REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL regarding the use of additional forms of expression and presentation of the nutrition declaration
Date: 2020-05-20
Institutions: Directorate-General for Health and Food Safety, European Commission
Subjects: EU Member State, consumer information, foodstuff, labelling, nutrition, product designation

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 20.5.2020  COM(2020) 207 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL regarding the use of additional forms of expression and presentation of the nutrition declaration    
 
 
TABLE OF CONTENTS 

1. 

2. 

3. 

3.1. 

3.2. 

3.3. 

4. 

4.1. 

4.2. 

Introduction .................................................................................................................. 2 

Historical background .................................................................................................. 2 

EU legal framework on front-of-pack nutrition labelling ............................................ 3 

Additional forms of expression and presentation under the FIC Regulation ............... 3 

Other front-of-pack nutrition labelling schemes .......................................................... 4 

Nutrient profiling ......................................................................................................... 4 

Front-of-pack schemes implemented or developed at EU-level .................................. 5 

Different formats of front-of-pack nutrition labelling schemes ................................... 5 

Front-of-pack schemes endorsed or under consideration by Member States and the 
United Kingdom ........................................................................................................... 5 

4.3. 

Front-of-pack schemes developed by EU private operators ........................................ 8 

5. 

6. 

7. 

8. 

8.1. 

8.2. 

8.3. 

8.4. 

9. 

Situation at international level ..................................................................................... 9 

Consumer interest, understanding and reaction and impact on health ....................... 10 

Impact on food business operators and on the internal market .................................. 13 

Positions and points of view ...................................................................................... 15 

Council, European Parliament and Committee of the Regions .................................. 15 

EU Member States' experts from national competent authorities .............................. 16 

Stakeholders ............................................................................................................... 17 

International organisations ......................................................................................... 17 

Conclusions ................................................................................................................ 18 

1 

 
 
 
 
 
 
1. 

INTRODUCTION 

This report responds to the obligation set for the Commission by Article 35(5) of Regulation 
(EU) No 1169/20111 on the provision of food information to consumers (the FIC Regulation). 
This provision requires the Commission to submit a report to the European Parliament and the 
Council  on  the  use  of  additional  forms  of  expression  and  presentation  of  the  nutrition 
declaration,  on  their  effect  on  the  internal  market  and  on  the  advisablility  of  further 
harmonisation of those forms. This provision also states that the Commission may accompany 
the report with proposals to modify the relevant Union provisions. 
As from December 2016, the FIC Regulation requires the vast majority of pre-packed foods2 
to  bear  a  nutrition  declaration,  often  provided  on  the  back  of  food  packaging,  to  allow 
consumers  to  make  informed  and  health-conscious  choices.  This  declaration  can  be 
complemented by a voluntary repetition of its main elements in the principal field of vision  
(known  as  the  ‘front-of-pack’),  in  order  to  help  consumers  to  see  at  a  glance  the  essential 
nutrition  information  when  purchasing  foods.  For  this  repetition,  other  forms  of  expression 
and/or presentation (e.g. graphical forms or symbols) can be used on the front-of-pack (FOP) 
in addition to those contained in the nutrition declaration (e.g. words or numbers).  

In  the  light  of  the  experience  gained  with  these  additional  forms  of  expression  and/or 
presentation of the nutrition declaration, the Commission was requested to adopt a report on 
their use and impact by 13 December 2017. Considering the limited experience in this area in 
the past years and some recent developments at national level, the adoption of the report was 
postponed  with  a  view  to  include  the  experience  with  recently  introduced  schemes.  The 
present  report  goes  beyond  the  scope  of  Article  35  of  the  FIC  Regulation  (i.e.,  additional 
forms  of  expression  and/or  presentation  repeating  the  information  provided  in  the  nutrition 
declaration)  and  includes  also  schemes  that  are  providing  information  on  the  FOP  on  the 
overall nutritional quality of foods, since such a differentiation would not be pertinent from a 
consumer’s perspective. 

This report presents the main FOP nutrition labelling schemes currently implemented or being 
developed at EU level, as well as some of the schemes implemented at international level. It 
also  addresses  consumer  understanding,  effectiveness  and  impacts  of  FOP  schemes.  This 
report  builds  upon  literature  reviews  and  data  gathered  and  analysed  by  the  Joint  Research 
Centre on the topic and extensive consultation carried out by the Commission with national 
competent authorities and relevant stakeholders. 

2. 

HISTORICAL BACKGROUND 

Under  the  Commission's  proposal  for  a  Regulation  on  food  information  to  consumers  laid 
down  in  January  20083,  food  business  operators  were  supposed  to  display,  on  a  mandatory 
basis, details about energy, fat, saturated fat, carbohydrates, sugar and salt on the FOP of pre-
packed processed foods. In addition, it was allowed to develop voluntary national schemes to 
declare these mandatory elements through other presentation formats (e.g. graphical forms).  

1   Regulation (EU) No 1169/2011 of the European Parliament and of the  Council of  25 October 2011 on the 

provision of food information to consumers, OJ L 304, 22.11.2011, p. 18. 

2    Foods which are exempted from the requirement of the mandatory nutrition declaration are listed in Annex V 

of Regulation No 1169/2011 
3    COM(2008) 40 final, Article 34 

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The  co-legislators  decided  to  keep  the  FOP  labelling  concept  but  to  remove  its  mandatory 
character.  They  agreed  that,  in  the  absence  of  a  FOP  nutritional  scheme  that  would  be 
understandable  and  acceptable  for  all  EU  consumers,  this  matter  should  be  left  to  Member 
States and food business operators to develop their own schemes, adapted to their consumers, 
provided  they  comply  with  certain  criteria.  The  aim  was  to  gather  experiences  on  the 
functioning  of  the  various  schemes  in  Member  States,  in  order  to  take  a  more  informed 
decision on possible further harmonisation at a later stage. Against this background, the FIC 
Regulation,  adopted  in  2011,  required  the  Commission  to  provide  the  present  report  on  the 
use and impact of the various schemes and on the advisability of further harmonisation.  

Given  the  increasing  rates  of  overweight  and  obesity  in  most  EU  Member  States  and  a 
substantial burden of diseases attributable to dietary risks4, the interest from public authorities 
in  FOP  nutrition  labelling  has  been  growing  since  the  adoption  of  the  FIC  Regulation.  The 
policy  objectives  of  FOP  labelling  are  typically  two-fold:  (1)  to  provide  additional 
information to consumers to inform healthier food choices and (2) to encourage food business 
operators  to  reformulate  products  towards  healthier  options  (Kanter  et  al.,  2018).  FOP 
labelling  is  therefore  increasingly  seen  as  a  tool  to  support  strategies5  for  the  prevention  of 
obesity and other diet-related non-communicable diseases. Today, several FOP schemes have 
been developed and implemented across the EU.   

3. 

1.1. 

EU LEGAL FRAMEWORK ON FRONT-OF-PACK NUTRITION LABELLING 

Additional forms of expression and presentation under the FIC Regulation  

The FIC Regulation allows, on a voluntary basis, the repetition of information provided in the 
nutrition declaration, i.e. the energy value alone or the energy value together with the amounts 
of fat,  saturates, sugars  and salt, on the FOP  (Article 30(3)). According to  Article 35 of the 
FIC Regulation, additional forms of expression and/or presentation of the nutrition declaration 
(e.g. graphical forms or symbols) can be used by food business operators or recommended by 
Member States, provided that they comply with the criteria set out in the Regulation.  

