Workshop on food information to consumers – Zagreb, Croatia, 3-4 December 2012
Guidance on Food Information to Consumers A European food and drink industry perspective on certain new food information requirements in the EU Dirk JACOBS Director
Consumer Information, Diet and Health Department
04/12/2012
Workshop on food information to consumers – Zagreb, Croatia, 3-4 December 2012
Agenda
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Introduction to FoodDrinkEurope The European food and drink industry
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FoodDrinkEurope Membership
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FoodDrinkEurope Structure General Assembly
Board Committee of Directors General (CDG)
LCCG/ Board Sherpas
Liaison Committee (LC)
Food & Consumer Policy Committee
Competitiveness Committee
Environmental Sustainability Committee
Communication Advisory Group
Expert Group
Expert Group
Expert Group
Expert Group
Ad Hoc Group
Ad Hoc Group
Ad Hoc Group
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Figures
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Regulation 1169/2011 Challenges for industry
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Industry welcomed the original objectives of the Regulation
Providing the consumer with factual information enabling an informed choice
Harmonisation
Improving consumer understanding
However‌
Removing the barriers to the Internal Market
Simplification
Decreasing the administrative burden for food business operators, particularly SMEs
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Political compromises had to be made‌ Pressure on EU Institutions
Package deals were made but
Some important decisions were postponed to a later stage E.g. report on trans fats
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Furthermore, many implementing measures have been included in the Regulation‌ Item
Obligation Deadline for EC?
EC to establish rules on the application of Art. 26.3 on the origin of primary ingredients
Yes
Within 2 years after the entry into force (Dec 2013)
EC to draft report on the mandatory indication of origin/provenance for meat used as an ingredient (Art. 26.) EC to draft (impact assessment) reports on the mandatory indication of origin/provenance for certain foods (Art. 26.) EC to draft report on trans fats (Art. 30.7)
Yes
Within 2 years after the entry into force (Dec 2013)
Yes
Within 3 years after the entry into force (Dec 2014)
Yes
Within 3 years after the entry into force (Dec 2014)
EC to establish rules for legibility
Yes
Not specified (however, expected by Dec 2014)
EC to establish rules on the expression per Yes portion/consumption unit for specific categories of foods
Not specified
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Furthermore, many implementing measures have been included in the Regulation‌ Item
Obligation for EC?
Deadline
EC to establish rules on (voluntary) reference intakes for specific population groups in addition to the adult reference intakes (Art. 36.3, Art. 43) EC to draft report on additional forms of expression/presentation EC to establish rules related to suitability of a food for vegetarians or vegans EC possibility to adopt rules regarding the energy value and amounts of nutrients which can be regarded as negligible EC possibility to adopt rules on the manner of indicating the date of minimum durability EC possibility to adopt rules on alternative expression by means of pictograms/symbols
Yes
Not specified
Yes Yes
Within 6 years after the entry into force (Dec 2017) Not specified
No
N/A
No
N/A
No
N/A
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Furthermore, many implementing measures have been included in the Regulation‌ Item
Obligation Deadline for EC?
EC possibility to establish a different expression of net quantity than in units of volume (for liquids) or in units of mass (for other) for certain specified foods EC possibility to adopt rules on expression of certain mandatory particulars by means other than on the package or on the label EC possibility to adopt rules regarding the manner of presenting the nutrition declaration (Art. 34.6) EC possibility to add or remove voluntary nutrients/nutrients to be repeated (Art. 30.6)
No
N/A
No
N/A
No
N/A
No
N/A
EC possibility to adopt conversion factors for vitamins and minerals
No
N/A
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Workshop on food information to consumers – Zagreb, Croatia, 3-4 December 2012
…and a Regulation which leaves many practical questions as to its interpretation…
Which legislation do I have to follow for my multi-lingual packs, marketed not only in EU member states but also in an EEA country, within the transition period?
What is precisely meant with “pre-packed for direct sale”?
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Hence, a Regulation far from finished‌ A Regulation far from finished Many implementing measures
Many interpretation issues
Uncertainty for companies
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Impact of new requirements on costs Some examples
Costs of adapting management systems Adaptation of packaging material in size or type as result of new additional information
Food business operator responsibility to update information on allergens, nutrient content, etc. to distance sellers via online databases??
