by Caterina Campese1 | May 24, 2022

1. Agronomist

Edited by Ivy Rose Sebastian.

In line with current eco-conscious behaviour, consumers are becoming more aware of the impact of their dietary choices on the environment. In order to make healthy and environmentally conscious choices, they need comprehensive and unambiguous nutritional information, in line with their personal preferences and tastes. One of the primary objectives of the Farm to Fork strategy, published in 2020 by the EU commission, is to create a favourable food environment, conducive to choosing healthy and sustainable diets. This would benefit consumers’ health and quality of life, ultimately reducing health care costs1 (see also: “Do you know Jack? Properties, benefits, and curiosities of a multifunctional fruit“). The completeness of the information on the label plays a pivotal role in this scenario.

As part of implementing active measures on this issue, ten years ago, Member States of the EU Commission were invited to submit a report on the use of supplementary forms of labelling following Article 35(5) of Regulation (EU) 1169/2011 (also known as the FIC Regulation). The “Report from the Commission to the European Parliament and the Council regarding the use of additional forms of expression and presentation of the nutrition declaration“, finally published in May 2020, announced that a new harmonised and mandatory Front-of-pack nutrition labelling (FoP) would be proposed for adoption as part of the Farm to Fork strategy.

Finally, at the request of the European Commission, in April 2022, the European Food Safety Authority (EFSA) published a scientific opinion on nutrient profiles for the development of harmonised frontal nutrition labelling2.

What is the Nutri-Score?

The Nutri-Score is one of the most widely used front-end labelling schemes in Europe (Fig. 1) and has been proposed for mandatory adoption. This scheme was developed in France3, where it was adopted in 2017. Spain announced its decision to adopt it in 2018, followed by the Netherlands in 2019. Belgium also joined the Nutri-Score in 2019. Luxembourg declared its intention to join the system in 2020, and Germany also notified a draft national regulation on the use of Nutri-Score to the European Commission in the same year.

Figure 1: Nutri-Score logo. From Wikipedia, public domain

The scheme aims to provide an overall indication of the nutritional quality of food, which is a challenging task.

The Nutri-Score label comprises of a five-colour scale. The dark green colour on the far left represents food with the highest nutritional quality, while the colour red, on the far right, indicates food with poor nutritional quality. Colours are associated with the letters from A to E. The algorithm used to calculate the nutritional score considers both ‘harmful’ (i.e., sugars, fat, salt, and calories) and ‘beneficial’ (i.e., protein, fibre, fruit, vegetables, pulses, and nuts) elements. The final sum of the positive and negative scores classifies a food with colour and the letter associated with it.

There are currently many diverse types of FoP on the market (Fig. 2). However, it is important not to underestimate the consequences that an overly synthetic nutritional label could create, as is the case with the Nutri-Score.

So why is the Nutri-Score so successful? Is the information provided by this system clear and comprehensible for European consumers?

Figure 2: Types and formats of FOP nutrition labelling schemes implemented/proposed/announced at EU Member State and UK level. Report from the Commission to the European Parliament and the Council on the use of additional forms of expression and presentation of the nutrition declaration, 2020.

For further information on the legislative framework, please consult the following document: Legislative Framework in Europe.

Evaluation of Nutri-Score as an FoP label

Perception, understanding, liking and use in purchasing situations are some of the characteristics of labelling systems, identified by Grunert and Will4 and used for their evaluation.

This system has already been used to support the Nutri-Score3 but here, we use the same system to interrogate and highlight some of the weaknesses of the Nutri-Score.

Perception: the Nutri-Score, a very colourful and non-detailed label, is certainly a system that allows for immediate perception and easy readability.

Understanding: understanding the Nutri-Score system may seem simple. It is based on the colour-letter-class association, e.g.: green – positive class. Some consumers may find that it is an intuitive association, but this is not the case for all. From the independent debate “Front-End Nutrition Labelling as a weapon for consumer empowerment and a healthier future food system” organised by Equipo Europa last June, it emerged that older consumers tend to associate the colour red (used by the Nutri-Score to classify products with a negative rating) with offers and promotions.