These  criteria  comprise  the  requirements  that  the  additional  forms  are  based  on  sound  and 
scientifically valid consumer research and do not mislead the consumer. The forms should be 
the  result  of  consultation  with  a  wide  range  of  stakeholder  groups,  must  be  aimed  at 
facilitating  consumer  understanding  of  the  contribution  or  importance  of  the  food  to  the 
energy and nutrient content of a diet and should be supported by scientific evidence showing 
that  they  are  understood  by  the  average  consumer.  In  addition,  the  forms  must  be  objective 

and 

4   Weight problems and obesity are increasing at a rapid rate in most of the EU Member States, with estimates 
of  51.6 %  of  the  EU’s  population  (18  and  over)  overweight  in  2014.  Obesity  is  a  serious  public  health 
problem,  as  it  significantly  increases  the  risk  of  chronic  diseases  such  as  cardiovascular  disease,  type-2 
diabetes 
(https://ec.europa.eu/eurostat/statistics-explained/index.php/ 
Overweight_and_obesity_-_BMI_statistics). More generally, it is estimated that in the European Union, over 
950,000 deaths and over 16 million years of life lost are  attributable to dietary risks due to unhealthy diets 
(https://ec.europa.eu/jrc/en/health-knowledge-gateway/societal-impacts/burden). 

cancers 

certain 

5   EU  Member  States  are  taking  various  approaches  (e.g.  reformulation  agreements,  marketing  restrictions  of 
foods high in fat, salt and sugar, public procurement of healthy food, taxing sugary drinks) as part of their 
strategies  on  health  promotion  and  disease  prevention.  The  European  Commission  is  supporting  Member 
States in actions on healthy lifestyles and healthy eating through the implementation of the 2007 EU Strategy 
on Nutrition, Overweight and Obesity-related Health Issues, the 2011 EU Framework for National Initiatives 
on Selected Nutrients (a 2008 reformulation framework had been agreed to reduce salt) and the EU Action 
Plan on Childhood Obesity 2014-2020. Promoting healthy lifestyles will help the Member States to reach the 
Sustainable  Development  Goals  by  2030  and  the  WHO  targets  on  non-communicable  diseases  by  2025. 
(https://ec.europa.eu/health/sites/health/files/nutrition_physical_activity/docs/2019_initiatives_npa_en.pdf) 

3 

 
 
                                                 
and non-discriminatory and must not create barriers to the free movement of goods. In case of 
other forms of expression, they should be based on harmonised reference intakes or generally 
accepted scientific advice on intakes. 

Member  States  are  required  to  monitor  the  use  of  any  additional  forms  of  expression  and 
presentation within their territory and submit this information to the Commission. To facilitate 
this monitoring, Member States can require food business operators, placing on the market in 
their territory  foods bearing such information,  to notify them  the use of  additional forms  of 
expression and/or presentation and to provide them with the relevant justifications  regarding 
the fulfilment of the requirements set in the EU legislation. 

1.2. 

Other front-of-pack nutrition labelling schemes 

Some FOP schemes developed by Member States or food business operators do not fall under 
Article 35 of the FIC Regulation since they do not repeat information provided in the nutrition 
declaration as such but provide information on the overall nutritional quality of the food (e.g. 
through  a  symbol  or  letter).  Such  schemes  are  considered  as  'voluntary  information'  under 
Article 36 of the FIC Regulation which shall not mislead the consumer, not be ambiguous or 
confusing for the consumer and shall, where appropriate, be based on the relevant scientific 
data.  At  the  same  time,  when  such  a  scheme  attributes  an  overall  positive  message  (for 
example through a green colour), it also fulfils the legal definition of a "nutrition claim"6 as it 
provides information on the beneficial nutritional quality of a food as defined in Regulation 
(EC)  No  1924/2006  on  nutrition  and  health  claims  made  on  foods7  (Claims  Regulation). 
According to the Claims Regulation, claims should be based on scientific evidence, shall not 
be misleading and are only permitted if the average consumer can be expected to understand 
the beneficial effects expressed by the claim. FOP schemes falling in the scope of the Claims 
Regulation can only be used in the territory of a Member State if they have been adopted by 
the  Member  State  in  question  in  accordance  with  Article  23  of  the  Claims  Regulation 
outlining the notification procedure to the Commission. 

1.3. 

Nutrient profiling 

Nutrient  profiling  is  the  categorisation  of  foods  according  to  their  nutritional  composition 
using  predefined  criteria8.  It  has  a  variety  of  applications  around  the  world,  for  example  to 
regulate  food  marketing  to  children.  A  common  use  of  nutrient  profiling  is  also  in  FOP 
nutrition  schemes.  Most  FOP  schemes  are  based  on  nutrient  profiling  criteria  that  may  be 
simple nutrient thresholds, for example to define when a scheme will attribute a green, amber 
or  red  colour,  or  more  complex  algorithms  that  result  in  a  summary  score.  The  nutrient 
profiling  criteria  can  be  applicable  to  all  food  groups  across  the  board,  or  be  specific  to 
different product groups. As such, nutrient profiling criteria do not appear on labels. 

In the EU, the notion of nutrient profiling is also used in the context of nutrition and health 
claims on food, where “nutrient profiles” are understood as thresholds of nutrients such as fat, 
salt  and  sugars  above  which  nutrition  and  health  claims  are  restricted  or  prohibited,  thus 
preventing a positive health message on food high in these nutrients. According to the Claims 
Regulation,  the  Commission  was  due  to  set  “nutrient  profiles”  by  2009,  but  these  profiles 
have  not  yet  been  established  given  the  high  controversy  of  the  topic,  which  was 

6   A nutrition claim states or suggests that a food has beneficial nutritional properties due to the energy the food 
provides,  the  nutrients  and  other  substances  the  food  contains  or  does  not  contain  (Article  2(2)(4)  of 
Regulation (EC) No 1924/2006 ) 

7   Regulation (EC) No 1924/2006 of the European Parliament and of the Council of 20 December 2006 on 

nutrition and health claims made on foods, OJ L 404, 30.12.2006, p.9. 

8    https://www.who.int/nutrition/topics/profiling/en/ 

4 

 
 
                                                 
demonstrated  by  divergent  and  polarized  views  in  2009  when  the  Commission  tried  to  set 
them. An evaluation of the Claims Regulation is focusing, amongst other issues, on nutrient 
profiling and more specifically on the question whether setting “nutrient profiles” aiming to 
avoid attractive claims on too salty, fatty or sweetened foods, are still fit for this purpose or if 
any alternative could be envisaged to reach the same objectives. 

4. 

1.4. 

FRONT-OF-PACK SCHEMES IMPLEMENTED OR DEVELOPED AT EU-LEVEL  

Different formats of front-of-pack nutrition labelling schemes 

In  the  1980s,  some  governments  started  to  develop  FOP  nutrition  labels  in  the  context  of 
strategies for the prevention of obesity and other diet-related non-communicable diseases. In 
the early 21st century, concomitant with the emerging global obesity epidemic and the greater 
abundance  of  processed  food  in  the  marketplace,  the  number  of  FOP  labelling  initiatives 
increased  steadily  (Kanter  et  al.,  2018).  FOP  nutrition  labelling  has  been  implemented  in 
many different ways and different formats are currently being used around the world. Various 
typologies  have  been  put  forward  in  the  literature  to  classify  these  formats  into  categories 
according to their main features.  

Schemes  can  be  divided  into  'nutrient-specific'  schemes,  providing  more  or  less  detailed 
nutritional  information  on  specific  nutrients,  and  'summary  indicator'  schemes  that  rather 
provide  a  synthetic  appreciation  of  the  product's  overall  nutritional  quality/healthfulness 
(Savoie et al., 2013). The 'nutrient-specific' category can be sub-divided into 'numerical' and 
'colour-coded'  sub-categories.  The  'summary  indicator'  schemes  can  be  sub-divided  into 
'positive'  indicators  (endorsement  logos)  that  can  be  applied  only  on  foods  complying  with 
certain  nutritional  criteria,  and  'graded'  indicators  that  are  providing  global  and  graded 
information on the nutritional quality of foods and can be applied on all food products (Julia 
& Hercberg, 2017). 

Another typology relates to the level of 'directiveness' of the scheme, in other words, to what 
extent the label provides a direct indication whether the product is nutritionally good for the 
consumer  or  not  (Hodgkins  et  al.,  2012).  Another  classification  includes  two  categories, 
'reductive'  schemes  (reduced  version  of  the  nutrition  information  contained  on  the  back-of-
pack)  and  'evaluative'  schemes  (evaluating  the  nutrition  information  for  the  consumer) 
(Newman et al., 2014). By definition, all evaluative FOP schemes, be they nutrient-specific or 
summary indicators, are based on nutrient profiling models.  