Additional technical costs To ensure that declared values of nutrients in the mandatory nutrition declaration are correct and up to date (tolerances, rounding rules)
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Industry anticipation of new requirements Some examples
FoodDrinkEurope GDA Scheme
Mandatory Nutrition Labelling Position
Legibility Guidelines
Guidance on Portion Sizes
Position on tolerances
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Clarity needed…and not much time left…
New requirements
• Industry anticipated where it could (e.g. guidance on portion sizes, legibility, tolerances) • However, more than implementation only: additional management system costs, technical costs • Many implementing and interpretation issues still to be resolved • Additional burden on SMEs
Preparations will have to be made by manufacturers well in advance Therefore: clarity needed! (e.g. timing, process and content of the implementing measures, interpretation)
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Guidance on Food Information to Consumers
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FoodDrinkEurope’s approach
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Guidance for Food Business Operators - Objectives •
To provide a joint EU-wide understanding of the legal requirements of the Regulation across the European food and drink industry and beyond (e.g. retailers)
•
Mainly targeted at food business operators (especially SMEs) as well as national and European authorities
• The document is dynamic and will be updated on the basis of the outcome of discussions in the Commission Working Group on Regulation 1169/2011 on the provision of food information to consumers
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Guidance for Food Business Operators - Timeline End September 2011: Start of the work with prioritisation of the topics to be covered
October 2011 to January 2012: Discussions in 3 ad hoc expert meetings
3 February 2012: Finalisation of the first version
May 2012: Finalisation of the second version
March 2012 – April 2012: Further discussions in expert meetings
2 November 2012: Joint FoodDrinkEurope -EuroCommerce Guidance
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Guidance for Food Business Operators - Content
Nutrition Labelling
Origin Labelling
Legibility
Allergen Labelling
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Legibility
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Legibility - definition “ ‘legibility’ means the physical appearance of information, by means of which the information is visually accessible to the general population and which is determined by various elements, inter alia, font size, letter spacing, spacing between lines, stroke width, type colour, typeface, width- height ratio of the letters, the surface of the material and significant contrast between the print and the background”
Article 2.2m
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Legibility – general principles “Without prejudice to the national measures adopted under Article 44(2), mandatory food information shall be marked in a conspicuous place in such a way as to be easily visible, clearly legible and, where appropriate, indelible. It shall not in any way be hidden, obscured, detracted from or interrupted by any other written or pictorial matter or any other intervening material.”
Examples of how it should not be done: - backgrounds with noisy pictures; - stickers covering the mandatory declaration.
Article 13
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Legibility – general principles
Examples of use of colours, contrasts and visual background noise
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Legibility – rules (mandatory food information) • Minimum font size requirement for mandatory particulars under Art. 9.1 • 1.2 mm for packs with the largest surface 80 cm2 • 0.9 mm for packs with the largest surface < 80 cm2
• European Commission to establish detailed rules on legibility (other criteria) • FoodDrinkEurope has anticipated by providing Guidelines on Legibility
Article 13
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Legibility – mandatory particulars a) b) c)
d) e)
the name of the food; the list of ingredients; any ingredient or processing aid listed in Annex II or derived from a substance or product listed in Annex II causing allergies or intolerances used in the manufacture or preparation of a food and still present in the finished product, even if in an altered form; the quantity of certain ingredients or categories of ingredients; the net quantity of the food;
f) g) h)
i) j)
k)
l)
Article 9.1
the date of minimum durability or the ‘use by’ date; any special storage conditions and/or conditions of use; the name or business name and address of the food business operator referred to in Article 8(1); the country of origin or place of provenance where provided for in Article 26; instructions for use where it would be difficult to make appropriate use of the food in the absence of such instructions; with respect to beverages containing more than 1,2 % by volume of alcohol, the actual alcoholic strength by volume; a nutrition declaration.
Workshop on food information to consumers – Zagreb, Croatia, 3-4 December 2012
Legibility – other EU legislation •
Council Directive 76/211 on the making up by weight or by volume of certain prepackaged products (i.e. net quantity) provides specific rules for the font sizes of the nominal quantity (i.e. for the numerical value): -
not exceeding 50g/ml 50g/ml - 200g/ml 200g/ml - 1kg/l exceeding 1kg/l
2mm minimum* 3mm minimum* 4mm minimum* 6mm minimum*
* Figures referring to numerical height, not x-height. •
Other (vertical) EU legislation could stipulate some specific legibility principles/rules (e.g. the Chocolate Directive 2000/36/EC, fruits and vegetable sector Regulation 1580/2007, etc.)
