The Nordic Countries Support the Development of a Harmonised Front-Of-Pack Nutrition Labelling

Many people within the Nordic countries and the European Union (EU) do not eat in accordance with dietary recommendations. Over half of the adult population is overweight, which contributes to a high prevalence of diet-related diseases and related healthcare costs. The health challenges in the Nordic countries and in the EU call for action and show the need for evidence-based and trustworthy guidance for our citizens. We believe that FOPNL schemes are tools that can make healthier choices easier and improve diets. Therefore, the Nordic countries are committed to participate in a constructive and transparent dialogue and actively contribute to the process of developing a harmonised FOPNL within the EU.

To ensure the new FOPNL's effectiveness and credibility we would like to see participatory and open dialogues based on the latest scientific evidence and thorough impact assessments. The Nordic countries believe that a FOPNL should be based on nutritional recommendations, documented dietary differences, and current dietary challenges in the different countries. Furthermore, it should not be influenced by commercial interests. These aspects are important to consider in order to ensure the effectiveness and credibility of a new FOPNL. We also want to acknowledge the Guiding principles and framework manual for front-of-pack labelling for promoting healthy diets from WHO and the guidelines on nutritional labelling from Codex Alimentarius. We believe these are important building blocks to ensure that a harmonised FOPNL does not force long-standing Nordic nutrition policies to regress.

We can contribute with our experiences and lessons learned from the Keyhole label, introduced in 1989 and today used in Denmark, Norway, Iceland, Lithuania and Sweden, and the Heart Symbol, used by Finland since 2000. Although these are both voluntary labels, we believe that our lessons learned may be valuable for other FOPNLs. The Keyhole label and the Heart Symbol are independent labels that are available for companies that produce products in accordance with the respective criteria. The labels have been well received by both consumers and producers in the Nordic countries and surveys show that the labels are regularly used and that they have a high level of trust among consumers. We believe that a key reason for the Keyhole label's and Heart Symbol's popularity and trust is that they are based on scientific evidence, government-led with relevant stakeholder involvement, easy to understand and well known.

The high level of trust among both producers and consumers has been crucial for their success.

The Nordic Countries also collaborate on the Nordic Nutrition Recommendations (NNR) which constitute the scientific basis for national nutrient recommendations, our food-based dietary guidelines, and for the Keyhole label and the Heart symbol. We believe that the NNR, with its sixth edition due in 2023, can be a valuable input into the discussions on the criteria underlying the new FOPNL.

Finally, The Nordic Council of Ministers has initiated a collection of available data on the Keyhole label and the Heart symbol, as well as the Finnish salt warning labels to show how these may be incorporated into the algorithms of a harmonised FOPNL in the EU. We will make this data available to the Commission by the summer of 2022. We will remain at the Commission's disposal for any further questions and wish to contribute positively to the development of a harmonised FOPNL.

To summarize, the Nordic countries support the development of a new harmonised FOPNL and want to actively contribute to the development of the label. We believe it is important that:

• the new FOPNL is built upon the experiences from already existing FOPNLs. We need to use the lessons-learned from the work with such labelling and take inspiration from the best features of each system and possible algorithms.
• the new FOPNL is evidence based and built upon scientific knowledge.
• dietary recommendations and dietary challenges of different countries are considered to find a common basis for a harmonised FOPNL within the EU.
• available nutrition recommendations, such as the Nordic Nutrition Recommendations, are used to build a solid scientific base for the new harmonised FOPNL.
• the development of the new harmonised FOPNL takes Codex Revised Guidelines on Nutrition Labelling and the new Annex 2: Guidelines on Front-of-Pack Nutrition Labelling (CXG 2-1985, Annex 2 adopted in 2021) into account.

We are looking forward to further collaboration on this important process.

lngvild Kjerkol, Minister for Health and Care Services, Norway

Rasmus Prehn, Minister of Food, Agriculture and Fisheries, Denmark

Antti Kurvinen, Minister of Agricultur and Forestry, Finland 

Svandis Svavarsdottir, Minister of Food, Agriculture and Fisheries, Iceland

Anna-Caren Satherberg, Minister for Rural Affairs, Sweden