Table  1  classifies  the  public  schemes  (implemented  or  proposed)  and  some  of  the  private  
schemes  according  to  different  typologies  and  provides  also  information  on  their  developer 
and where the schemes are used or proposed/announced.  

1.5. 

Front-of-pack schemes endorsed or under consideration by Member States and 
the United Kingdom9 

Summary labels - Positive logos 

The  Keyhole  logo,  developed  by  the  Swedish  National  Food  Agency  and  introduced  in 
Sweden in 1989, was the first FOP logo system to be implemented in the EU. The Keyhole is 
a voluntary free-of-charge label in the form of a symbolic green representation that identifies 
the healthier choice within 33 defined food groups (e.g. bread, cheese, ready meals), based on 
nutritional criteria such as the level of fat, sugars, salt, wholegrain or fibre. The logo cannot 
be  used  on  products  that  have  a  low  nutritional  value,  such  as  salted  snacks  or  soft  drinks. 

9    The United Kingdom withdrew from the European Union and became a third country as of 1 February 2020. 

5 

 
 
                                                 
Denmark  and  Lithuania  introduced  the  Keyhole  label  respectively  in  2009  and  2013.  The 
label has also been adopted by non-EU countries (e.g. Norway, Iceland). 

6 

 
 
Table 1 – Typologies and formats of FOP nutrition labelling schemes implemented/proposed/announced at Member States’ and UK level 

Taxonomies put forward in the literature 

Examples of FOP schemes 

Developer 

EU Member State 

Nutrient-
specific 
labels 

Numerical 

Non-
directive 

Reductive   
(non-
interpretative) 

Reference Intakes label 

Private 

Across the EU 

NutrInform Battery 

Colour-
coded 

Semi-
directive 

Evaluative 
(interpretative) 

UK FOP label  

Public 

Public 

IT 

UK 

Summary 
labels 

Positive  
(endor-      
sement) 
logos 

Other 'traffic light' labels 

Private (retailers) 

PT, ES 

Directive 

Evaluative 
(interpretative) 

Keyhole   

Public 

SE, DK, LT 

Heart/Health logos 

NGO 

FI  SI   

Public 

HR 

Healthy Choice 

Private 

CZ, PL 

Phased out in NL 

Graded 
indicators 

Nutri-Score  

Public 

FR, BE 

ES, DE, NL, LU 

7 

 
 
 
 
 
 
 
 
 
 
 
 
 
Finland  endorsed  the  "Heart  Symbol  -  Better  choice"  in  2000.  The  criteria  for  using  the 
symbol (fat, salt, sugar and/or fibre content) are defined for nine main food groups. The right 
to  use  the  label  is  granted  by  experts  nominated  by  the  Finnish  Heart  and  Diabetes 
Associations and is subject to a charge10. 

In Slovenia, the 'Protective Food' (also called ‘Little Heart’) logo was introduced in 1992 by 
the  Society  of  Cardiovascular  Health11  and  promoted  by  the  government  (Miklavec  et  al., 
2016). It applies to pre-packed foods that meet specified nutrition criteria.  

As  part  of  the  2015  national  programme  'Healthy  Living',  the  Institute  for  Public  Health  of 
Croatia12 is mandated to grant the right to use the 'Healthy Living' logo on foods that meet  
specific nutrition criteria13.  

Summary labels - Graded indicators   

In October 2017, France adopted the Nutri-Score scheme after a series of experimental and 
large-scale studies.  Nutri-Score, based on the UK Food Standards Agency nutrient  profiling 
model, indicates the overall nutritional quality of a given food item. The label is represented 
by  a  scale  of  five  colours,  from  dark  green  indicating  food  products  with  the  highest 
nutritional quality to dark orange for products with lower nutritional quality, associated with 
letters from  A to  E. The algorithm  to  calculate the nutritional score considers both  negative 
(sugars,  saturated  fats,  salt  and  calories)  and  positive  elements  (protein,  fibre,  fruits, 
vegetables,  legumes  and  nuts).  Also  Belgium  adopted  Nutri-Score  (March  2019).  In  March 
2020, Germany notified to  the Commission  a draft national  regulation  on the use of Nutri-
Score.  Spain14  (November  2018),  the  Netherlands15  (November  2019)  and  Luxembourg16 
(February 2020) announced their decision to adopt the scheme.  

Nutrient-specific labels  

In January 2020,  Italy  notified to  the Commission a draft Decree recommending the use of 
the  voluntary  front-of-pack  scheme  ‘NutrInform  Battery’.  The  scheme  is  based  on  the 
Reference  Intakes  label  (described  below),  with  an  added  battery  symbol  indicating  the 
amounts  of  energy  and  nutrients  in  a  single  serving  as  percentage  of  the  daily  intake.  The 
scheme is not yet present on the EU market. 

In  2013,  the  United  Kingdom  formally  introduced  a  voluntary  FOP  scheme,  the  so-called 
'traffic light' scheme, after several years of research and stakeholder consultation. The scheme 
combines  colour-coding  and  percentage  reference  intakes17  and  is  supported  by  a  guide 
adopted by the UK authorities18.  It  provides information  on the content of fat,  saturated fat, 
sugars and salt, and the energy value by serving  or portion of the food. Colours are used to 
classify those nutrients as 'low' (green), 'medium' (amber) or 'high' (red); colour thresholds are 

10     Information provided by the Finnish Ministry of Agriculture (February 2017) 
11   Information provided by the Slovenian Ministry of Agriculture, Forestry and Food (February 2017) 
12   Information provided by the Croatian Ministry of Health (February 2017)   
13   https://www.hzjz.hr/wp-content/uploads/2015/06/Healthy-Living-Food-criteria.pdf 
14   https://www.lamoncloa.gob.es/serviciosdeprensa/notasprensa/sanidad/Paginas/2018/121118- 

premiosnaos.aspx 

15  https://www.rijksoverheid.nl/actueel/nieuws/2019/11/28/nutri-score-wordt-na-aanpassing-het-

voedselkeuzelogo-voor-nederland 

16  https://gouvernement.lu/fr/actualites/toutes_actualites/communiques/2020/02-fevrier/12-lenert-bilan.html 
17   Reference intakes (RIs) for energy and nutrients are maximum recommended daily intakes  
18  Guide to creating a front of pack (FoP) nutrition label for pre-packed products sold through retail outlet (last 
updated on 8 November 2016), available at https://www.gov.uk/government/publications/front-of-pack-
nutrition-labelling-guidance 

8 

 
 
                                                 
based on 100 g/ml of food/drinks (for products sold in large portions, portion thresholds apply 
for the red colour). 

1.6. 

Front-of-pack schemes developed by EU private operators 

Nutrient-specific labels 

Parallel to the government-endorsed schemes, the association of the European food and drink 
industry  developed  the  Guideline  Daily  Amounts  (GDA)  scheme,  later  renamed  Reference 
Intakes  label,  which  was  introduced  in  2006.  The  label  provides  numerical  information  on 
how  much  energy  and  nutrients  are  present  in  a  portion  of  a  food  and  how  much  this 
represents as a percentage of the daily reference intake19. The scheme is used across the EU 
(Storcksdieck genannt Bonsmann et al., 2010).   

Some retailers (e.g. in Portugal and Spain) developed their own FOP nutrition label based on 
a traffic light format that adds colours to the Reference Intakes label.  

In  2017,  six  multi-national  food  and  drink  companies  developed  the  'Evolved  Nutrition 
Label' (ENL), building on the Reference Intakes label and adding colours similar to the UK 
FOP  scheme  but  being  more  lenient  between  amber  and  red  for  products  considered  to  be 
consumed in small portions20. In November 2018, the companies communicated their decision 
to suspend/cease ENL label trials for food.  

