No reform in sight to promote readability of food labels. Health and Food Safety Commissioner Stella Kyriakides thus settles the issue raised by MEP Mihai Tudose, former prime minister of Romania.
Readability of food labels, what criteria?
The Food Information Regulation has finally introduced in Europe-42 years after the first European directive on the labeling, presentation and advertising of foodstuffs (dir. 1979/112/EEC)-an objective requirement to ensure the minimum legibility of mandatory label information. We no longer refer only to the vague concept of ‘clear legibility’ but also to a minimum font height (EU reg. 1169/11, Article 13).
The minimum character height of the mandatory information, referring to the lowercase letter ‘x’ (middle part), is set at 1.2 mm. It may be 0.9 mm instead, if the largest area of the package is less than 80 cm2.
The minimum height of capital letters, numbers and font body are instead derived from the chart in Annex IV to reg. EU 1169/11. Exceptions to mandatory reporting are then established in favor of packages with a surface area of less than 10 cm2. (1)
Visibility of mandatory information
‘The mandatory information on food shall be affixed in a conspicuous place so as to be easily visible, clearly legible and, if necessary, indelible. They are not in any way hidden, obscured, restricted, or separated from other written or graphic indications or other elements likely to interfere‘ (EU reg. 1169/11, Article 13.1).
Visibility remains critical where the responsible operator does not pay due attention to the light and color contrast between the lettering and the background. As well as in cases where mandatory information is affixed to the flaps of packages and reading it actually involves breaking into the package. With the consequent risk, among other things, of compromising its closure and thus the safety of the food.
Readability of food labels, Europarliamentary question
MEP Mihai Tudose, S&D Group (Socialists and Democrats), raised the issue of legibility of food labels in his question 2.7.21 to the European Commission. (3)
‘In order to help consumers make informed purchasing choices there is also a need-in the eyes of many citizens who have written to me-for the markings on packaging to be as easy to read as possible.
The Commission plans to increase the minimum font size currently set by Article 13 (Presentation of mandatory particulars) of Regulation (EU) No. 1169/2011 of the European Parliament and of the Council?‘ (3)
Illegibility of food labels, no reform in sight in Brussels
Commissioner Stella Kyriakides, in her response to Hon. Mihai Tudose’s question on 6.8.21, followed the classic script of non-response.
‘The review of the Regulation (EU) No. 1169/2011 will focus on harmonized nutrition labeling on the front of the packaging, extension of origin labeling to certain products, rules on date marking, and rules on alcoholic beverage labeling. (…)
Regulation (EU) no. 1169/2011 requires that mandatory food information be displayed in a conspicuous place so that it is easily visible, clearly legible and, where appropriate, indelible. While
member states are responsible for implementing these rules, they will also inform the Commission’s proposal to amend Regulation (EU) No. 1169/2011.’ (4)
Eurocrats vs. European citizens
The European executive confirms the supine adherence of theestablishment to the interests of the powerful lobbies. As noted recently, among other things, in an earlier non-answer by Commissioner Stella Kyriakides herself to another question on the subject of food origin labeling. (5)
Bureaucracy-which moves from ‘policy strategy’ (once a ‘white paper’ and before that a ‘green paper’), subject to public consultations and opinions of the institutions, even before translating into regulatory proposals-is worth entrenching the Eurocrats behind a shield that increasingly distances them from citizens.
Tempus fugit
In the ten years since the Food Information Regulation (FIR) came into effect, meanwhile, food labels have remained largely illegible. And the average age in the Old Continent advances in tandem with presbyopia. Ad memoriam, the original proposal of the FIR regulation – on 30.1.08 – referred to a minimum font height in 3 mm. But Big Food, ça va sans dir, prevailed.
Given the way things are going–in the complacent inertia of consumer associations–we will have to wait for a new political strategy, a decade from now, to return to discuss the topic in the following decade. Or enforce, with determination, so that everyone can actually read food labels. A small but great revolution for the rights of the visually impaired and civilization.
Dario Dongo
Notes
(1) Measure packs and readability criteria, lawyer Dario Dongo responds. FARE(Food & Agriculture Requirements). 12.10.17, https://www.foodagriculturerequirements.com/archivio-notizie/domande-e-risposte/misura-confezioni-e-criteri-di-leggibilità-risponde-l-avvocato-dario-dongo
(2) Dario Dongo. Visibility of label information, the case of imported energy bars. GIFT(Great Italian Food Trade). 6/30/17, https://www.greatitalianfoodtrade.it/etichette/visibilità-delle-informazioni-in-etichetta-il-caso-delle-barrette-energetiche-d-importazione
(3) Question 2.7.21 by MEP Mihai Tudose (S&D) to the European Commission, with request for written answer (E-003251/2021). https://www.europarl.europa.eu/doceo/document/E-9-2021-003251_EN.html
(4) Answer 6.8.21 by Commissioner Stella Kyriakides, on behalf of the European Commission (E-003251/2021). https://www.europarl.europa.eu/doceo/document/E-9-2021-003251-ASW_EN.html
(5) Dario Dongo. Origin labeling, not a priority for the European Commission. GIFT(Great Italian Food Trade). 5/28/21, https://www.greatitalianfoodtrade.it/etichette/etichettatura-di-origine-non-una-priorità-per-la-commissione-europea
(5) Dario Dongo. NutriScore and nutritional profiles, updates from Brussels. GIFT(Great Italian Food Trade). 10.5.21, https://www.greatitalianfoodtrade.it/etichette/nutriscore-e-profili-nutrizionali-aggiornamenti-da-bruxelles
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
