Consumer Information

CONTEXT


When Regulation 1169/2011 was adopted, it was decided to temporarily exempt alcoholic beverages from the scope of regulation until the Commission conducted an assessment. While fully a part of the food sector, it was acknowledged that alcoholic beverages require a marginally different treatment to other foods when labelling energy and ingredients.

 In its report published in March 2017, the Commission invited the sectors to “respond to consumers’ expectations and present within a year of adoption of this report a self-regulatory proposal [on ingredients and nutrition information] that would cover the entire sector of alcoholic beverages”.

After 12 months of intense discussions between seven European federations, a common voluntary commitment, with detailed implementation plans presented in four sector annexes, was presented on 12 March 2018 to the Health Commissioner, Vytenis Andruikaitis (Joint Press Release 12 March 2018).

This proposal consists of a common umbrella voluntary commitment, with implementation plans laid out in each sector’s annex.

OUR COMMITMENT


For spirits, spiritsEUROPE members commit to providing nutrition and ingredient listing by 2022, thus sooner than if mandated by regulation. This will be done either on or off-label. Some companies in particular SMES, may opt for the off-label solution. Others may choose on label information, in addition to the information being available online. spiritsEUROPE will support its members in both endeavours.

Energy information will always be provided per portion (or single serve container) and, as required, per 100 ml.  When using online platforms, we will go beyond the requirements of Regulation 1169/2011 and will provide:

  • Full nutrition information for all spirits
  • A list of ingredients, as well as the legal definition of every category giving consumers details of the raw materials and the production process.

Whether consumers choose to access information via this harmonised system, or company or brand websites, they will always be able to find everything they need to make informed purchasing decisions.

To show how serious we are about digital solution, we are partnering with ETRC (European Travel Retail Confederation) contracted to developed a pilot project making product information for our products directly accessible, in several languages, by scanning the barcode on the packaging via a smartphone, scanner facilities in-store and on-line. The pilot’s results will be available during the second half of 2018.

The European Commission will now review this proposal. As the regulation currently stands, spirits producers who wish to voluntarily put nutrition information on label must do so per 100ml, which represent more than three standard servings of spirits and contradict responsible drinking messages. This has been, and remains, a barrier for many operators when choosing where to display this information.  Which is why we invite to Commission to consider:

  • allowing energy per serving to be mentioned more prominently than the 100ml on spirits labels. 
  • requiring for all alcoholic beverages not usually consumed per 100ml the mention of energy per serving (or single serve container).

    Illustration for Rum


Illustration for Vodka

Questions & Answers

  • Why were alcoholic beverages exempted from labelling energy and ingredients back in 2011?

While fully a part of the food sector, it was acknowledged that alcoholic beverages require a marginally different treatment to other foodstuffs when labelling energy and ingredients.  To account for these specificities, it was decided to temporarily exempt alcoholic beverages form the scope of regulation 1169/2011 until the Commission conducted an assessment. In its report published in March 2017, the Commission invited the sectors to “respond to consumers’ expectations and present within a year of adoption of this report a self-regulatory proposal [on ingredients and nutrition information] that would cover the entire sector of alcoholic beverages”. 

  • What is your position on this issue?

spiritsEUROPE’s position is as clear as it is simple: we will provide the information. In doing so, our guiding principle is to ensure that the information provided is meaningful to consumers. We also believe that it is essential that the way information is provided applies equally to all sectors.  

  • What is presented to the European Commission today?

We are presenting the results of 12 months of negotiations between seven European federations. Our joint proposal is articulated around a common umbrella commitment, with the implementation plans clearly laid out in four sector annexes (wine, spirits, cider, and beer).

  • Are you presenting one commitment? Or four different ones?

spiritsEUROPE has worked closely with the colleagues in wine, beer and cider colleagues during the past 12 months. From the onset, we knew we had to develop a comprehensive proposal taking into account the specificities each sector, some because they are strictly regulated at EU level (wine, aromatised wine and spirits) and others because they are not (beer and cider).

The Brewers of Europe came out with their labelling pledge in 2015, and the Commission with its report in March 2017. It was never about other sectors adopting what the brewers have done, it was about all collectively moving towards better consumer information. 

Our key objective has been, and always will be, to ensure that the information provided is meaningful and comparable. For this reason, we proposed a collective voluntary commitment to display the information per serving (or single serve containers) in addition to 100 ml. This was not considered acceptable by The Brewers. From then on, the other sectors had no choice but to develop sector annexes detailing what information they will provide, and how.

  • What makes spirits different from other alcoholic beverages?

