Now that you understand the terminology surrounding the ins and outs of becoming carbon neutral, let’s get into some practical applications.
Navigating Front-of-Package Labeling Systems in the US and EU
When you see a package on the store shelf, do you see the front or the back of the package first? Now, you may be wondering if this is a trick question—of course you see the front of the package first! (Unless someone has put it back in its place improperly.) But the nutritional labeling is not on the front, and that may be the most critical information a consumer needs to be concerned with when buying a food product.
That information does have to be printed on the package—in fact, mandatory nutritional labeling on food and beverage packaging has a multi-decade history in the United States. Traditionally, nutritional labeling is located on the back or side of food packaging, leaving ample space for branding and other important product information. However, in recent years there has been a movement both internationally and domestically to include front-of-package (often referred to as FOP) labeling systems, which would simplify complex nutritional information for the consumer to encourage healthier choices and to align with national health strategies. The FOP labeling system can take many forms; one of the most common to have been used in numerous nations in the EU is Nutri-Score, a traffic light system. Join us as we explore the origins of the movement in the US, the current status of voluntary FOP schemes in the EU, and the debate around the efficacy of FOP labeling, like Nutri-Score
Origins in the US
A front-of-package labeling system is used to provide additional nutritional information on the front of food packaging to give consumers more transparency and context around making healthier choices. The idea of a mandatory FOP labeling system for food packaging is relatively new in the US, first being introduced in the Biden/Harris administration in September of last year (2022).
The White House National Strategy on Hunger, Nutrition, and Health report lays out a 5 pillar strategy in an effort to “make America truly a stronger, healthier nation.” The following are the 5 pillars guiding the White House strategy:
- Improving food access and affordability
- Integrating nutrition and health
- Empowering all consumers to make and have access to healthy choices
- Supporting physical activity for all
- Enhancing nutrition and food security research
So, which pillar do you think the development of a front-of-package labeling scheme is tied to?
If you guessed pillar 3: Empowering all consumers to make and have access to healthy choices, you guessed right!
Pillar 3 contains numerous subsections. Subsection A states: “Empower consumers with updated and more accessible food labeling.” One of the actions under this section is to, “develop a front-of-package (FOP) labeling system to quickly and easily communicate nutritional information.” The report claims this system will work to help consumers, especially those with “low nutrition literacy,” understand which foods are “part of a healthy eating pattern.” In the section, the Administration mentions both “star ratings” and “traffic light” schemes as examples of FOP formats, which makes sense as they have an emphasis on quick and easy solutions. The “traffic light” system, in the form of Nutri-Score, has been used voluntarily by numerous nations since 2017, with mixed opinions on its efficacy.
The State of FOP Labeling in the European Union
The application of front-of-package labeling systems, like Nutri-Score, was first adopted in France in 2017 on a voluntary basis. Nutri-Score is a voluntary FOP labeling system that measures the nutritional balance of foods with a fixed quantity of 100 grams; the system uses nutrients to limit (calories, saturated fats, sugars, and salt) and those to seek (fiber, protein, nuts, fruit, and vegetables). Companies in France who desire to include a Nutri-Score label on their packaging are able to do so for free, registering on the Sante publiqué France site. The system was adopted by numerous EU nations following its implementation in France, including Spain, Germany, Belgium, Switzerland, Luxembourg, and the Netherlands.
The Nutri-Score Debate in Europe
As of August 2023, the use of Nutri-Score and FOP systems in the nations above are on a voluntary basis. However, there is a movement in the European Parliament for a harmonized and mandatory nutrition labeling in the EU, as part of “A European Green Deal,” with a focus on Nutri-Score due to its popularity in several member states.
As the FDA researches the best way to go forward with an FOP system, they should look to the ongoing debate around the system in Europe led by nations like Italy, Romania, Czech Republic, Greece, Latvia, and Cyprus. Many representatives and health departments in these nations feel the Nutri-Score system is misleading and decisions like nutritional intake should not be relegated to a simple formula.
A quote from Teresa Bellanova, the Italian Minister of Agriculture, states: “(An E.U.-wide food labeling system) should take into account the daily nutritional intake, be understandable without using simplistic tools like colors on packages. Diet and nutritional health concepts are much more complicated than an algorithm.”
The Italian resentment towards the system partially stems from national staples like olive oil, hams, and cheeses often scoring “C” and below on the Nutri-Score system. Nations like Romania and Greece agree with the likes of Bellanova and are pushing for a new approach to an FOP system. The opponents of Nutri-Score also point out that the system fails to take into account the degree of food processing and additives, focusing only on the nutritional balance.
On the other hand, advocates for Nutri-Score claim the system provides a simple, quick way to help consumers determine which foods contribute to a balanced diet. Amy Bragagnini (MS, RD, CSO & spokesperson for the Academy of Nutrition and Dietetics) states, “The Nutri-Score may be able to offer folks a quick way to determine if a product would be a good fit for their family.” In a world where consumers are shopping at a rapid pace, Nutri-Score labels can cut through the nutritional jargon and help any and all consumers gauge which food choices are the most balanced, especially when comparing similar food choices.
Furthermore, researchers from the University of Göttingen reviewed data from a consumer survey with 1000+ German consumers which explored how Nutri-Score labels could reduce the rate at which consumers were misled by food products. The study found that with products like instant cappuccino and oat drinks, the lack of FOP labels led to consumer misconception that products were healthier than reality, which was greatly reduced with the presence of a Nutri-Score label.
It is evident that despite usage since 2017, the topic of a mandatory front-of-package labeling system is one of continuous debate. Nations like France and Germany feel the system, particularly Nutri-Score, promotes healthy eating and allows nutritional information to be understood by all consumers. And nations like Italy and Latvia feel the system is too simple, is misleading, and should be revised and not prescriptive. As the debate continues in the EU, Parliament is in the process of exploring an EU-wide mandatory system—similar to that of the Biden/Harris Administration.
Current State of an FOP Labeling Requirement in the US
As of June 2023, the FDA announced a 30-day procedural notice to conduct a study titled “Quantitative Research on Front-of-Package Labeling on Packaged Foods.” The FDA is carrying out consumer research in an effort to understand and explore the potential impact of a front-of-package labeling scheme. In the FDA’s April 2023 FOP Literature Review, they listed several general findings.
Amongst the notable general findings are the following:
- “An FOP rating system or symbol can help consumers identify and select healthy food.”
- “Consumers generally prefer simple labels (such as the ones using a summary system).”
- “Some manufacturers have reformulated products following the implementation of FOP nutrition symbols; some evidence suggests increased sales of products bearing an FOP symbol.”
It is safe to say the system is still under development, yet the FDA in the literature review alone has found the pros of an FOP system, like Nutri-Score, more appealing than the cons promoted by Italy and other EU countries.
How To Prepare Your Business for Potential FOP Labeling Regulation
Packaging professionals need to constantly scan the regulatory environment to ensure compliance with existing and emerging regulations. Although the FDA is still researching the best approach for a potential FOP system, it is smart to proactively research the potential impacts on your organization and packaging value chain—having your pulse on the regulatory environment to avoid potential fines is essential.
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