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Legibility – specific rules and exemptions •
The name of the food, the net quantity and – where applicable – the actual alcoholic strength by volume (for >1.2% alcohol) must be provided together in the same field of vision • Exceptions: • •
•
Glass bottles intended for reuse which are indelibly marked and which therefore bear no label, ring or collar; Packaging or containers with a largest surface of less than 10 cm2
Limited information may be provided for: •
Packs with the largest surface < 25 cm2 and other categories under Annex V •
•
Beverages containing more than 1.2% alcohol • •
•
Exempted from nutrition declaration and list of ingredients However, report to be undertaken by the Commission
Packs with the largest surface < 10 cm2 •
•
Exempted from nutrition declaration
Only name of the food, possible allergens, net quantity and date of minimum durability
Glass bottles intended for reuse limited information may be provided •
Only name of the food, possible allergens, net quantity, date of minimum durability and nutrition declaration
Articles 13, 16, Annex V
Workshop on food information to consumers – Zagreb, Croatia, 3-4 December 2012
Legibility – “largest surface” • Definition of “largest surface” •
Pragmatic approach needed which facilitates readability of the information by the consumer, on the one hand, and the technical options of the manufacturer, on the other hand.
•
3 'categories‘ identified: • ‘Box‘ shape: largest surface bounded/limited by edges • Cylindrical/conical shape: curvature has to be taken into consideration when calculating the available area (can is approximately 1/3rd of the total surface) • Other shapes: case-by-case basis
•
In any case, food business operator should ensure that the mandatory food information that is provided is clearly legible and easily accessible for the consumer.
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Legibility â&#x20AC;&#x201C; rules (voluntary food information)
Voluntary information not to be displayed to the detriment of the space available for mandatory information
Article 36
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Legibility – FoodDrinkEurope guidelines • Specific guidance on legibility for manufacturers and enforcement authorities to ensure that all on-pack information is legible
• Code is not intended to be a substitute for legislation but aims to help compliance with the legal requirement to provide legible information by addressing the key factors that determine legibility • Increasing importance for alternative means of communication of food information (e.g. smart phones, websites, social media, etc.) – it is not only the label!
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Legibility â&#x20AC;&#x201C; FoodDrinkEurope guidelines Same font size (6 pt) in relation with different typefaces x-height
FONT SIZE
Arial Narrow
6 pt
Ingredient x
1.098 mm
Avant Garde
Aldus
Ingredient x
Ingredient x
1.157 mm
0.924 mm
Same x-height (1.2 mm) in relation with different typefaces font sizes X-HEIGHT
Arial Narrow
1.2 mm
Ingredient x
6.672 pt
Avant Garde
Times New Roman
Ingredient x
Ingredient x
6.252 pt
7.992 pt
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Legibility â&#x20AC;&#x201C; FoodDrinkEurope guidelines
Examples of character spacing
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Nutrition Labelling
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Nutrition Labelling â&#x20AC;&#x201C; current rules (summary)
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Nutrition Labelling â&#x20AC;&#x201C; new rules (summary)
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Nutrition Labelling – exemptions (i) • Unprocessed products that comprise a single ingredient or category of ingredients; • Processed products which the only processing they have been subjected to is maturing and that comprise a single ingredient or category of ingredients; • Waters intended for human consumption, including those where the only added ingredients are carbon dioxide and/or flavourings; • A herb, a spice or mixtures thereof; • Salt and salt substitutes; • Table top sweeteners; • Products covered by Directive 1999/4/EC of the European Parliament and of the Council of 22 February 1999 relating to coffee extracts and chicory extracts ( 1 ), whole or milled coffee beans and whole or milled decaffeinated coffee beans; • Herbal and fruit infusions, tea, decaffeinated tea, instant or soluble tea or tea extract, decaffeinated instant or soluble tea or tea extract, which do not contain other added ingredients than flavourings which do not modify the nutritional value of the tea; • Fermented vinegars and substitutes for vinegar, including those where the only added ingredients are flavourings;
Annex V
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Nutrition Labelling – exemptions (ii) • • • • • • • • • •
Flavourings; Food additives; Processing aids; Food enzymes; Gelatine; Jam setting compounds; Yeast; Chewing-gums; Food in packaging or containers the largest surface of which has an area of less than 25 cm2; Food, including handcrafted food, directly supplied by the manufacturer of small quantities of products to the final consumer or to local retail establishments directly supplying the final consumer. • Beverages containing more than 1.2% alcohol • Food supplements falling into the scope of Directive 2002/46/EC • Natural mineral waters falling into the scope of Directive 2009/59/EC
N.B. the exemption does not apply when making a nutrition or health claim or when adding vitamins or minerals to the food or drinks!
