Introduction

The European Commission's Green Paper on General Principles of Food Law, published in 1997, invited comment from stakeholders in the EU. CIAA feels now is the time to start a dialogue to ensure that consumer information maintains its effectiveness, with the label continuing to play a central role.

However this role is changing. With growing sophistication and the opportunities offered by the Single Market, consumers have ventured from diets based on local produce - where labelling featured familiar wording, often in one language for one market - to a much wider variety of products. Additional factors challenging the traditional role of the label are consumer pressures for more information, the increasing variety of products available within the Single Market, and the need for multilingual labelling in Union languages. The label is no longer sufficient to meet all information needs.

Therefore there are grounds for fundamentally reviewing both the role of the label and for consolidating EU legislation on labelling. But at the same time new channels should be found in order to provide consumers with adequate information.

In the introduction to the EU's Directive 79/112/EC on Food Labelling, the objective of the law is clear: "The prime consideration for any rules on labelling of foodstuffs should be to inform and protect the consumer".

Labelling can provide consumers with easy access to information on the identity, content, storage method, preparation and use of the foodstuffs they purchase. But this information must not be so detailed or overcrowded that it becomes unreadable or confusing: a label is only useful and informative only if the consumer can read and understand it easily.

Existing EU laws provide for essential information: what does the product contain ? how much is in the packet ? who manufactures the product ? But with marketplace pressures increasing, legislation is becoming more complex. For example, there are already several items directly regulating food labelling. In addition, there are numerous labelling requirements contained within other Directives (e.g., the Hygiene Directive). A review is necessary to consolidate and simplify these.

Challenges for regulators and industry

A starting point for this debate is to remind ourselves of the essential role of a label. CIAA believes it has to fulfil three fundamental requirements:

1. product identification via the sales designation, the trade name or other commercially important indicators, e.g., the EAN (European Article Numbering) code or product tracking systems such as lot marks;

2. other consumer information allowing people to make an informed choice on the content, amount and value of products and if relevant, to store, prepare and consume food;

3. product marketing information, e.g., claims, trademarks or other means of differentiating a product.

• information must avoid uncertainty or confusion;
• product labels must be legible, both in terms of content and design;
• consumers need to be able to understand what they are reading;
• non-essential information of little consumer interest currently on labels (e.g., health marks, packaging gases, etc) should be reviewed;
• while respecting demands from certain consumers for more information, labels should be concise, informative and useful for the majority. Hence, information channels other than labels should be envisaged.

Complementary in-store information sources range from traditional point-of-purchase displays and leaflets to in-store touch screens and bar code scanners radio-linked to computer terminals accessible to every shopper. If this technology is combined with personal data, via a loyalty card or held in computer memory, then information specific to that consumer can be displayed on screen when the bar code is scanned. For example, a consumer following a diet dictated by his ethical or religious beliefs would be able to avoid products containing ingredients which did not fit with his/her diet. Out-of-store sources include telephone carelines, E-mail and Internet sites.

CIAA believes that the consumer information dialogue should (1) focus on how to consolidate and streamline current EU legislation, (2) establish criteria to determine what needs to be included on labels to protect and inform, and what is complementary information and thus not mandatory on food labels, and (3) ensure that labelling contributes to trade in the Single Market.

This summary is an extract of the CIAA document MIN/140/99E Final.