Summary labels – Positive logos   

The  'Healthy  Choice'  ('tick')  logo,  owned  by  Choices  International  Foundation,  identifies 
healthier options within food groups. The category-specific criteria are based on the levels of 
saturated and trans fatty acids, added sugar, salt, dietary fibre and/or energy. The criteria are 
applicable  to  all  food  products,  including  snacks  and  soft  drinks.  Companies  paying  a 
membership fee to  the national  Choices organisation can  use the logo on eligible products. 
The scheme is in operation in the Czech Republic and in Poland. The logo was endorsed by 
the Dutch government in 2013 but withdrawn in 201721.  

19   Understanding the label. In: Reference Intakes [website], FoodDrinkEurope 

(https://referenceintakes.eu/understanding-label.html) 

20   Presentation six companies at EU Platform for action on diet and health, 30 November 2017, available at  
https://ec.europa.eu/health/sites/health/files/nutrition_physical_activity/docs/ev_20171130_co03_en.pdf. 

21   Communication Staatscourant Vinkje, 27 October 2017  (available at https://www.row-

minvws.nl/documenten/vergaderstukken/2017/10/27/mededeling-staatscourant-vinkje-row-del-27-oktober-
2017) 

9 

 
 
 
 
                                                 
5. 

SITUATION AT INTERNATIONAL LEVEL  

Currently  more  than  40  countries  around  the  globe  have  some  type  of  nutrition  labelling 
scheme on the front of food packaging in place22. 

While  most  third  countries  introduced  FOP  nutrition  labels  on  a  voluntary  basis,  some 
countries have made FOP labels mandatory. Overall, there is a tendency for countries within 
the same geographical region to pick similar labels, while adapting certain aspects to national 
circumstances23.  

Nutrient-specific traffic lights formats have been introduced beyond the UK by only a few 
countries  on  voluntary  (e.g.  South  Korea)  or  mandatory  (e.g.  Ecuador)  basis.  India  is  also 
considering a mandatory label24. 

A number of Asian countries (e.g. Malaysia, Singapore, Thailand) are using positive healthy 
choice logos with different formats and criteria (some are based on the Choices International 
criteria).  Some  African  (e.g.  Nigeria,  Zimbabwe)  countries  have  also  introduced  healthy 
choice logos. 

The graded Health Star Rating scheme is implemented in Australia and New Zealand and is 
a voluntary FOP scheme attributing to products from half a star up to five stars depending on 
the healthfulness defined by negative as well as positive nutrients and other components.  

The Chilean warning system, introduced in 2016, is a mandatory nutrient-based scheme that 
denotes  products  that  are  high  in  energy,  sugars,  saturated  fat  and/or  sodium.  Some  other 
South  American  countries  (e.g.  Brazil,  Peru,  Uruguay)  as  well  as  Canada  and  Israel  have 
developed or are developing similar alert schemes.  

The food and drink industry developed at international level different variants of the nutrient-
specific Reference Intakes scheme which are broadly used by companies worldwide. 

Figure 1 presents some examples of labels used on the front of food packaging, implemented 
outside the EU.  

Figure 1 – Examples of schemes used at international level

22    Preliminary Regulatory Impact Analysis Report on Nutrition Labeling, ANVISA (Brazil), May 2018 
23   Global Update on Nutrition Labelling - The 2018 edition, EUFIC, July 2018 
24   'Draft Food Safety and Standards (Labelling and Display) Regulations, 2019',  notified to the WTO 

Committee on Technical Barriers to Trade on 7 July 2019 

10 

 
 
 
                                                 
The  Codex  Alimentarius  Guidelines  on  Nutrition  Labelling25  provide  only  limited  guidance 
on  FOP  nutrition  labelling,  being  a  form  of  'supplementary  nutrition  information'.  The 
guidelines stipulate that this type of nutrition information should be intended to increase the 
consumer's  understanding  of  the  nutritional  value  of  the  food  and  assist  consumers  in 
interpreting the nutrient declaration. No specific guidelines on best practices for FOP nutrition 
labels  exist  at  international  level  and  a  variety  of  labels  have  been  developed.  Since  the 
proliferation of labels could create problems for international trade, the Codex Committee on 
Food  Labelling  agreed  in  October  2017  to  start  new  work  to  develop  guidelines  on  FOP 
labelling systems for governments wishing to implement this type of labelling, which would 
help  in  harmonisation  of  FOP  systems  and  thus  facilitate  international  trade26.  This  work  is 
ongoing27. 

6. 

CONSUMER INTEREST, UNDERSTANDING AND REACTION AND IMPACT ON HEALTH 

An  important  policy  objective  of  FOP  nutrition  labelling  is  to  help  consumers  to  make 
healthier  food  choices  (Kanter  et  al.,  2018).  Most  consumers  declare  indeed  that  they  find 
FOP labelling helpful (e.g. 71% of respondents in a Dutch consumer survey28 and 78% in a 
German consumer survey29). Evidence seems to suggest that FOP labels fill an informational 
gap or an unmet consumer need, with older and overweight/obese people more likely to report 
a need for a FOP label (Joint Research Centre, 2020). 

However,  whether  people  really  change  their  purchasing  behaviour  in  response  to  the 
presence of FOP labels depends on a range of factors. To be effective, a FOP label needs to 
attract  attention  and  then  be  accepted  and  understood  by  the  consumers  before  it  can 
potentially influence their food choices (Grunert & Wills, 2007) and consequently their diet 
and health. 

Consumer attention  

Before being able to accept and understand a FOP label, consumers need to pay attention to 
the labels in the first place. It has been shown that labels on the front of the package receive 
more attention than labels  on the back of  the package  (Becker et  al.,  2015). The number of 
consumers  declaring  that  they  look  at  FOP  labels  is  very  high  (e.g.  60%  in  a  study  with 
Belgian  consumers  (Möser  et  al.,  2010))  but  it  is  well-known  from  the  literature  that  self-
reported use of labels is higher than what has been concluded based on observational in-store 
studies (Grunert et al., 2010). 

Several main characteristics can increase attention to FOP nutrition labels. Larger label size 
helps to capture faster attention. Attention is also higher if there is less other information on 
the food package and when the type of label and its location on the package do not change. 
Colour seems  to  increase attention  as long  as contrast  between the label  and the package is 
achieved.  In  addition  to  specific  label  features,  attention  to  FOP  labelling  also  appears  to 
depend  on  consumer  characteristics  such  as  age,  education  level,  and  health  motivation. 

25   Codex Guidelines on nutrition labelling CAC/GL 2-1985, last revised in 2017 
26   Codex Alimentarius Commission, Report of the forty-fourth session of the Codex Committee on Food 

Labelling (REP18/FL), Paraguay, 16-20 October 2017 

27  The 45th Session of the Codex Committee on Food Labelling was held in May 2019.  
28    Consumentenbond, Consumer research on food choice logo's, April 2018, available at  

https://www.consumentenbond.nl/binaries/content/assets/cbhippowebsite/landingspaginas/acties/weet-wat-je-
eet/consumentenonderzoek-voedselkeuzelogos-nl.pdf 

29   Lebensmittelmarkt und Ernährungspolitik 2018, University Göttingen in cooperation with Zühlsdorf+Partner, 
January 2018 (Positive replies to question 'I find traffic light color-labelling on the front of packs helpful') 

11 

 
 
                                                 
Signposting in shopping aisles or the provision of an information leaflet can greatly improve 
attention. (Joint Research Centre, 2020) 

Consumer acceptance  

If labels are not accepted by the consumer, even though they are noticed, their message will 
be ignored. Attractiveness and liking seem to be important aspects for acceptability (Ducrot et 
al., 2015a).  

In  general,  consumers  prefer  labels  with  minimal  numerical  content  and  using  graphics  and 
symbols  (Campos  et  al.,  2011),  in  particular  consumers  of  lower  socio-economic  status 
(Méjean et al., 2013). Colour is also clearly identified as a relevant characteristic (Babio et al., 
2014). The level of directiveness of the FOP scheme also plays a role: some consumers like 
directive  labels  because  they  allow  for  a  quick  decision,  but  others  may  react  negatively  to 
being told something is ‘healthful’ in the absence of detailed nutritional information (Grunert 
&  Wills,  2007;  Hodgkins  et  al.,  2012).  Therefore,  some  researchers  suggest  that  a  scheme 
combining both directive and non-directive elements can be an effective format (Hodgkins et 
al., 2012).  

