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From:
Anders Møller <[log in to unmask]>
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Date:
Wed, 21 Oct 2015 11:43:56 +0200
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Dear Esther,

 

First of all, currently I do not know of any countries in Europe
recommending – even making it mandatory – to use national food composition
data in the calculation for nutrition labelling, and I would be very
surprised if there is.

 

The Regulation (EU) No 1169/2011 lays down the principles for labelling
including nutrition labelling of prepacked foods in Europe
(http://ec.europa.eu/food/safety/labelling_nutrition/labelling_legislation/i
ndex_en.htm).

One of the main principles in the Regulation is that the
manufacturer/producer of the prepacked foods is responsible for the
information on the label, and can be fined/taken to court, if the
information is misleading or wrong.

 

Chapter IV of the Regulation lists the mandatory food information
(“mandatory particulars”). Article 31 clearly states

 

The declared values shall, according to the individual case, be average
values based on: 

(a) the manufacturer’s analysis of the food; 

(b) a calculation from the known or actual average values of the ingredients
used; or 

(c) a calculation from generally established and accepted data.  

 

Indent (c) above opens for the use of (national) food composition data, i.e.
“generally established and accepted data” in the process of preparing the
nutrition label.

Our Czech colleagues have together with EuroFIR AISBL prepared a Guideline
for Food Business Operators setting out the principles in calculation
information for nutrition labelling. 

 

But it is still the responsibility of the manufacturer/producer of the
prepacked foods that the information on the label is right!

The European Commission has published a Guidance document defining which hob
big deviations from the labelled value can accepted for the actual content.

The national food inspections check labels according to these tolerances,
also how values are calculated.

 

Now, back to your actual question.

Yes, national food composition data can be used (indent (c)), but I would be
very surprised, if any European country would make it mandatory to calculate
nutrition labelling from national food composition data, because it would
rule out indent (b). Furthermore, I do not know of any national food
composition table/database that has the necessary detailed information on
the many industrial ingredients and food additives used in commercial food
processing.  

 

And the food manufacturer is still responsible for the information on the
label.

So, in my view any government recommending the specific use of national food
composition data to calculate the values for nutrition labelling would
relieve the manufacturer of (some of) his responsibility, weakening the
Regulation.

 

All the best,

Anders

 

 

Anders Møller

Danish Food Informatics

Borgediget 12

DK-4000 Roskilde, Denmark

 

 

 

From: Food Composition Discussion Group
[mailto:[log in to unmask]] On Behalf Of Esther Infanger
Sent: 21 October 2015 09:33
To: [log in to unmask]
Subject: National FCDB for nutrient labelling of branded foods

 

Dear European colleagues,

 

In Switzerland we currently have a consultation process for a new
legislation which plans to make nutrient labelling mandatory like in the EU.

 

I’d like to know if there is a European country where it is recommended or
even mandatory by legislation to use the own National FCDB when calculating
food labels according to EU1169/2011?

 

If yes, I’d appreciate to get the reference of this legislation or official
recommendation.

 

Thank you and best wishes,

Esther

 

 

 

Esther Infanger, RD, MNutr
Project Manager

Swiss Society for Nutrition SSN

Schwarztorstrasse 87 | Postfach 8333 | CH-3001 Bern
T +41 31 385 00 15 | F +41 31 385 00 05 | E [log in to unmask]

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