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European Parliament
2014-2019
Committee on Petitions
26.8.2015
NOTICE TO MEMBERS
Subject:
1.
Petition No 0546/2014 by Piero Carini (Italian) on coloured labels to identify
product features
Summary of petition
The petitioner calls for a directive to be introduced providing for an EU-wide uniform system
of coloured labels for products which enable certain features to be identified immediately,
thereby facilitating the disposal of household waste.
2.
Admissibility
Declared admissible on 11 February 2015. Information requested from Commission under
Rule 216(6).
3.
Commission reply, received on 26 August 2015
The petitioner proposes that information on the method of disposal, ingredients, conservation,
product preparation process, cooking time and expiry date should be displayed by colours to
quickly identify this information.
Regarding foodstuffs which are not anymore intended for human consumption, Regulation
(EC) No 1069/20091 lays down strict rules for the further use or disposal of animal byproducts not intended for human consumption, in view of the risks such by-products may
pose to human or animal health.
1 Regulation (EC) No 1069/2009 laying down health rules on animal by-products and derived
products not intended for human consumption and repealing Regulation (EC) No 1774/2002
(OJ L 300, 14.11.2009, p. 1).
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The EU waste directives, including the Waste Framework Directive1 and the Packaging and
Packaging Waste Directive2 set objectives and goals, including collection and recycling
targets. The Packaging Directive requires Member States to set up appropriate collection
systems for packaging waste. Standard EN 16403, which specifies a way to identify the
various fractions of municipal waste by a set of visual elements, including colours, symbols or
text, was submitted for approval but is still at draft stage. However standards are voluntary,
therefore there is no automatic legal obligation to apply them. Member States are free to
establish the types of packaging collection systems which are best suited to their needs,
consumption and distribution patterns of various types of packaging and packaged goods
provided that these collection schemes help meet the objectives and targets of the Directive,
comply with internal market rules and respect competition.
The provisions of food information to consumers are laid down in Regulation (EU) No
1169/20113. This Regulation aims to enable consumers to make informed food choices. In
particular, it establishes the list of mandatory indications, including the list of ingredients, the
minimum durability date and the storage conditions and/or conditions of use in order to allow
them to know the nature and the characteristics of foods.
In particular, the need for information to be easily legible on foods was one of the main
priorities in the revision of this Regulation4. Food labels should be clear and understandable
in order to assist consumers who want to make better-informed food and dietary choices.
Studies show that easy legibility is an important element in maximising the possibility for
labelled information to influence its audience and that illegible product information is one of
the main causes of consumer dissatisfaction with food labels. Thus, a comprehensive
approach was developed in order to take into account all aspects for mandatory food
information related to legibility, including font, color and contrast.
The Regulation introduces a definition for ‘legibility’ which means the physical appearance of
information, by means of which the information is visually accessible to the general
population and which is determined by various elements, inter alia, font size, letter spacing,
spacing between lines, stroke width, type color, typeface, width-height ratio of the letters, the
surface of the material and significant contrast between the print and the background. In
addition, it foresees that food information must be marked in a conspicuous place in such a
way as to be easily visible, clearly legible and, where appropriate, indelible. It shall not in any
way be hidden, obscured, detracted from or interrupted by any other written or pictorial
matter or any other intervening material5.At the same time, the Regulation has introduced a
minimum font size for mandatory food information. Food information on foods where the
largest surface of the packaging is more than 80 cm2, the x-height in Annex IV is equal to or
1 Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on waste and
repealing certain Directives (OJ L 312, 22.11.2008, p. 3).
2 Directive 94/62/EC of the European Parliament and of the Council of 20 December 1994 on packaging and
packaging waste (OJ L 365, 31.12.1994, p. 10).
3 Regulation (EU) No 1169/2011 of the European Parliament and of the Council of 25
October 2011 on the provision of food information to consumers (OJ L 304, 22.11.2011, p.
18).
4 Regulation (EU) No 1169/2011 was adopted in October 2011 and came into application on
13 December 2014. It has repealed the previous Directive 2000/13/EC.
5 Regulation (EU) No 1169/2011, Article 13, paragraph 1.
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greater than 1.2 mm1. For products where the largest surface is less than 80 cm2, the x-height
must be equal or greater than 0.9 mm2.
Furthermore, the Regulation stipulates that voluntary food information shall not be displayed
to the detriment of the space available for mandatory food information.
For the purpose of achieving the objectives of Regulation (EC) No 1169/2011, the
Commission shall adopt a delegated act on legibility3. The Commission may also by means
of a delegated act extend the list of particulars that have to appear in the same field of vision
for specific types or categories of foods. Today only the name of the food, the net quantity of
the food and the alcohol percentage must appear in the same field of vision4.
Conclusion
With Regulation (EU) No 1169/2011 on the provision of food information to consumers, the
legislators have recognised the importance of food information to be easily legible. The
Regulation lays down a comprehensive approach to the legibility of food information,
including font, colour and contrast. The Regulation contains provisions which ensure that
food labels should be clear and understandable in order to assist consumers who want to make
better-informed food and dietary choices. As Regulation (EU) No 1169/2011 came into
application in December 2014, and also taking into account the transitional measures5
foreseen, the Commission considers that appropriate time should be allowed for the new
changes on the legibility of food information to appear on the labels of foods. The Regulation
(EC) No 1169/2011 foresees that the Commission should adopt a delegated act on legibility.
While the proposals from the petitioner could be analysed and examined in the framework of
the preparatory work for adoption of the delegated act on legibility, the Commission cannot at
this stage commit to the content of such act. The Commission would like to stress that
Regulation (EU) No 1169/2011 imposes obligations on the Commission to adopt certain
implementing acts within certain specific deadlines. The Commission is tackling these actions
as a priority. The Commission’s empowerment to adopt a delegated act on legibility is not
subject to a deadline.
1 Regulation (EU) No 1169/2011, Article 13, paragraph 2.
2 Regulation (EU) No 1169/2011, Article 13, paragraph 3.
3 Regulation (EU) No 1169/2011, Article 13, paragraph 4.
4 Regulation (EU) No 1169/2011, Article 13, paragraph 5.
5 Regulation (EU) No 1169/2011, Article 54.
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