Another important aspect for acceptability is trust. Studies show that if a logo is endorsed by a 
credible  institution,  it  gives  consumers  greater  confidence  and  it  is  better  accepted  (De  la 
Cruz-Góngora et al., 2017).  

In  terms  of  FOP  schemes’  acceptability,  no  clear  frontrunner  emerges  from  the  literature. 
Rather, different studies show a preference for different schemes, due perhaps to the specific 
characteristics  of  the  labels  being  studied  or  to  cultural  differences  (Joint  Research  Centre, 
2020).  

The relevant literature shows that it is not because a label is the most preferred, that this label 
leads  to  the  best  objective  understanding  and  helps  the  consumer  the  best  to  identify  the 
healthier option (Ducrot et al., 2015b; Gregori et al., 2014). 

Consumer understanding 

It is clear from the literature that in an experimental setting most FOP nutrition labels have a 
positive effect on the ability of consumers to identify the healthier option compared to a no 
label  situation  (e.g.  Cecchini  and  Warin,  2016;  Roseman  et  al.,  2018;  Hawley  et  al.,  2013). 
The majority of studies suggest that evaluative schemes that use colour-coding, and especially 
colour-coding  combined  with  a  graded  indicator  according  to  a  recent  international  study 
(Egnell  et  all.,  2018c),  help  consumers  of  various  ages,  socio-economic  status,  and  cultural 
background  the  most  in  identifying  more  healthful  products  (Joint  Research  Centre,  2020; 
Egnell et al., 2018a; Ducrot et al., 2015a).  

When  colour-coded  nutrient-specific  labels  are  used  to  decide  between  the  healthfulness  of 
foods,  consumers  seem  to  find  it  more  important  to  avoid  reds  than  choosing  greens 
(Scarborough  et  al.,  2015).  Evaluative  schemes  seem  to  help  consumers  to  gauge  the 
healthfulness  of  products  better  than  reductive  schemes  (Joint  Research  Centre,  2020)  and  
seem  to  be  more  effective  than  reductive  labels  when  consumers  need  to  compare  products 
that are difficult to compare (Newman et al., 2018).  

Impact on purchasing behaviour 

Notwithstanding  the  extensive  studies  and  evidence  that  FOP  schemes  increase  the 
understanding of nutrition information, scientific studies that actually test whether FOP labels 
have  any  impact  on  consumers’  food  purchasing  decisions  are  much  rarer.  Most  studies 

12 

 
 
concern  surveys  or  experiments,  looking  at  the  intention  to  purchase  in  response  to  FOP 
labels, rather than at actual shopping behaviour in real situations30. 

Studies looking at the intention to purchase show that FOP labels can improve the nutritional 
quality  of  food  choices  and  shopping  baskets  (Joint  Research  Centre,  2020).  Comparative 
experimental  studies  give  insights  into  the  relative  effectiveness  of  different  labels  on 
purchasing  behaviour  but  very  few  of  these  studies  include  comparisons  across  countries, 
exploring the effect of cultural differences. Preliminary results  from  an international study31 
show  that  of  five  FOP  labels  tested32,  the  Nutri-Score  and  traffic  light  labels  produced  the 
most frequent and largest improvements in consumers' food choices towards healthier options 
across the different countries. 

Only few real-life studies on purchasing behaviour are available and evidence about the effect 
on actual shopping behaviour is difficult to obtain (Joint Research Centre, 2020). A possible 
reason  is  that  purchasing  decisions  are  influenced  by  a  multitude  of  factors  beyond  FOP 
labels,  including  price  (e.g.,  discounts),  expected  tastiness,  habits  etc.  (e.g.,  Grunert  et  al., 
2010; Boztuğ et al., 2015). Some real-life studies do confirm that evaluative FOP schemes can 
improve  the  nutritional  quality  of  food  choices;  schemes  with  colour-coding  and/or  with 
colour-coding in combination with a graded indicator appear most promising (Joint Research 
Centre, 2020). Several studies also show that the effect of FOP schemes can be substantial if 
their  introduction  is  combined  with  awareness  and/or  communication  campaigns  (e.g., 
Graham et al., 2017; Julia et al., 2016).  

There is also evidence showing that FOP schemes are effective in supporting “motivated”, i.e. 
health-conscious consumers (e.g. Finkelstein et al., 2018, Ni Mhurchu et al., 2018). The type 
of labelling scheme may influence the effect on purchasing behaviour depending on the type 
of  consumer:  evaluative  labels  seem  more  effective  on  hedonically  motivated  consumers, 
while  reductive  schemes  might  be  more  effective  on  health-motivated  consumers  (Hamlin, 
2015; Sanjari et al., 2017).  

The  food  category  also  seems  to  affect  the  FOP  labels’  effectiveness  (Ni  Mhurchu  et  al., 
2018;  Nikolova and Inman, 2014). For example, consumers are less likely to  read labels  on 
‘unhealthy’  foods  because  when  buying  such  foods  they  want  to  indulge  and  avoid 
discouraging information (Talati et al., 2016). FOP schemes may also have unintended effects 
on  purchases.  Some  studies  have  identified  a  change  in  purchasing  behaviour  due  to  the 
presence of a FOP label but without any association with the food healthfulness indicated by 
the scheme (Sacks et al., 2009; Hamlin, 2015; Hamlin and McNeill, 2016). 

Impact on diet and health 

To directly measure whether FOP schemes improve consumers' diet and health in real life, it 
would be necessary to observe their daily eating choices over the long term, and to assess the 
effect  of  FOP  schemes  on  health  in  a  randomized  controlled  trial  over  years.  Given  the 
difficulty to set up such studies and prove causality, there is not enough empirical evidence to 

30  Based on a meta-analysis of several experimental and real-life studies, Cecchini & Warin (2016) computed 
that FOP labelling would increase the number of people choosing a healthier food option by about 18% on 
average (ranging from 11% to 29% depending on the scheme). 

31   FOP-ICE  study  (Front-Of-Pack  International  Comparative  Experimental)    conducted  by  a  scientific 
consortium  from  Paris  13  University  (France)  and  Curtin  University  (Australia).  Nationally  representative 
samples recruited in Argentina, Australia, Bulgaria, Canada, Denmark, France, Germany, Mexico, Singapore, 
Spain, USA, and UK. 

32   Nutri-Score, traffic light label, Health Star Rating, Warning symbol and Reference Intakes label 

13 

 
 
                                                 
draw conclusions on the impact of FOP label use on the healthfulness of diets and on health 
itself (Cecchini and Warin, 2016; Hersey et al., 2013; Crocket et al., 2018).  

Instead, researchers use modelling approaches to extrapolate effects on purchasing behaviour 
to  overall  diet  and  diet-related  health  outcomes  (Joint  Research  Centre,  2020).  Modelled 
scenarios  of  replacing  commonly  consumed  foods  with  healthier  options,  as  identified  by 
evaluative FOP labels (based on nutrient profiling models), indicate potential reductions in the 
intake  of  calories  and  nutrients  of  public  health  concern  (e.g.  Amcoff  et  al.,  2015; 
Roodenburg et al., 2013; Cecchini & Warin, 2016). 

Some  studies  looking  at  associations  between  the  quality  of  diets  (of  volunteers)  and 
nutrition-related diseases, suggest that diet quality, evaluated by the dietary index underlying 
the Nutri-Score scheme, is associated with lower risk of cardio-vascular disease (Adriouch et 
al.,  2016  &  2017),  cancer  (Deschasaux  et  al.,  2018)  and  overweight  (Julia  et  al.,  2015). 
Another study, which involved five different FOP labels, concludes that FOP nutrition labels 
have  the  potential  to  help  decrease  mortality  from  diet-related  non-communicable  diseases, 
with effects depending on the type of label tested and Nutri-Score appearing the most efficient 
(Egnell et al., 2019). 

