NutriScore, Prof. Serge Hercberg responds to Safe’s report.

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The NutriScore synthetic nutrition labeling system-which is overwhelmingly supported by the scientific community and consumer groups in the EU (e.g., NutriScore. BEUC, AltroConsumo, Foodwatch, etc.) – was the subject of a critical report by Safe Food Advocacy, which Serge Hercberg, professor emeritus of Nutrition at the University Sorbonne in Paris, responds to in the interview below.

1) Science v. rhetoric

More than one hundred scientific studies, conducted on more than 500,000 people in many European countries and published in peer-reviewed journals, validate the Nutri-Score algorithm and its graphical format,’ explains Professor Serge Hercberg. Referring to:

  • cohort studies showing a link between consumption of foods classified by Nutri-Score as imbalanced and increased risk of serious and chronic diseases (NCDs, Non-Communicable Diseases),
  • numerous studies performed on consumers’ objective understanding of NutriScore, its impact on food purchasing choices, and the nutritional quality of shopping carts. (1)

The authors of the SAFE report, as well as the lobbyists of the no-NutriScore alliance, are careful not to call out this scientific literature. (2) Except to then challenge its contents with purely rhetorical arguments‘, Serge Hercberg continues.

2) ‘Gross falsehoods and nonsense statements

Professor Serge Hercberg – selflessly engaged on the NutriScore public health project for a decade now – also points out some ‘gross falsehoods and nonsensical statements‘ in SAFE’s paper:

  • the SAFE report states that the Nutri-Score update by the scientific committee established at the European level classified olive oil as A. This is totally false, as no vegetable oil is classified as A!’ Instead, it is true that the NutriScore favors extra virgin olive oil, while the Italic Nutrinform ‘system’ penalizes it over other vegetable oils, (3)
  • SAFE falsely states that the ‘Food Information Regulation’ recommends expressing nutrition information per serving.’ Reg. EU 1169/11, on the contrary, requires that the nutrition information be referred to 100 g/ml of product. And only possibly, on a voluntary basis, also by portion, (4)
  • SAFE’s paper then theorizes that products classified as A [di migliore qualità nutrizionale] would likely be sold at a lower price than other foods, which would worsen the nutritional situation of European consumers. A nonsensical statement, since if the price of good nutritional quality A-rated products decreased we would all be happy and consumers would certainly benefit. SAFE, however, does not explain why this ‘miracle’ should occur‘.

3) Ultra-processed foods and junk food.

Ultraprocessed foods are in SAFE’s crosshairs. Indeed, scientific research developed from the insight of Professor Carlos Monteiro of the University of São Paulo, Brazil, has identified precise correlations between consumption of ultraprocessed foods (UTPs), prevalence of serious and chronic diseases, and premature mortality from all causes. (5)

The classification of foods according to their degree of processing, according to the NOVA 4 system, was based on this premise. (6) Professor Serge Hercberg in turn considered adding a black border, with the words ‘ultra-processed food,’ around the NutriScore logo on the front label of the relevant products. (7) However, without confusing the two concepts.

3.1) Nutritional quality and level of food processing

Nutritional quality and the level of food processing are measured in complementary dimensions that cannot be integrated into a single algorithm. In fact, noFront-of-Pack Nutritional Labeling (FOPNL) system has so far ventured in this direction. (8) Except rather, as hypothesized above, (7) add on the front label a news item (ultra-processed food) that disregards the NutriScore classification.

Epidemiological studies confirm the importance of these dimensions in the development of chronic diseases and independently of each other.
But the correlations between consumption of foods with a poor NutriScore and cancer risk, in the NutriNet-Santé cohort, remain significant,’ explains Professor Serge Hercberg. Some examples to follow help to understand the concept.

3.2) NOVA 4 and NutriScore

If there is an averageconcordance between ultraprocessed foods (NOVA4) and lower nutritional quality, it is not surprising that some ultraprocessed foods have favorable nutritional quality,’ explains Serge Hercberg. ‘Some whole-grain sandwiches and fruit compotes without added sugars may in fact be rated as A by the Nutri-Score.’ And yet:

  • some ‘non-ultra-processed’ foods (NOVA 1, 2 and 3) have poor nutritional profiles (HFSS, High In Fats, Sugar and Sodium). ‘Some pure grape juices, for example, are NOVA1 (unprocessed or minimally processed) and rated E by the Nutri-Score (because they contain more than 160 g/l of sugar),
  • some culinary ingredients (NOVA2), such as sugar, salt, oil or butter, are not classified as ultra-processed foods, but their nutritional composition justifies their identification as foods/ingredients that should be consumed in limited quantities and/or with limited frequency, in line with public health recommendations‘.

