European Commission proposals on labelling of food products could drive up costs for manufacturers and generate mountains of additional waste for landfill, making a mockery of EU commitments to reduce packaging waste whilst adding to consumer confusion and undermining efforts of Member States to tackle obesity.The measure, a proposal for a regulation on the provision of food information to consumers, started off as a well-intentioned project to update and simplify the existing food labelling legislation by replacing directives on general labelling (Directive 2000/13/EC) and nutrition labelling (Directive 90/496/EC) as well as "recasting" other measures.
Its objectives are laudable. It seeks to have food labels that are simple, legible, understandable and not misleading. It seeks to bring clarity by laying down clear-cut rules that are proportionate and flexible without imposing unnecessary burdens. But simply using buzz-words such as "proportionate" and "flexible" does not make a silk purse out of the proverbial sow's ear!
One of the more disproportionate, inflexible and unnecessary burdens is a proposed requirement for a minimum 3mm font size for nutritional information on labels. To accommodate this arbitrary imposition, many manufacturers would need to increase label sizes considerably, and for some this would mean increasing pack sizes to ludicrous proportions - leading to more landfill waste and more energy wasted in production and packaging.
What matters most surely is legibility, and it is to be hoped that when the Environment Committee of the Parliament really engages with this issue its rapporteur, Mrs Sommer, will take a lead in proposing a significant amendment to replace the arbitrary size requirement with a more practical test of "legibility"; not least because font style and contrast between writing and background colour are just as important.
But that is not the only problem. The measure also proposes front of pack nutrition information as mandatory for nearly all pre-packed processed food; including energy, fat, saturated fat, carbohydrates, sugars and salt per 100ml/100g or portion.
This "one size fits all" meddling will be of benefit in some Member States where such information is not provided in an organised manner. But what of others who have led from the front in empowering consumers and encouraging responsible manufacturers to look at product formulation and in improving public health by reducing salt, sugar and fat consumption through clear traffic light labelling systems?
In some States industry has spent considerable sums of money in developing such systems.
The proposed solution, not to prohibit the use of national schemes in addition to the EU schemes, risks complete confusion for consumers and challenges for manufacturers who need to repackage for different Member States.
One might wonder whether officials have been consuming too many of the alcopops that are to be included, for the sake of inconsistency, in the requirement to display nutritional information, rather than wine, spirits and beer, which, for the moment, are not.
As part of its rationale for this measure, the Commission cites a survey that consumers are finding it increasingly difficult to identify key information on labels and often seem confused and overwhelmed by them. Really? Now there's a surprise: if you ask consumers if they want more information on labels they say "yes" (what else would they say?) and that after decades of EU labelling legislation the situation is getting more confusing, not less. Ask a silly question, get a silly answer!
At my local supermarket, shoppers' biggest concerns are not label font size and the nutritional content of alcopops - which are consumed for reasons other than nutrition - but the soaring food and fuel prices.
Perhaps the label "dog's dinner" might appropriately be applied to this proposal, and the best hope now is that the Parliament will eventually bring a healthy portion of rationality to the table!
Chris Whitehouse is md of The Whitehouse Consultancy, which advises clients how best to identify, approach and influence key decision-makers in Brussels and the UK government.
Contact him at: chris.whitehouse@whitehouseconsulting.co.uk