Brussels, 12/01/2022
Object: Comments from the No-Nutriscore Alliance on the Draft Scientific Report on the development of mandatory nutrition labelling and nutrient profiling to restrict nutrition and health claims on foods (EFSA Public Consultation – Public Consultation Number PC-0108).
The No-Nutriscore Alliance unites consumers, the scientific world, and those within the food chain who are negatively affected by the Nutriscore.
Our work focuses mainly on gathering these voices to make them heard at national and European level, to raise awareness to the European Commission on the impacts, consequences and economical drawbacks caused by the Nutriscore.
First and foremost, we would like to thank the European Food Safety Authority (EFSA) for the work carried out thus far in creating the “Draft Scientific Report on the development of mandatory nutrition labelling and nutrient profiling to restrict nutrition and health claims on foods”.
In this regard, the No-Nutriscore Alliance would like to convey to EFSA the following comments on the above-mentioned draft report:
• When it comes to Front of pack labels (FOPS) such as the Traffic light and the Nutriscore, the issue of quantity comes to play. Often, the calculation used to come up with the scores are based on in g/100 gm without considering the actual portion sizes of products consumed. The main issue with these types of calculations is that they often result in a possible over – or underestimation of the impact of products on
consumer health. Additionally, they provide a distorted ideal for consumers of what is healthy and unhealthy penalizing individual products.
• There is a strong need to properly come up with a standard harmonized definition for portion sizes for various food types and products, which actually relates to the actual consumed quantity/portion size.
• It is essential to avoid an oversimplification of key information which is vital for the consumers. A lack of information due to excessive simplification may result in an adverse effect then what was expected. In fact, overly easy-to-interpret FOP-NL could be risky for those who require specific nutritional information to help manage, for instance, chronic diseases.