3.3) Nutritional variations between foods in the same category.

It is also important to consider ‘even significant variations in the nutritional profiles of foods belonging to each category. For NOVA2 products, for example, there is no differentiation between vegetable and animal fats. And among vegetable oils, it is not possible to recognize those with the most favorable nutritional composition (e.g., olive oil, canola), to be preferred therefore in terms of public health over other vegetable oils (sunflower, corn, peanut, coconut, palm, etc.).

The Nutri-Score, on the other hand, distinguishes different oils with a score from C to E, allowing the healthiest ones to be recognized in line with public health recommendations’. And in any case, ‘for those who do not want to or cannot avoid ultra-processed foods or do not have the time or ability to cook, choosing a food better ranked by the Nutri-Score has a positive impact on health.’

4) Nutrition education

Nutrition education-which has been invoked for two decades as the solution to spur improvements in the diets of populations-has so far found no concrete and effective application to mitigate the ever-increasing trend of obesity, overweight and related diseases. Whereas:

  • the promises of Big Food and other stakeholders in the context of the EU Platform for Action on Diet, Physical Activity and Health proved so flimsy that they led civil society associations to abandon the platform, as early as 2019, (9)
  • government initiatives, as the case may be, have fallen on deaf ears (e.g., Italy. See footnote 10) or at any rate have not been sufficient to counter the predatory marketing of junk-food on children and adolescents, which the British government alone has decided to counter with appropriate measures. (11)

4.1) Public health needs and useful communication

WHO Europe uses the term ‘epidemic’ to describe the growing impact of obesity, overweight and related diseases on the population (NCDs, Non-Communicable Diseases. E.g., cardiovascular disease, diabetes, cancer). These causes are linked to 13 percent of premature deaths and 7 percent of years lived with disability in the Old World. (12)

Useful communication to help citizens eat with balance, Professor Serge Hercberg continues, can thus be articulated on the three dimensions of:

  • nutritional quality, through the NutriScore logo on the label,
  • Reducing consumption of ultra-processed foods (by allowing them to be identified with the appropriate label),
  • Organic products, likewise marked on the label. (13).

5) Nutritional information per 100 g/ml and/or per serving.


Big Food
has over the decades built a strategy of nutritional dis-information by referring energy and nutrient values to servings instead of 100 g/ml. A viral deception is thus accomplished, a viral deception that allows nutritional profiles to be hidden behind the mask of unrealistic ‘serving sizes‘ (e.g. Nutella, 15 g).

Portion size, in the European Union, is not subject to any legal standard (as it is in the U.S. and other non-EU countries). Manufacturers can thus ‘tailor’ nutritional information to ‘tailor’ reduced portions. Conversely, consumers are unable to compare the nutritional profiles of different products.

5.1) GDAs, or ‘Reference Intakes,’ per portion

Big Food products often feature, on the front label, so-called ‘ReferenceIntakes‘ aka ‘Guidelines Daily Amounts‘, GDAs. Namely:

  • The energy value (kcal) or a range of values (calories, fat, saturated fat, sugar, and salt), referring to
  • variable portions from one product to another (instead of 100 g/ml), and expressed as well as in absolute value,
  • as a percentage of an ‘average daily recommended intake’ (2000 kcal/day).

5.2) Viral deception ‘per portion’

Examples of viral deception ‘by portion’ are numerous. Professor Serge Hercberg points out some of the most striking cases. ‘The 30-40 g portions of breakfast cereal, while most adolescents consume 60 or 80 grams per serving.’ But also ‘the portions of ‘one candy bar’ on packages containing two‘.

The variability of portions is also extraordinary in the case of pizzas. Depending on the brands, in France, 123 g, 150 g, 175 g, 200 g, 210 g, and 420 g. And in many other cases, insists Professor Serge Hercberg, ”the consumer has difficulty identifying the portion itself. What is the equivalent of 35 g of Roquefort cheese? 123 g of pizza? 40 g of pate?’

5.3) 100 g/ml. The choice of the European legislator, as well as the basis of the NutriScore

Referring nutritional information to 100 grams or milliliters of product is the choice of all time of the European legislator (already in dir. 90/496/EEC, then in EU reg. 1169/11), as well as the one adopted in the NutriScore system. For a number of reasons, which the research group led by Serge Hercberg has already extensively justified. (14) From the consumer’s perspective, it is worth adding that:

  • portion size is difficult to define, as it varies with age, gender, physical activity/sedentary lifestyle. And it is difficult to imagine a plurality of nutrition claims, especially on the label front, based on different population groups,
  • only a standard quantity, such as 100 g and 100 ml, allows a valid comparison between foods without misleading the consumer. Who should be able to compare 100 ml of olive oil with 100 ml of another oil, 100 g of breakfast cereal with 100 g of other cereals, 100 g of a pizza with 100 g of another pizza, 100 g of Comté, 100 g of Camembert or Roquefort or Mozzarella, and so on‘.