The  literature  also  points  to  some  potential  unintended  effects  of  labelling  on  the  diet.  For 
example,  perceiving  a  food  as  healthy  could  increase  intake  of  the  food  due  to  less  guilt 
(Chandon and Wansink 2007) and inappropriately large portion sizes may also result if a FOP 
label fails to signal limited healthfulness of the food (Egnell et al., 2018b).   

Other effects on the consumer 

Studies have shown that FOP schemes can increase the willingness of consumers to pay for 
healthier  products  (Joint  Research  Centre,  2020).  According  to  Crosetto  et  al.  (2018), 
nutritional  improvements  of  the  shopping  basket,  when  shopping  for  labelled  healthier 
products,  may  come  at  an  economic  cost,  but  low-income  households  seemed  the  least 
affected in terms of cost of nutritional improvements of the shopping basket. 

Consumer confusion and loss of trust is another aspect to consider. Literature reviews show 
the extent to which consumer confusion about labelling schemes constitutes a major obstacle 
to  their  adoption  and  effective  use  (Cowburn  &  Stockley,  2005;  Grunert  &  Wills,  2007). 
Consumer confusion might increase due to the coexistence of a range of FOP label formats in 
the market place (Harbaugh et al., 2011; Draper et al., 2013; Malam et al., 2009). Confusion 
might  also  emerge  from  the  fact  that  voluntary  schemes  do  not  require  FOP  labels  on  all 
packages,  which  may  bias  consumer  perceptions  towards  products  with  FOP  labels  that  are 
equally,  or  potentially  less,  healthful  than  products  with  no  labels  (Talati  et  al.,  2016). 
Research  also  reports  that  consumers  lose  trust  and  become  suspicious  of  a  label  when  an 
'unhealthy'  product  is  depicted  by  the  FOP  label  as  relatively  nutritious  (Harbaugh  et  al., 
2011).  

7. 

IMPACT ON FOOD BUSINESS OPERATORS AND ON THE INTERNAL MARKET 

FOP  labelling  schemes  can  affect  food  manufacturers,  and  food  suppliers  in  general,  in 
different  ways.  The  introduction  of  FOP  labels  can  be  an  incentive  for  companies  to 
reformulate  existing  and  develop  new  products  in  order  to  obtain  a  (more)  favourable  FOP 
label rating. Other issues linked to FOP labels, such as potential barriers to the free circulation 
of food products in the internal market, are also relevant to food suppliers.    

Impact on supply behaviour including reformulation and innovation 

14 

 
 
As long as FOP schemes may affect consumers' choices, producers have an incentive to adapt 
the  nutritional  composition  of  their  products  to  the  requirements  needed  to  obtain  a  (more) 
favourable  rating.  There  is  some  evidence  that  FOP  labels  actually  influence  product 
composition. For example, the adoption of the Healthy Choice logo in the Netherlands (Vyth 
et  al.,  2010), the Health Check Program33 symbol in Canada (Dummer et al., 2012) and the 
Health  Star  Rating  in  New  Zealand  (Ni  Mhurchu  et  al.,  2017)  are  reported  to  have  brought 
improvements in the nutrient profile of food products on the market. However, this evidence 
of  reformulation/innovation  is  largely  based  on  self-reported  data.  Scientific  studies  on  the 
impact of FOP labels on the development of more healthful products are scant, although some 
evidence exists on the role that voluntary FOP labels can play in attaining a market with more 
healthful  products  (e.g.  study  by  Liu  et  al.  (2015)  on  ready-to-eat  cereals).  A  reported 
potential risk associated with producers' response to FOP schemes is that reformulation occurs 
only  for  the  nutrients  that  are  included  in  the  FOP  scheme  (Vyth  et  al.,  2010;  Carter  et  al., 
2013). Attention should also be given to potential substitute ingredients so that any achieved 
reformulation also has the potential to confer a true public health benefit34.  

Reformulation  may  influence  taste  and  other  features  of  products,  which  could  lead  to  a 
decrease  in  demand  and  therefore  offset  potential  benefits  for  companies  of  a  better  FOP 
scheme  rating.  Manufacturers  will  thus  strategically  evaluate  the  benefits  of  nutrition-based 
product differentiation when they reformulate or introduce food innovations (Van Camp et al., 
2012).  

But even if manufacturers decide not to reformulate their products, or if they are not able to 
reformulate  their  products  due  to  specific  product  composition  or  standards35,  they  can  still 
choose to apply a voluntary FOP label, for example for reasons of transparency. This strategy 
can also be chosen by retailers (Machleit and Mantel, 2001) with a view to positively affect 
customers'  perceptions  of  the  retailer's  attention  to  their  health  (Newman  et  al.,  2014).  FOP 
labelling could also allow retailers to further differentiate private label products (sold under a 
retailer's brand name) from national brands. As shown in a study by Van Camp et al. (2012) 
in the UK, private label products were most likely to use FOP labels.  

Impact on SMEs  

Especially for SMEs, potential fees and/or certification procedures can be important barriers 
for  applying  FOP  labels.  Therefore,  some  of  the  schemes  are  specifically  designed  to 
encourage SME uptake (free of charge, no certification, data made available to proceed to the 
score calculation…). SMEs may find it more difficult to reformulate their products than larger 
companies  due  to  less  financial  and/or  human  resources,  although  it  has  to  be  noted  that 
continuous  product  improvement  is  only  partly  related  to  and  affected  by  FOP  labels.  With 
regard  to  positive  logos  (e.g.  Keyhole,  healthy  choice  logos),  smaller  producers  report  that 
they  appreciate the impact  that a well-known logo  can have on their own, less well known, 
brands and for raising their products’ quality and health image.36  

Impact on internal market 

33   Ended in 2014 
34   Transfatty acids in Europe: where do we stand?, JRC Science and Policy Report, 2014 
35   This can for example be the case for some agricultural products or foodstuffs which have been granted with a 

‘Geographical Indication’ under European Union law  (geographical indication includes protected 
geographical indication (PGI) and protected designation of origin (PDO), two quality schemes protecting the 
name of products which come from a specific region and follow a particular production process laid down in 
the product specifications). 

36   Case studies on Keyhole, Choices programme, UK FOP scheme and Nutri-Score conducted by external 

contractor in the context of the  Evaluation of Regulation (EC) No 1924/2006 

15 

 
 
                                                 
The  FIC  Regulation  provides,  as  one  of  the  requirements  for  FOP  schemes  developed  by 
Member  States  or  food  business  operators  under  Article  35,  that  their  application  does  not 
create  obstacles37  to  the  free  movement  of  goods  in  the  EU  internal  market.  The  same 
principle  applies  to  FOP  schemes  falling  within  other  regulatory  provisions  (see  section 
3.2)38.  

Some food manufacturers argue that  FOP  schemes recommended by  certain  Member  States  
could  have  an  impact  on  sales  of  specific  products  imported  from  other  Member  States,  or 
that some schemes, although voluntary, could become de facto compulsory due to pressure on 
food manufacturers to apply the recommended label. Official complaints have been received 
in this context in 2013 from economic operators against the UK traffic light scheme. So far, 
no  other  complaints  or  data  regarding  the  potential  impact  of  FOP  schemes  on  the  internal 
market have been received by the European Commission.  

The fact that a FOP scheme is recommended by a Member State could create expectations for 
consumers  that  food  products  marketed  in  that  country,  including  those  coming  from  other 
countries,  should  be  labelled  with  the  official  scheme.  This  could  imply  that  the  average 
consumer  gives  a  preference  to  products  labelled  with  the  official  scheme  compared  to 
products that are not labelled or that are labelled with other existing labels, and could create a 
pressure on EU food business operators to  label all products  present  on  the national  market 
with the official scheme promoted by the Member State.  