Annex V
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Nutrition Labelling – bases for declaring nutrient values
Declared values shall, according to the individual case, be average values based on: a) the manufacturer’s analysis of the food; b) a calculation from the known or actual average values of the ingredients used; or c) a calculation from generally established and accepted data (e.g. Eurofir) EU Guidance with regard to the setting of tolerances and rounding rules for nutrient declaration
Article 31
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Nutrition Labelling – ‘back of pack’ Energy Fat Of which: Saturates mono-unsaturates polyunsaturates Carbohydrate
Nutrition information Per 100g Per Portion(/ (/Per 100ml) Per Unit) kJ/kcal kJ/kcal g g
% reference intake (GDA)* % %
g
g
%
g1 g1 g
g g g
%
g g1 g1 g1 g g
g g g g g g
Of which: Sugars Polyols Starch Fibre Protein Salt
%
% %
* GDA = Reference intake of an average adult (8400kJ/2000Kcal)
Vitamins and minerals
Article 30
Per 100g (/per 100ml) Units mentioned in Annex XIII and % NRVs
Per Portion (/per unit) Units mentioned in Annex XIII and % NRVs
% reference intake (NRV) % NRV per 100g (and/or per portion)
Mandatory Voluntary
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Nutrition Labelling – ‘front-of-pack’ (repetition) Two options for voluntary repetition:
or
It is not possible to provide on the ‘front of pack’ nutrition information for nutrients other than those mentioned in the above two options! Article 30.3
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Nutrition Labelling – ‘front-of-pack’ (repetition)
In either case, the energy value must be indicated at least per 100g or per 100 ml!
Articles 30.3, 32.5, 33.2, 34.3
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Nutrition Labelling Guideline Daily Amounts (GDA) •
Guideline Daily Amounts (GDA) were developed by FoodDrinkEurope (then CIAA) in 2005 as a commitment under the EU Platform on Diet, Physical Activity and Health
•
% GDA reference intakes are a voluntary nutrition labelling guide to how much energy and nutrients are present in a portion of a food or beverage and what each amount represents as a percentage of a person’s daily dietary need
•
Endorsed and implemented by an increasing amount of food companies, large and small alike, on the front of pack
•
Expression of reference intakes explicitly in EU legislation (Art. 32.4 of Regulation 1169/2011 on the provision of food information to consumers)
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Nutrition Labelling Guideline Daily Amounts (GDA)
Per portion (25g):
kcal 140 7% GDA* Per 100g:
2343 kJ / 560 kcal
Level 1: Flexibility provided for alternative, equivalent expressions (e.g. ‘Each portion (Xg/ml) contains‘, ‘Per portion‘, ‘Per Xg/ml‘, ‘Per bar/bag/glass‘, ‘*Symbol+ Xg/ml’ etc.)
Level 2: Flexibility provided for ‘kcal’ above/right to/below the value, or for a combination of term ‘Energy’ + value + ‘kcal’ Level 3: Flexibility provided for placement of ‘GDA*’ right below or within the icon, for suppression of ‘GDA’ (with asterisk only next to %) or for ‘of an adult’s GDA*’. * Asterisk as reference to explanatory statement on FOP (if no GDAs on BOP) or BOP
Level 4: Flexibility provided for alternative expression ‘100 g/ml’ alone (without ‘Per’)
The values per portion and per 100g/ml should be displayed in the same font size (≥ 1.2 mm). Details of graphics (font, sizes, colours, shapes) are of explanatory, non-binding character only.
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Nutrition Labelling â&#x20AC;&#x201C; GDA reference intakes
Annex XIII
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Nutrition Labelling – per portion or per consumption unit expression •
Most foods are not consumed in 100g/ml quantities – additional information is needed to help consumers understand the nutritional value of the amount of food/drink they actually consume
•
Therefore, the energy value and the amount of nutrients may be expressed per portion or consumption unit, in addition to per 100g/ml
•
General conditions when food business operators wish to use per portion/consumption unit expression: 1.The portion/consumption unit is easily recognisable by the consumer; 2.The portion or unit used is quantified on the label; 3.The number of portions/units contained in the package is stated.
