No labelling of ingredients and calories for alcohol
Labelling ingredients in wine is extremely complicated since the composition of the product changes from one year to the other: the values of some components vary based on the production area, of the climatic conditions, the variety of grapes and their phytosanitary situation, as well as of the aging of the wine in the barrel and the bottle. Moreover, a substantial transformation of the raw materials takes place during the fermentation process in the production of wine, i.e. there is no simple and direct relationship between the initial ingredients and the contents of the finished product. Therefore, full ingredient listing for wines would be largely meaningless to the consumer.
Consumers have had the opportunity to express themselves on this aspect, in the framework of a study carried out in 28 European countries by the OPTEM for DG SANCO in April 2005, by stating that wine is a specific product which combines pleasure and affectivity. Regarding the nutritional value, the study specifies as follows: “it is a criterion absolutely without object for a product of pleasure and culture”.
For wine, nutritional labelling does not make sense since wine would not have to label most of the requirements: wine does not contain lipid, protein, saturated fats and salt. Plus there would be the problem of how to define the portion/serving size: a glass is not a standard unit[1].
No minimum font size
The font size of a minimum of 3mm (Microsoft: 12 Times New Romans) for mandatory particulars proposed by the European Commission is not something feasible in practice on wine labels. When assessing label clarity a number of factors need to be considered and not just font size. As the final report “Evaluation of the food labelling legislation” requested by DG SANCO in October 2003 underlines in p.12: “No conclusions are drawn on the need to standardise font sizes used on the label. However, there was strong convergence that the legibility of indications on the label is not determined by font size alone. Legibility is also affected by a number of elements, including use of type-face, contrast, and colour”.
To reinforce legibility of the labels by imposing a minimum font size of 3mm would appear completely disproportionate, even inapplicable, due to the numerous mandatory particulars that must be labelled on a wine label. It should not be forgotten that this product – beyond the requirements imposed by the regulation on the provision of food information to consumers – has to be in line with specific standards of labelling laid out in the single Common Market Organization. Moreover, this requirement clashes with the language obstacle. Indeed, the possibility which is left to Member States to impose their official language for the imported products would lead to the multiplication of translations on the same label. It would be necessary to print out specific labels for each country of export. This would put an overwhelming burden on SMEs which are the backbone of our sector, be extremely costly and go against the very objective of the Single Market.
The labelling of allergens
The presence of allergens in food products must be labelled and this information must be in a language that is understandable by consumers in the Member States where the product is sold. However, producing different labels in accordance with the export market represents a disproportionate economic burden for many European producers which are often SMEs. Hence it is common to label allergens in various languages on the same label.
It is fundamental to inform consumers about the presence of substances that may cause allergic reactions in food products. However, this obligation should not impose such a heavy economic burden to the sector as is the case with the current legislation. Furthermore, the indication of the presence of several allergens in various languages is not the best labelling option for consumers.
A conceivable solution would be to allow the use of symbols when labelling allergens. In fact, the use of a common symbol to indicate the presence of allergens in food may help persons suffering from allergies to identify clearly products containing such ingredient(s). A common symbol would help overcome language obstacles and difficulty in understanding ingredients.
Unfortunately, this solution does not seem to be feasible since the current legislation – Directive 2000/13/EC and Directive 2003/89/EC – does not allow such possibility. In fact, the existing rules provide that allergens must be labelled using the word “contains” followed by the name of the ingredient or of the substance that may cause an allergic reaction: no other labelling solution is envisaged. Furthermore, the actual Commission proposal on food labelling does not put forth a provision clearly allowing the labelling of allergens through the use of symbols. Thus, there is the need to define the terms that will allow the labelling of allergens by the use of symbols and it is essential that these measures consider the specificity of each sector.
Taking this into account we would like to ask you to find a solution to this major problem by providing the possibility for operators to label the presence of allergens with a symbol. The detailed rules (ex. graphics of the symbols) would be developed in the implementing rules in accordance with the relevant provisions applicable to different sectors under the comitology procedure.
[1] Wines are traditionally served in different size glasses. Thus a producer would calculate the calories in the glass it is traditionally served whereas the consumer might use another type of glass thus rendering void the labelling of calories.