As responsible businesses ESA members support the accurate labelling of all foods to help consumers make informed choices by providing them with information on a wide variety of issues including ingredient composition, nutritional value, portion sizes and storage conditions.

The Food Information to Consumers Regulation (EU) 1169/2011, which came into effect on 13 December 2014, consolidated and updated the existing European food labelling legislation into a single text, but also introduced a number of new requirements. These include:

• A minimum font size for mandatory information
• Mandatory back-of-pack nutrition labelling
• A clearer indication of allergens in the ingredient list
• Indication of the vegetable oil type(s) for vegetable oil

The obligation to provide nutrition information has applied since 13 December 2016. Since then, European savoury snacks manufactures have invested significant financial and human resources into the revision of their labels to ensure that they are fully in line with the provisions of Regulation (EU) 1169/2011.

New proposals for Front-of-Pack (FOP) Nutrition Labelling

ESA welcomes the proposal for a revision of the Regulation on food information to consumers as a follow-up on the European Commission’s Farm to Fork Strategy adopted in May 2020. The European savoury snacks industry has been at the forefront of voluntarily providing consumers with clear nutrition information (GDAs, now Reference Intakes) and fully supports a voluntary, science-based, non-discriminatory and informative labelling of food products. In our vision, an EU-wide FOP labelling scheme should:

• Be based on sound scientific knowledge; led by the European Food Safety Authority
• Be transparent and meaningful for consumers and help them in making the healthier choice
• Reflect the dietary needs and habits of all EU consumers
• Stimulate innovation

Portion Size recommendation

ESA continues to support the use of Reference Intakes (RIs) on-pack as formalised by European Law. However, whilst nutrition information provided per 100g (100ml) helps the consumer compare the nutrient content of different kinds of foodstuffs in general, it fails to provide information on the actual nutrient content the consumer intends to consume. Providing nutrition information on a per portion basis empowers consumers to choose a healthy, balanced diet.

In this way, consumers can decide if consumption of the whole pack of that particular food, or of the portion suggested on the pack, is appropriate for them.

Therefore, ESA members have been encouraged to voluntarily display the portion rationale of 30 g front-of-pack and/or back-of-pack. The portion rationale of 30g for snacks and nuts is in line with dietary recommendations for a snack in between meals and reflects consumption patterns. As a result, the majority of European savoury snacks manufacturers now systematically indicate the recommended ESA portion rationale of 30g on their packs.

Allergen labelling

The Regulation includes a list of allergens which have been transferred over from the previous European Directive. However, the Law also introduced a change in terms of how to label allergens in food products.

From 13 December 2014 a separate list of allergens is no longer permitted, and instead there is a requirement to highlight each allergenic ingredient or processing aid in the ingredients list.

Origin labelling

The new labelling Regulation also extends the provisions for mandatory country of origin labelling (MCOOL) for some meats. As stated in Article 26(3) of Regulation (EU) No 1169/2011, it is required that where the origin of a food is given and is different from the one of its primary ingredient, the origin of the primary ingredient shall be given or at least indicated as being different to the origin of the food.

As a sector ESA fully supports the principle that misleading statements of origin should not be made. However, we remain concerned that any future potential extension of the legislation to cover the mandatory origin labelling for products such as crisps (chips), nuts and other savoury snacks, would be highly burdensome for industry and would lead to greatly increased costs with little benefit to improving consumer information and absolutely no impact upon food safety. Therefore, we fully support the existing framework with a voluntary origin labelling.