6) Interim Conclusions

Hundreds of independent scientists and many European expert associations (15) – including IARC/WHO, EAP (European Academy of Paediatrics) and ECOG (European Childhood Obesity Group) support Nutri-Score because of its scientific basis,’ Professor Serge Hercberg concludes.

This system now appears to be the most practical solution to help address a serious and widespread public health problem. And it is in fact already applied in 7 European countries, much to the appreciation of citizens and their associations. (16)

Let’s support this virtuous path at the European level, including through the appropriate petition, at the link https://bit.ly/3STjJAU.

Dario Dongo

On the cover, elaboration of the cover of Serge Hercberg’s book ‘Mange et tais-toi – Un nutritionniste face au lobby agroalimentaire’. HumenSciences (Paris, 2022). ISBN. 978-2-37931-325-7

Notes

(1) Dario Dongo, Andrea Adelmo Della Penna. European Commission, research confirms NutriScore approach. GIFT (Great Italian Food Trade). 14.9.22

(2) An up-to-date list of the scientific literature on the NutriScore is available on the blog of the same name maintained by EREN(Équipe de Recherche en Epidémiologie Nutritionelle). Last updated at 2.10.22 https://nutriscore.blog/2022/09/23/bibliography-references/

(3) Dario Dongo, Andrea Adelmo Della Penna. NutriScore, consumer health prevails over agribusiness lobby. Petition and insights. GIFT (Great Italian Food Trade). 18.5.22

(4) Dario Dongo. Mandatory nutrition declaration to start on 14.12.16. The ABCs of standards to be applied. FARE (Food and Agriculture Requirements). 30.10.16

(5) Dario Dongo. Diet, health, and ultraprocessed foods. The FAO report. GIFT (Great Italian Food Trade). 2.9.19

(6) Dario Dongo, Andrea Adelmo Della Penna. Ultraprocessed foods, the worst evil. Appeal of scientists in the British Medical Journal. GIFT (Great Italian Food Trade). 16.8.21

(7) Dario Dongo. NutriScore, signal on ultra-processed foods is added. GIFT (Great Italian Food Trade). 21.12.21

(8) Galan P, Kesse-Guyot E, Touvier M, Deschasaux M, Srour B, Chazelas E, Baudry J, Fialon M, Julia C, Hercberg S (2020). Nutri-Score and Ultra-Processing: two dimensions, complementary and not contradictory. https://nutriscore.blog/2020/11/07/nutri-score-and-ultra-processing-two-dimensions-complementary-and-not-contradictory/. NutriScore blog

(9) Dario Dongo, Giulia Caddeo. Obesity, all to go. Civil society abandons Brussels platform. GIFT (Great Italian Food Trade). 6.7.19

(10) Dario Dongo, Giulia Baldelli. Health in schools, fine words in state-region agreement. GIFT (Great Italian Food Trade). 10.3.19

(11) Dario Dongo. England, stop junk food advertising thanks to Health and Care Bill. GIFT (Great Italian Food Trade). 2.5.22

(12) Dario Dongo, Sabrina Bergamini. Obesity, childhood obesity, and marketing. WHO Europe 2022 Report. GIFT (Great Italian Food Trade). 16.6.22

(13) Nutri-Score and other health dimensions of foods (ultra-processing, and presence of pesticide residues): how to better inform consumers? https://nutriscore.blog/2021/11/28/nutri-score-and-other-health-dimensions-of-foodshow-to-better-inform-consumers/ NutriScore blog. 28.11.21

(14) Why is Nutri-Score computed on the basis of 100g of food and not per serving (as requested by manufacturers)? https://nutriscore.blog/2021/12/02/why-nutri-score-is-computed-on-the-basis-of-100g-of-food-and-not-per-serving-as-requesteded-by-manufacturers/ NutriScore blog. 2.12.21

(15) Group of European scientists supporting the implementation of Nutri-Score in Europe. https://doi.org/10.1024/0300-9831/a000722

(16) Dario Dongo. NutriScore, we help consumers choose balanced foods! Petition. GIFT (Great Italian Food Trade). 8.10.22

Dario Dongo
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Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.