•
Commission must develop rules on portions for specific categories of food •
FoodDrinkEurope has developed industry guidelines on portions
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Nutrition Labelling â&#x20AC;&#x201C; FoodDrinkEurope Guidelines on Portions
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Nutrition Labelling â&#x20AC;&#x201C; FoodDrinkEurope Guidelines on Portions
If a pack is designed to be consumed in one single consumption occasion, the portion is the entire pack, even if the pack weight is greater than the reference portion. Examples: Snack bar, pre-packed sandwich, meal-for-one.
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Nutrition Labelling – FoodDrinkEurope Guidelines on Portions The portion is equal to one individual preportioned unit only if this complies with all essential guiding principles. If declaring one individual unit as a ‘portion’ does not comply with all guiding principles, then category 3 should be applied. Examples: Sliced bread, sliced ham.
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Nutrition Labelling â&#x20AC;&#x201C; FoodDrinkEurope Guidelines on Portions
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Nutrition Labelling – FoodDrinkEurope Guidelines on Portions Reference portion: where judgment is required (rice, pasta, sauces...) o Preferably use the term ‘typical’ (usage based on individual preferences) • E.g. ‘a typical portion is 75g rice’
Pack proportion: where the product is designed to be consumed by a set number of people:
or
o Portion = total pack weight / # of people the product is designed to serve • E.g. ‘For Two’: ‘Portion = ½ of this pack (xg)’ o Fractions should only be used up to ‘one eighth’ of a pack or food item.
Examples: Jam, family/share packs (e.g. crisps, cereals), some confectionery, family pizza, etc.
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Nutrition Labelling – Additional forms of expression or presentation
Provided that certain requirements are met (see next slide), all nutrients that are declared on a mandatory or voluntary basis (30.1-30.5) may, additionally, be:
• expressed differently than per 100g/100ml (Art. 32.2), per % GDA reference intakes (Art. 32.4) or per portion (Art. 33); and/or • presented in a different form than the tabular format with numbers aligned (Art. 34.2). This may be done by using graphical forms or symbols in addition to words or numbers.
Article 35
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Nutrition Labelling â&#x20AC;&#x201C; Additional forms of expression or presentation 1.
Based on sound and scientifically valid consumer research and do not mislead the consumer as referred to in Article 7;
2.
Result of consultation with a wide range of stakeholder groups;
3.
Aim to facilitate consumer understanding of the contribution or importance of the food to the energy and nutrient content of a diet;
4.
Supported by scientifically valid evidence of understanding of such forms of expression or presentation by the average consumer;
5.
In the case of other forms of expression, based either on the harmonised reference intakes set out in Annex XIII, or in their absence, on generally accepted scientific advice on intakes for energy or nutrients;
6.
Objective and non-discriminatory; and
7.
Their application does not create obstacles to the free movement of goods.
Article 35
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Nutrition Labelling – Additional forms of expression or presentation •
A Member State may recommend the use of one or more additional forms of expression or presentation of the nutrition declaration to food business operators, including retailers and food manufacturers.
•
If Member States do so, they must inform the Commission of the details of such additional forms of expression and presentation.
•
Member States must monitor the various additional nutrition labelling schemes that are present on the market.
•
The European Commission must submit by 13 December 2017 a report on: • the use of additional forms of expression/presentation • their effect on the internal market • the advisability of further harmonization of those forms of expression/presentation
•
On this basis, the Commission may propose new (additional) EU legislation on this topic.
Article 35
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Transition Period
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Conclusions and recommendations
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Conclusions/recommendations •
For food business operators: • • •
•
Get acquainted with the Regulation’s requirements (e.g. through the industry Guidance) Prepare on time for label and management system changes in view of compliance with the new EU rules Be as consistent as possible in implementing the new requirements (across product categories, markets, etc.)
For (enforcement) authorities: • •
Reach agreement at EU level on a joint understanding/application without delay to provide certainty to stakeholders, in particular food business operators Take a pragmatic approach with regard to the application of the Regulation’s requirements that duly considers the objectives of simplification, harmonisation and improving consumer information
FoodDrinkEurope Guidance can be a tool for further dissemination of the practical interpretation of the Regulation
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www.fooddrinkeurope.eu
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