Summary

CIAA welcomes EU harmonisation in relation to food information. We strongly believe that
harmonisation at the EU level is the only means to guarantee the Single Market and the free movement of goods whilst protecting the legitimate interests of producers and
enabling consumers to make informed choices.

Therefore, we have some major concerns about the proposed National Schemes (article37 to 47 of the Commission Proposal 2008/40) and believe that these could, de facto, have the opposite effect to the one intended vis-à-vis the Single European Market and also potentially lead to consumer confusion as a result of various nutrition labelling schemes coexisting in the same Member State. Thus, we favour a Regulation that goes for full
harmonisation while at the same time providing operators with some flexibility to provide additional information.

Mandatory Nutrition Labelling (MNL)

CIAA welcomes the recognition of its approach to nutrition labelling and in particular the Commission's support of GDAs.

The efforts and achievements so far by industry should be encouraged. Thus, the implementation of the CIAA scheme should be encouraged by public authorities, notably
through the adoption of a Regulation that is compatible with the implementation of this scheme.

Portion sizes are critical to improve consumer understanding and should be addressed
appropriately by the Regulation based on proposals from industry.

A higher degree of flexibility is required to enable manufacturers to provide additional voluntary information.

CIAA believes that Mandatory Nutrition Labelling should comprise the following1:

Front of Pack:

• GDA icon for Energy (i.e. values for energy are expressed in the absolute amount per portion and its percentage of the Guideline Daily Amounts), in line with the
CIAA ‘’GDA Style Guide’’.

Back of Pack:

• Big 8 nutrients (energy, protein, carbohydrates, sugars, fat, saturated fat, fibre and sodium2) to be expressed per 100g/100ml;

• The format is to be labelled in accordance with the current labelling rules under Directive 1990/496/EC in a table and, where space does not allow, in a linear
format.

Exemptions, in addition to Annex IV of the EC proposal3:

• Food in packaging or containers the largest printable surface of which has an area of less than 100cm²;

• Foods with negligible amount of energy per portion;

• Foods of any description in a quantity of less than 5g/ml;

• Food items with a seasonal, luxury, gifting or fancy design, shape or packaging including assortments;

• Indelibly marked glass bottles.

Disclaimer: This position does not apply to PARNUTS (foods for special dietary uses) where specific provisions for nutrition labelling apply.

Origin Labelling

Regarding the proposed origin labelling provisions, the key principle should remain not to mislead the consumer. Hence, there is no need for further legal requirements since law
already requires origin labelling when the absence of such provision may mislead the consumer as to the true origin of the product. The same rule applies with regard to the
provision of origin information on a voluntary basis.

Clarity & Legibility of Labels

The application of mandatory particulars as proposed under article 14 of the proposed Regulation is impractical and a disproportionate burden for manufacturers. To address
both the issue of clarity/legibility of labels and the feasibility of any proposed approach, CIAA recommends the development of guidelines in this area. CIAA has already
developed industry recommendations and best practice guidelines for labelling legibility4 as not only a more proportionate but also a more flexible tool enabling a case-by-case application.