As  far  as  can  be  ascertained,  the  literature  is  silent  as  to  the  impact  of  the  FOP  labels 
introduced  in  the  EU  market  on  trade  between  Member  States  and/or  impact  on  sales  of 
imported  products.  Studies  regarding  the  impact  of  introducing  FOP  labels  on  purchasing 
decisions rather look at the impact on the nutritional quality of the purchased food than at the 
impact on sales of specific (imported) products.  

Finally,  a  potential  impact  could  be  caused  by  the  fact  that  different  FOP  schemes  are 
recommended by different  Member States, which can result in  additional labelling costs for 
food  business  operators  if  they  want  to  use  the  recommended  label  and  have  to  change  the 
packaging in function of the national market concerned.     

On the basis of the available information and studies and given the difficulty to collect data on 
any long-term impact of rather recently developed schemes, evidence that recommendations 
from  Member  States  to  use  a  specific  FOP  scheme  may  or  may  not  hamper  the  free 
circulation of food products, is so far limited and inconclusive. 

8. 

POSITIONS AND POINTS OF VIEW  

Council, European Parliament and Committee of the Regions 

1.7. 
In its conclusions39 adopted on 6 June 2017, the Council calls upon the Member States and the 
Commission to encourage voluntary labelling of foods, in accordance with the principles laid 
down in Regulation No 1169/2011, in particular of Article 35(1), to support all consumers, in 
particular  those  from  lower  socio-economic  groups,  into  choosing  healthy  options  and 
promote  education  and  information  campaigns  aimed  at  improving  consumer  understanding 

37   According to the settled case-law, an ‘obstacle’ is to be understood as those trading rules enacted by Member 

States which are capable of hindering, directly or indirectly, actually or potentially, intra-EU trade. 
38   Articles 34-35 of the Treaty on the Functioning of the European Union provide that national measures 

capable of hindering intra-EU trade are prohibited. 

39   Council conclusions to contribute towards halting the rise in Childhood Overweight and Obesity (2017), OJ 

OJ C205, 29.6.2017, p. 46–52 

16 

 
 
                                                 
of  food  information,  including  nutritional  labelling.  In  its  conclusions40  adopted  on  22  June 
2018, the Council invites the Commission to continue prioritising public health, in particular 
by addressing issues of cross-border importance such as, amongst others, food labelling, with 
the ultimate goal of improving health outcomes in the EU.   

Since  the  adoption  of  the  FIC  Regulation,  no  specific  resolution  from  the  European 
Parliament has been adopted on the topic of FOP labelling.  
In its opinion41 adopted on 4 July 2018, the European Committee of the Regions "calls on the 
European  Commission  to  propose,  after  examining  existing  food  labelling  systems,  a 
mandatory, single European colour labelling system, in which colours would be applied on a 
basis of 100 g units, on the front of food packaging throughout the EU, providing consumers 
with  clear  information  on  the  sugar,  salt  and  fat  content,  encouraging  healthier  eating 
patterns." 

1.8. 

EU Member States' experts from national competent authorities 

In the preparatory phase for this report, joint meetings between Member States' experts from 
the  national  competent  authorities,  stakeholders  and  the  Commission  were  organised  in  the 
course of 2018 to exchange on the issues covered by the report and collect data/information42. 

Experts  from  a  few  EU  national  competent  authorities  favoured  reductive  FOP  schemes 
providing nutrient-specific information, based on portion sizes, without evaluating foods and 
are  concerned  that  under  evaluative  FOP  schemes  some  traditional  products  and  regional 
specialities (e.g. cheeses, edible oils, meat products) might display labels that deter consumer 
purchase.  Experts  from  a  number  of  EU  national  competent  authorities,  including  countries 
where  evaluative  labels  are  already  in  operation,  favoured  evaluative  schemes  arguing  that 
such schemes are helping consumers make healthy food choices. Experts from other national 
competent authorities did not express any specific preference for reductive or evaluative FOP 
schemes.    

Experts  from  many  EU  national  competent  authorities  explicitly  expressed  their  support  for 
harmonisation  of  FOP  nutrition  labelling  across  the  EU  underlining  that  a  multitude  of 
schemes across the EU is confusing for the consumer and might lead to market fragmentation. 
In  general,  most  Member  States’  experts  agreed  that  any  scheme  should  build  on  extensive 
scientific  research,  with  demonstrated  evidence  of  the  scheme's  objective  understanding  by 
the consumer, taking different socio-economic groups into account. 
In 2014, a voluntary EU Action Plan on Childhood Obesity 2014 - 202043 was agreed at EU 
level  by  EU  government  representatives  referring  to  the  development  of  voluntary  food 
labelling schemes that are easy to understand for consumers.  

1.9. 

Stakeholders 

Consumer representatives and public health associations consider that FOP nutrition labelling 
can play a key role in helping consumers make more informed, healthier food choices. During 

40   Council conclusions on Healthy nutrition for children (2018), OJ C232, 03.07.2018, p. 1-8.   
41   Opinion of the European Committee of the Regions on local and regional incentives to promote healthy and 

sustainable diets (2018), OJ C387, 25.10.2018, p. 21-26. 

42   Summary of the meetings of 23 April, 22 June and 22 October 2018 available at 
https://ec.europa.eu/food/expert-groups/ag-ap/adv-grp_fchaph/wg_2018_en 

43   EU Action Plan on Childhood Obesity 2014-2020. Brussels: European Commission, updated July 2014. 

Available at 
https://ec.europa.eu/health/sites/health/files/nutrition_physical_activity/docs/childhoodobesity_actionplan_20
14_2020_en.pdf 

17 

 
 
                                                 
the  negotiations  of  the  FIC  Regulation,  they  supported  the  introduction  of  a  harmonised 
mandatory EU FOP scheme. They still favour a common approach for FOP nutrition labelling 
and  favourcolour-coded  FOP  nutrition  labelling44;  consumer  representatives  support  Nutri-
Score  in  particular45.  Associations  of  dietitians  have  a  similar  position  about  colour-coded 
schemes and are in favour of one single robust labelling scheme throughout the EU46.   

Back  in  2008  during  the  negotiations  of  the  FIC  Regulation,  the  European  food  and  drink 
industry  was  in  favour  of  voluntary  FOP  information  and  favoured  the  Guideline  Daily 
Amount (now Reference Intakes) scheme. Many sectors expressed in particular opposition to 
a FOP traffic light scheme, highlighting that such a scheme could confuse the consumer about 
the meaning of the colours and is too judgemental47. Today, some sectors are still opposed to 
colour-coded  schemes  for  the  same  reasons  and  in  particular  specific  sectors  dealing  with 
food  products  that  could  only  marginally  (if  at  all)  be  reformulated  (e.g.  meat  products)  in 
order  to  avoid  an  unfavourable  label.  Some  other  food  and  drink  companies  have  changed 
their position regarding colour-coded schemes and are applying colour-coded (nutriet-specific 
or  summary)  labels.  Also  several  retailers  are  currently  using  different  FOP  schemes, 
including colour-coded schemes, across the EU.  

EU  farmers  and  their  cooperatives  consider  that  providing  nutritional  information  enables 
consumers to adopt a healthier and more balanced diet. However, they oppose colour-coded 
schemes  focusing  only  on  negative  nutrients  since  they  consider  that  this  would  ignore  the 
overall  nutritional  contribution  of  agricultural  products  that  are  rich  in  essential  nutrients48. 
They are concerned that such schemes would have the effect of negatively highlighting some 
agricultural  products  that  cannot  be  easily  reformulated  because  of  their  compositional  or 
traditional characteristics. 

Many  stakeholders favour a harmonised approach on  FOP  nutrition  labelling across the EU 
and most stakeholders agree that any FOP scheme should be science- and evidence-based.  
A  European  Citizens’  Initiative49  ‘PRO-NUTRISCORE’  calling  on  the  Commission  ‘'to 
impose simplified Nutriscore labelling on food products’ was registered on 8 May 201950. 

1.10. 

