The European Food Safety Agency (EFSA) released its scientific opinion on the guidelines for nutrient profiling, i.e., “the classification of food based on their nutritional composition for specific purposes”. This opinion aims to set the scientific basis for the set up a harmonized European front-of-pack labelling system (FOPL). But the European agency states it in a very clear and bold way that it does not assess the relevance of the various labelling models, leaving this to the risk manager, i.e., the European Commission. It alsostates that there are three main methodologies to follow when developing a front-of-pack label: either by developing an algorithm, by setting a quantitative threshold for individual nutrients, or by assessing the nutrient contribution that a food makes to recommended nutrient intakes.
However, EFSA underlines that “because diets are composed of multiple foods, overall dietary balance may be achieved through complementation of foods with different nutrient profiles so that it is not necessary for individual foods to match the nutrient profile of a nutritionally adequate diet. Nevertheless, individual foods might influence the nutrient profile of the overall diet, depending on the nutrient profile of the particular food and its intake, in terms of frequency and amount”.
In other words, food that compose healthy diets already contain all the nutrients that we need to be healthy, but there is no single food that already contains every nutrient that we need, thus, a combination of different foods is needed, which can be read as a warning about overly reductionist approaches.
The overall document delivers a complete analysis of the general nutritional outlook on which nutrient profiling should be based. The Scientific opinion considers a comprehensive set of nutrient and non-nutrient components of food (total fats, fatty acids, sugars, sodium, protein, fiber, potassium, EPA, DHA, Iodine, Iron, Calcium, Vitamin D, Folate). It analyzes the available scientific literature on the subject and concludes that a decrease of the intakes of saturated fatty acids, sodium, added/free sugars and energy, together with an increase of intakes of dietary fibers and potassium would represent an improvement for the health of the EU population at large.
The initiative finds its place within the framework legal initiative of the Farm to Fork strategy (F2F) and its declared efforts to improve public health, notably to fight the rise of non-Communicable diseases, such as diabetes, cancers, cardiovascular diseases, hypertension, etc.
Important to note as well that EFSA assessed nutrients that are “likely to be consumed in excess or in inadequate amounts in a majority of European countries”, avoiding, thus, the nutrient profiling guidelines to give a holistic view on the food, but to only assess it based on those specific nutrients.
Remarks
- One of the recommendations of the EFSA on nutritional profiling concerns the fact of replacing energy indicators with total fats. This measure can create confusions in consumers that might have difficulty to translate total fats back to energy (Kcal) intakes. Moreover, this provision moves the focus from energy to fats and/or sugar, therefore, it does not provide a solution on the issue of high energy intakes. On the contrary, energy should become the key parameter in food categories, so to prevent reformulation practices that bring no benefits to consumers.
- As already underlined by Farm Europe, in the context of EFSA’s opinion on sugars (01/03/2022), in the cases of fats and sugars the guideline of ‘as low as possible’, opens to the interpretation that there is no safe level of intake, no matter the quantity. A statement that contradicts the principle of a balanced and diversified diet. Therefore, confusion both from consumers and for the authorities supposed to design FOPs may arise, considering that no concrete guidelines are given. However, despite the public health importance of reducing overall energies, the Nutrient profiling -as well as any possible FOP label method developed on it- should stop at objectively informing about the energy content and do not try to influence consumers’ purchasing choices.
- An aspect that is mentioned in the report, but it does not make it to the recommendations section, is the method of cooking of the food. In fact, depending on how a food is cooked, ingested nutrients might change. Moreover, considering the important effect on health, also the overall level of processing (not only method of cooking, but also reformulation) should be considered both in nutrient profiling and, thus, in font-of-pack labels.
- As a general remark on the FOPL systems, it is worth noticing that the methods relying on algorithms and thresholds are, by definition, biased. In fact, depending on where the threshold is set, or how the algorithm is composed, then the overall assessment of the food will change. In addition, regardless of the chosen methodology, a criterion that takes into account the level of processing of food should be inserted, so to consider the effects of the processing on overall health.
EAT EUROPE is the dedicated department of Farm Europe which aims to tackle the most sensitive societal issues, focusing on the role that institutional actors play in citizen’s health, analyzing and defining the tools that the EU and its Member States could implement in order to prevent their population from habits that could lead to unhealthy lifestyles. It reasons on science and efficacy, by gathering knowledge of people and focusing exclusively on the EU common good and its ability to deliver.