Subject: 3295th meeting of the Competitiveness Council (Internal Market, Industry, Research and Space) – agenda point “Impact on the EU Acquis of "Hybrid" nutrition labelling system recommended in some Member States“ (namely, the UK voluntary nutrition labelling or ‘traffic light’ scheme)

Dear Attaché,

In light of the upcoming meeting of the Competitiveness Council on 20-21 February to debate the Italian delegation’s complaint regarding the impact of the United Kingdom’s voluntary colour-coded nutrition labelling scheme for processed food products and its EU acquis, the European Public Health Alliance (EPHA) – Europe’s leading NGO advocating for better health for all, would like to express its strong support and re-applaud the UK government for the decision taken as a part of their Public Health Responsibility Deal (1). We believe that the scheme provides an extremely efficient and easily understood element to help consumers make the healthiest choice.

According to current information, we see the scheme as being in compliance with all EU legislation, and the UK government has been monitoring the scheme’s implementation which presents no barriers to trade. Article 35 of the EU Regulation on the Provision of Food Information to Consumers (1169/2011) clearly states that “individual Member States and the industry are allowed to trial different schemes as there was no agreement on what worked best across the European Union.” (2). Of course, this is to be reviewed in 2017, by which time we are positive that the results will prove the scheme’s usefulness.

In 2012 those members of EPHA who had advocated for the traffic lights labelling scheme during the negotiations on the EU Regulation on Food Information to Consumers (which unfortunately failed to include the colour-coded scheme), welcomed the UK move and hope it will lead to other countries following suit. The use of colour-coding aims to interpret the levels of key nutrients in pre-processed food products and warns consumers against products with high fat, sugar or salt content. In our Position Paper on Food Labelling (3), EPHA outlined in detail the ’interpretative element’ rationale behind the proposal. The purpose of providing nutrition information is to allow consumers to make informed choices, however successive studies have indicated that consumers are not able to use the information correctly unless they are provided with an ‘interpretative element’ (4). Independent international research has also provided convincing evidence to suggest that consumers find the multiple colour coding ’traffic light system’ the easiest to understand. This makes it clear to consumers whether a product contains low, medium or high levels of a certain nutrient, and helps them to make choices both within and across food categories.

We are aware that this voluntary UK scheme has been met with criticism by some EU Member States, and challenged in front of the Council of the European Union (October and November 2013 sessions) on the grounds that it potentially discriminates against certain foods or categories of foods. We feel quite the contrary - the ‘traffic light system’ spotlights individual nutrients to give information to consumers to help them make an informed and honest assessment on how a given product contributes to their overall diet. The system would be particularly useful for interpreting the health risk of convenience foods, as this is where consumers have the most difficulty identifying healthier options. Consumers would benefit most from front-of-pack, at-a-glance information in a form of red, amber and green signs on convenience foods.

The public health community is extremely positive that the UK scheme will bring benefits to consumers and healthcare systems in the long term. The only drawback of the scheme is that it is voluntary and thus subject to self-regulation by industry. Furthermore, we hope that other EU Member States - where consumers still find it difficult to make easier, more informed and healthier choices, will follow this example.

We hope that by facilitating healthier choices for consumers, the burden of obesity, diet-related non-communicable diseases and health inequalities can be reduced across the European Union.

Yours sincerely,

Peggy Maguire

EPHA President

(1) UK Government Department of Health “Final design of consistent nutritional labelling system given green light”, available at https://www.gov.uk/government/news/final-design-of-consistent-nutritional-labelling-system-given-green-light

(2) Regulation on the Provision of Food Information to Consumers http://ec.europa.eu/food/food/labellingnutrition/foodlabelling/publications/proposal_regulation_ep_council.pdf

(3) EPHA Position Paper on Food Labelling (2009)

(4) Draper et al. (2011). Front-of-pack nutrition labelling: are multiple formats a problem for consumers? European Journal of Public Health, Available at http://eurpub.oxfordjournals.org/content/early/2011/12/02/eurpub.ckr144

Last modified on February 28 2014.