Spirits are different in that they are exactly pre-defined by the Spirits Drinks Regulation (110/2008). The Regulation states in detail what can – and cannot – be used to produce the different spirits drinks such as rum, vodka, or gin.

  1. On nutrition: The distillation process means that, for most categories of spirit, none of the normal nutrients are found.  Thus, a vodka, whisky or rum does not contain any fat, carbohydrate, sugar, protein or salt.  Spirits contain energy derived mainly from their alcohol content.  Our sector has long indicated its willingness to declare the energy content of spirits. Many are already doing so through their websites.  More importantly, it is necessary to ensure that energy declarations are meaningful and do not mislead consumers.  

  2. On ingredients: The distillation process transforms the raw materials so that they are no longer present in the final product.  Thus, there are no grapes in brandy, no molasses in rum and no cereals in whisky.  This being the case, the main ingredient of these spirits is, respectively, brandy, rum and whisky.  Water is a further ingredient, as would the tiny quantities of caramel that are sometimes added to harmonise colour between batches.  

  • What does that mean for consumers? It means that the category name on the label of a spirit acts as an anchor of trust and as a powerful tool to provide meaningful information to consumers, as different spirits brands within the same category will broadly have the same ingredients and energy content.

Therefore, information on nutrition and ingredients can be provided in a meaningful way online by product category. We illustrate this on our website www.responsibledrinking.eu with the example of vodka and rum. Information on other categories will follow.

  • What is spiritsEUROPE committing to exactly?

spiritsEUROPE members commit to providing energy and ingredient listing by 2022 and thus sooner than if mandated by regulation. This will be done off and/or on-label. Some companies, in particular the many SMEs active in our sector, may opt for the off-label solution. Others may choose to provide information on label in addition to the information being available online. We will support our members in both endeavours.

Energy information will always be provided per portion (or single serve container) and, as required, per 100 ml. 

When providing information online, we will go beyond the requirements of Regulation 1169/2011 and will provide:

  1. Full nutrition information for all spirits

  2. A list of ingredients, as well as the legal definition of every category giving consumers details of the raw materials and the production process.

Whether consumers choose to access information via this harmonised system, or company or brand websites, they will always be able to find everything they need to make informed decisions. To show how serious we are about this, the European Travel Retail Confederation (ETRC) was contracted to develop a Pilot Project making product information directly accessible, in several languages, by scanning the barcode on the packaging via a smartphone or scanner facilities in-store. The Pilot’s results will be available during the second half of 2018.

  • Boosting online information: what is the ETRC Pilot Project all about?

ETRC has been contracted for the development of a Pilot Project to create a dedicated digital platform for information to consumers for goods sold in duty free and travel retail shops. This will touch on a number of products including alcoholic beverages. The idea is that consumers will be able to easily access a responsive website, on which detailed product information will be available in several languages by scanning the barcode on the packaging via a smartphone or scanner facilities in-store and on-line. This will ensure that the information will be available to anyone anywhere, at any time. The Pilot Project results will be available during the second half of 2018.

The unique advantage of the innovative solution being developed and proposed by ETRC is its ability to provide consumers with information directly from the product itself, in multiple languages and in a format that is useful and relevant. It will be a powerful tool to show that such a provision of information is possible by means other than labelling on package.

It is a unique opportunity to implement a ground-breaking solution for the digital age, eight years after the adoption of the “FIC Regulation” which foresaw that “Food information rules should be able to adapt to a rapidly changing social, economic and technological environment” (recital 51).

  • How will spiritsEUROPE ensure the information is coherent throughout Europe

We will work with our 31 federations and 8 companies to provide guidance on how to best display the information for the 47 products categories. spiritsEUROPE will develop implementation guidelines to support members and in particular SMEs, allowing for the communication platforms to present information on nutritional and ingredients information in a comparable manner.

Whether consumers choose to access information via this harmonised system, or company or brand websites, they will always be able to find everything they need to make informed decisions.

  • How and when will spiritsEUROPE report about progress

spiritsEUROPE will report to the Commission at regular interval between March 2018 and 2022. The first deliverable will be a progress report in October 2019 indicating the percentage coverage of the organisations having chosen to make information available on labels.  The additional three phases are detailed in our spirits annex.

  • What do you think the Commission will do now?

The Commission will review the proposal presented on 12 March. 

As the regulation currently stands, spirits producers who wish to voluntarily put nutrition information on label must do so per 100ml, which represent more than three standard servings of spirits and contradict responsible drinking messages. This is why we invite to Commission to consider:

  1. allowing energy per serving to be mentioned more prominently than the 100ml on spirits labels. 

  2. requiring for all alcoholic beverages not usually consumed per 100ml the mention of energy per serving (or single serve container).