcoming revision of the Food Information to Consumers (FIC) Regulation. The Commission was seeking views on different proposed changes to front-of-pack nutrition labeling, nutrient profiling criteria to restrict claims, place of origin labeling, date marking, and alcoholic beverages labeling. Stakeholders had until March 7, 2022, to comment.

Mindful of the principles of neutrality and objectivity, and respectful of the different opinions expressed within its membership, TomatoEurope Processors Association has not expressed an official position on the debate between the different front-end nutrition labeling systems, but has contributed to the consultation process set up at the European level for the revision of the FIC regulation (Consumer Nutritional Information). In the words of the European Association of Tomato Processing Industries, "regarding FOPNL, TomatoEurope supports the introduction of a common EU FOPNL scheme, so as to avoid any further proliferation of national labeling systems and to meet EU consumers' requests. However, TomatoEurope's intention is to endorse those schemes that are providing unbiased, complete and accurate nutritional information, based on portion size/serving, as opposed to those schemes that provide "ratings" to food or nutritional values per 100 grams of product, not considering the actual use/consumption of the food.

TomatoEurope is the European Organization of Tomato Industries representing the tomato processing industry from Italy, Spain, Portugal, Greece and France.
As for the required information mentioning the place of origin on product labels, ”TomatoEurope is supporting mandatory EU/non-EU origin labeling, allowing Member States to introduce voluntary country of origin indications.”
On this subject, TomatoEurope published in February 2022 its official position regarding mandatory origin labeling in the context of the revision of Regulation (EU) 1169/2011 on Food Information to Consumers.
"TomatoEurope is the European Organization of Tomato Industries representing the tomato processing industry from Italy, Spain, Portugal, Greece and France.

We would like to thank the Commission for the opportunity to provide comments regarding the revision of Regulation (EU) 1169/2011 and in particular on the possibility of introducing mandatory origin labeling for processed tomato products.

TomatoEurope is highly in favor of a mandatory EU/non-EU indication of origin based on the place of harvest of the tomatoes used in the products thereof, with the possibility for each Member State to further allow manufacturers to indicate also the country of origin on a voluntary basis.

Our industry firmly believes in the benefits of providing accurate, consistent and reliable information to consumers in the most transparent way, and strongly supports the mandatory indication of origin labeling.

Nevertheless, the EU tomato processing sector also stands for a harmonized system that could foster and sustain a common level playing field in the EU, while avoiding the risk to face market distortions or protectionism within the common market.

A EU/non-EU mandatory indication of origin would be able to safeguard and balance both interests: for the consumers, it is important to have information on the place of production where the primary ingredient has been cultivated, in order to be confident that the product has been made according to EU standards on food safety and in compliance with EU socio-environmental rules. In addition, the advantage of EU origin labeling is that it prevents fraudulent adulterations or unfair trade practices while allowing flexibility for the processors to use EU raw materials, without the need to change the label. More information on the specific country of origin may be given on a voluntary basis.

We hope that the introduction of mandatory EU/non-EU origin labeling could represent an important step towards a more integrated, more transparent and consistent legislative framework for the indication of the origin of processed tomato products to EU consumers

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