International organisations  

The  Report  of  the  World  Health  Organisation  (WHO)  Commission  on  Ending  Childhood 
Obesity of March 201651 recommends to “implement interpretive FOP labelling supported by 
public education”. Its implementation plan of 2017 recommends further to "adopt, or develop 
as  necessary,  a  mandatory  interpretive  FOP  labelling  system  based  on  the  best  available 
evidence to identify the healthfulness of foods and beverages." In May 2019, WHO published 

44  https://www.beuc.eu/publications/beuc-x-2017-141_the_time_is_ripe_for_simplified_front-of-

pack_labelling_statement.pdf 

45   and http://www.beuc.eu/publications/new-european-commission-%E2%80%93-what-consumers-expect-

over-next-five-years/html  

46   Information provided by EFAD on 14 June 2018 
47   Summary of results for the consultation document on:“Labelling: competitiveness, consumer information and  

better regulation for the EU”, European Commission, December 2006 
(https://ec.europa.eu/food/sites/food/files/safety/docs/labelling-nutrition_better-reg_cons-summary.pdf) 

48   Information provided by Copa-Cogeca on 6 July 2018  
49   https://europa.eu/citizens-initiative/home_en 
50   Withdrawn in April 2020 
51   http://www.who.int/end-childhood-obesity/en/ 

18 

 
 
                                                 
its draft ‘Guiding principles and framework manual for front-of-pack labelling for promoting 
healthy diets’52. 

In  its  Food  and  Nutrition  Action  Plan  2015-2020,  WHO  Europe  calls  for  countries  to 
"increase  consumer-friendly  labelling  by  establishing  easy-to-understand  or  interpretative 
FOP labels that help consumers to identify healthier options". In its report from October 2018, 
WHO  Europe  further  highlights  that  FOP  schemes  providing  evaluative  judgements  about 
product unhealthfulness, which may also highlight ‘better-for-you’ choices, appear to be more 
effective  and  that  public  education  initiatives  are  important  to  improve  awareness  and 
understanding53.  
In  its  2017  Obesity  Update54,  the  Organization  of  Economic  Cooperation  and  Development 
(OECD) underlines that FOP labelling can help people to make healthier food choices and can 
motivate food manufacturers to reformulate products.  

9. 

CONCLUSIONS 

Front-of-pack  (FOP)  nutrition  labelling  aims  to  help  consumers  with  their  food  choices  by 
providing  at-a-glance  nutrition  information  and  is  increasingly  seen  as  a  tool  to  support 
strategies for the prevention of diet-related non-communicable diseases. 

Under the current EU rules, the indication of nutrition information on the FOP is possible on a 
voluntary basis in line with the requirements of Union law. A variety of FOP schemes have 
been  developed  by  public  institutions,  health  NGOs  and/or  private  sector.  Most  existing 
schemes are evaluative (interpretative) schemes that, be they nutrient-specific or summary 
indicators, are based on nutrient profiling models. 

The studies reviewed to elaborate this report confirm the potential of FOP schemes to help 
consumers make health-conscious food choices. Most consumers declare that they find FOP 
labels  helpful  and  look  at  the  labels  during  purchases,  even  though  the  percentage  of 
consumers  actually  doing  so  is  lower.  Studies  show  that  most  FOP  labels  have  a  positive 
effect  on  the  ability  of  consumers  to  identify  the  healthier  option  compared  to  a  no  label 
situation and that consumers’ understanding of FOP labels increases when the label features 
colour-coding, and especially when colours are combined with a summary indicator.  

As  regards  impact  on  purchasing  behaviour,  experimental  studies  looking  at  consumers’ 
intentions to purchase, show that FOP labels, especially colour-coded labels, can improve the 
healthfulness of consumers’ shopping baskets. Evidence from real-life (in store) studies about 
the effect on actual shopping behaviour is difficult to obtain as real-time purchasing decisions 
are  influenced  by  a  multitude  of  factors.  Some  studies  do  confirm  that  evaluative  FOP 
schemes using colour-coding and/or colour-coding in combination with a graded indicator can 
improve  the  nutritional  quality  of  food  choices  in  real-life.  Several  other  studies  also  show 
that  the  effect  of  a  FOP  scheme  can  be  substantial  if  its  introduction  is  combined  with 
awareness and/or communication campaigns.   

As regards potential impact of FOP labels on consumers’ diet and health, there is not enough 
empirical  evidence  to  draw  conclusions  but  modelling  studies  suggest  a  positive  effect,  in 
particular of evaluative labels. 

52   https://www.who.int/nutrition/publications/policies/guidingprinciples-labelling-promoting-healthydiet/en/ 
53   What is the evidence on the policy specifications, development processes and effectiveness of existing front-
of-pack food labelling policies in the WHO European Region? Copenhagen: WHO Regional Office for 
Europe; Kelly B., Jewell J., 2018 (Health Evidence Network (HEN) synthesis report 61). 

54   www.oecd.org/health/obesity-update.htm 

19 

 
 
                                                 
Regarding the potential impact of FOP schemes on food reformulation, a few studies, largely 
based  on  self-reported  data,  give  account  of  food  reformulation  allegedly  related  to 
evaluative FOP labels, although it must be noted that some agricultural food products cannot 
be easily reformulated due to their compositional or traditional characteristics. 

As regards the potential impact on the internal market, evidence, gained from the experience 
so far, that specific FOP schemes recommended by Member States or implemented by food 
business  operators  on  a  voluntary  basis  may  or  may  not  hamper  the  free  circulation  of 
products  in  the  EU  market,  is  limited  at  this  stage  and  inconclusive.  The  fact  that  a  FOP 
scheme is  recommended by a Member State could imply that the average consumer gives a 
preference  to  products  labelled  with  the  official  scheme  and  create  a  pressure  on  EU  food 
business  operators  to  label  all  products  present  on  the  national  market  with  the  officially 
promoted  scheme.  The  use  of  different  FOP  schemes  in  the  internal  market  could  result  in 
certain costs for businesses as well as consumer confusion and lack of trust. 

Views on FOP schemes – and on how they should (or not) be regulated upon – vary across 
Member States and stakeholder groups, with experts from several Member States, consumer 
organisations, health NGOs and some industry sectors in favour of schemes that evaluate the 
product's  nutritional  quality,  while  experts  from  a  few  Member  States  and  part  of  industry 
favour  reductive  (non-interpretative)  schemes.  Experts  from  many  EU  Member  States  and 
stakeholders favour a common harmonised approach, arguing that the co-existence of a range 
of FOP schemes in the EU market can lead to market fragmentation and consumer confusion.  

This report outlines the main issues to be considered as regards FOP nutrition labelling. One 
of the issues relates to nutrient profiling models, on which most FOP schemes are based. The 
concept  of  nutrient  profiling  is  also  used  by  EU  law  applicable  to  the  use  of  nutrition  and 
health  claims  made  on  food.  The  Staff  Working  Document  on  the  evaluation  of  the  Claims 
Regulation55 concludes that the specific objective pursued by the setting of nutrient profiles is 
still  pertinent  and  necessary  to  protect  the  consumer  by  limiting  the  use  of  claims  on  foods 
high in fat, sugars and salt content, as required by the legislation. 

Considering the strong link between nutrient profiling and FOP nutrition labelling, there 
could be possible synergies in reflecting on the two topics together. 
The  European  Green  Deal56  adopted  by  the  Commission  on  11  December  2019,  announces 
that a  Farm to  Fork Strategy57 will put  forward  actions  to  help  consumers choose healthy 
and sustainable diets. In particular, the Commission will explore new ways to give consumers 
better information on the nutritional value of foods. 

Given  this  political  priority,  the  above  elements  and  the  potential  of  FOP  schemes  to  help 
consumers  make  health-conscious  food  choices,  it  seems  appropriate  to  introduce  a 
harmonised  mandatory  FOP  nutrition  labelling  at  EU-level.  The  Commission  will  in  due 
course prepare a legislative proposal in line with the objectives of the Farm to Fork Strategy 
and with better regulation principles. 

55 SWD(2020) 95 
56 https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal_en 
57 COM(2020) 381 

20 

 
 
 
 
 
                                                 
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