Farm-to-Fork strategy throws the famous '1169/2011' on the rocks: this is what it means for labeling

Article updated June 2023

The Farm-to-Fork strategy adopted by the European Commission in 2020 should help consumers make healthier and more sustainable food choices. This has implications for the European Regulation on Food Information. This article shows what changes may be coming to Regulation 1169/2011 and when.

The Farm-to-Fork strategy is a core element of the European Green Deal. It sets out how Europe should become the first climate-neutral continent by 2050. In doing so, sustainability must play a role in every link of the food supply chain and involve everyone - from farmer to consumer. To achieve this, the European Commission has set goals for a fair, healthy and environmentally friendly food system in the Farm-to-Fork. Thus, the European Commission has made a proposal to revise a number of provisions in Regulation 1169/2011. These are as follows:

Mandatory nutrition declaration on front and nutrition profiles
Extension of mandatory indications of origin or provenance
Review of date markers
Mandatory ingredient list and nutrition declaration for alcoholic beverages

1. Listing nutritional value on front cover and nutritional profiles

To ensure a fair, healthy and environmentally friendly food system, the European Commission has proposed mandatory harmonized front-of-pack nutrition labeling. This is reflected in an official report from the European Commission. This mandatory indication should ensure that consumers can make informed and health-conscious choices.

In addition, the European Commission plans to create nutrient profiles to limit the promotion of foods with excessive fat, sugar and/or salt content through claims. This means that claims on foods will only be allowed if they meet a certain nutrient profile. These nutritional profiles also serve to encourage the transition to healthier diets and the reformulation of foods.

The European Food Safety Authority (EFSA) issued an opinion on nutrient profiles in April 2022. In doing so, EFSA indicated which nutrients are important for public health, which food groups play an important role in European diets and what scientific criteria should be adhered to for these nutrients and nutrient profiles.

Joint Research Centre (JRC) research shows that consumers generally value front-of-pack nutrition labels as a quick and easy way to obtain nutrition information when making purchasing decisions. Less complex labels require less attention and time to process. Also, consumers generally seem to prefer simple, colorful and summary front-of-pack labels. Front-of-pack labeling can help consumers make healthier food choices. Moreover, it seems to encourage food manufacturers to improve the nutritional value of their products.

2. Extension of mandatory indications of origin or provenance

The European Commission is also considering expanding mandatory indications of origin or provenance. Currently, this is only mandatory for olive oil and pre-packaged fresh meat, among others. This will mean that more products will be subject to mandatory origin or origin marking. These include products such as dairy products, meat as a primary product in processed products, rabbit meat, game meat, rice, durum wheat in pasta, potatoes and tomatoes in tomato products. Consumers will thus be better able to identify the origin of food in order to make more informed and sustainable food choices. There is still debate over whether origin should be indicated at the EU/non-EU, national or regional level. For honey, the EC proposes mandatory labeling of all individual member states and third countries of origin.

3. Revision of 'To be used until' and 'Best before'

The Farm-to-Fork strategy also states that food waste must be reduced. A 2018 European Commission study shows that 10% of food waste in Europe can be linked to 'Use by' and 'Best before' date markings. The European Commission has therefore decided to revise the rules around date markings to address the misunderstanding and misuse of the use-by and best-before dates. The EC proposes to replace the THT statement with 'THT, often well after'. Consumer research, between March 2021 and June 2022, showed that when using the wording 'THT, often well after' the least amount of food was wasted. The EC therefore wants to implement this modified wording in Europe through an accelerated procedure. The change will have to be included in Annex 10 of Regulation 1169/2011. After implementation, a transition period of 3 years will apply.

4. Mandatory ingredient list and nutrition declaration alcoholic beverages

In February 2021, the European Commission adopted Europe's Beating Cancer Plan. As a result, the European Commission is going to propose a mandatory ingredient listing and nutritional values for all alcoholic beverages with an alcohol content of 1.2% or more. For wine products, this obligation will take effect as early as December 8.

The JRC market analysis shows that the alcohol industry in the EU has already embraced the possibility of voluntary ingredient and nutrition information on alcoholic beverage labels. In particular, the beer industry is leading the way by providing an ingredient declaration for about 90% of beers on the market.

The European Commission is investigating whether the mandatory statement should be placed directly on the label ("on-label"), or whether it can be stated via a QR code ("off-label"). Through the QR code, the consumer is directed to the website where the list of ingredients and nutritional values are available. Again, the European Commission aims to harmonize the rules as much as possible throughout the European Union.

Current status

Following the European Commission's proposal to revise Regulation 1169/2011, 'impact assessments' were conducted in the period from December 23, 2020 to February 4, 2021 for the mandatory front-of-pack nutritional value, nutrient profiles, indications of origin and provenance, and date markings.

For the mandatory ingredient listing and nutrition declaration for alcoholic beverages, the 'impact assessments' were conducted from June 24, 2021 to July 22, 2021. These 'impact-assessments' informed citizens and stakeholders about the European Commission's plans and allowed for feedback on the proposal. In addition, studies were conducted and the European Commission invited citizens and stakeholders to contribute to various consultations. In this way, citizens and stakeholders were able to share their views and the European Commission was able to bring additional information for the review. At the end of December 2021, there was also a public public consultation to gather feedback and views.

The JRC findings will feed into current and future food information policy making. In particular, they will be used as scientific underpinning for the ongoing revision of Regulation 1169/2011. In addition, JRC findings will also support preparatory work for future EC legislative proposals, such as the Sustainable Food Systems Legislative Framework (FSFS) and the Sustainable Food Labeling Framework. Although it was initially expected that the EC would decide on the proposal to revise Regulation 1169/2011 by the end of 2022, this has not happened to date.