More confusion could be generated by the Nutri-Score system when consumers use it as a tool for comparing completely different types of food products, basing their choice solely or predominantly on the letter-colour assigned by this system. For example, while extra-virgin olive oil is classified as a “C” product, some products on the market such as Chocapic® breakfast cereals, or even Coca Cola Zero®, are classified as “B“. The Nutri-Score is only meaningful within categories of similar and therefore comparable foods, e.g., if you were to compare cereal bar X with cereal bar Y. It is not possible to compare two different food products such as Parmigiano Reggiano PDO (protected denomination of origin) and a cereal bar, even though they can both be considered as “snacks”. Cereal bars are easily reformulated products and can contain refined flours, added and/or natural fibres and so on. Parmesan cheese, which cannot be reformulated as a traditional PDO product due to its salt and fat content, is given a negative rating in the Nutri-Score, despite being a nutrient-rich and protein-rich food with no added additives. The Nutri-Score does not consider additives and preservatives present in ultra-processed products, which are completely absent in conventional ones. A “traffic light” label cannot decide what is a healthy snack that meets a consumer’s tastes, preferences, and needs, especially given the limitations of comparing traditional wholesome foods with ultra-processed foods. For this very reason, the Nutri-Score lacks both GDA (Guideline Daily Amounts) and gram references, making this type of assessment an approximation and not suitable for all contexts. Is this really the guidance consumers need?

Even when evaluating products within the same food category, the Nutri-Score label can cause difficulties in understanding. The system is unable to report the difference in quality between products with similar percentages of nutrients. For example, applying this methodology, no difference would be reported on the FoP labels of extra virgin olive oil5-6, virgin olive oil, olive oil and refined oils. Even more, according to the Nutri-Score, in the same category as extra virgin olive oil, whose health benefits have been known for a long time (Health Claims EFSA, AIRC), we would find some seed oils that are less healthy but recommended for moderate consumption.

Likeability: This is a characteristic that is highly susceptible to personal taste.

Use in purchasing situations: Grunert and Williams point out that “information on actual use is rarely available”. Data collected are based on simulated purchases, where a consumer is not in a realistic scenario, where often the haste, possible queues, availability in the division, price and other variables affect the purchase.

Solutions and strategies adopted by the rest of the world

An example of a winning model that can be followed for labelling has existed since 2012 when the “20.606, Law on the composition of foodstuffs and their advertising” was enacted in Chile. This law, which came into force definitively in 2016, received global approval in the fight against obesity and was soon reformulated and adopted by many countries such as Argentina, Australia, Brazil, Canada, Ecuador, Guatemala, Honduras, Israel, Mexico, New Zealand, Nicaragua, Panama, Peru, El Salvador, and Uruguay. So, why is Europe getting inspired by this model?

The 2012 law is based on a few articles, in part summarised below, and takes the form of four synthetic symbols on the front label (Fig. 3) which apply only to processed foods and identify products high in calories, sugar, sodium, and saturated fat.

The articles state that7:

  • The duty of manufacturers, importers and distributors to state, on containers or labels, the ingredients contained, including all additives, with complete and truthful information and to ensure that the information is visible and understandable. It is also the responsibility of producers and importers that good practices ensuring food safety are followed in the production chains.
  • The prohibition of adulterating ingredients and prepared foods with any substance that may create an erroneous impression about their true nature, composition, or quality, or that may cause damage to health.
  • The duty of nursery, primary and secondary schools to include educational materials and exercises to promote healthy eating habits and physical activity, and the obligation for the relevant ministries to have a nutritional monitoring system for nursery, primary and secondary school students.
  • The request for the Ministry of Health to identify foods whose nutritional composition has high amounts of calories, fat, sugar, or salt (or other ingredients, as set out in the regulation), setting maximum permitted amounts and ensuring compliance through the public health system.
  • A ban on the sale or commercial distribution in nurseries, primary and secondary schools of food products labelled as high in regulated nutrients or calories, as well as the free distribution or advertising of such products to children under 14, including commercial incentives designed to attract children, such as toys, accessories, stickers, or similar products.
  • A ban on labelling infant formulae and breast milk substitutes in any way that might discourage breastfeeding.

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Figure 3: Labels adopted in Chile, according to Law 20.606. Labels show that the product is high in sugars, in saturated fats, in sodium and in calories. Source: Araya, Sebastian e Elberg, Andres e Noton, Carlos e Schwartz, Daniel, Identificazione degli effetti delle etichette alimentari sul comportamento dei consumatori, 2019.
Conclusions and proposals

Recent surveys showed that about 85% of Europeans support using a logo to help them choose healthy products8.

The Nutri-Score is a simple and easily recognisable piece of information. Nevertheless, this does not mean it contains information that consumers, specifically European ones, need. The European Commission’s efforts, including the recent Farm to Fork strategy, are currently aimed at guiding us towards a healthy and sustainable lifestyle. So why not invest in nutrition education for citizens? Why not promote comprehensive nutrition courses in schools?

Unfortunately, simplifying labels so that uninformed consumers can ‘guess’ seems to be the approach that we are moving towards. On the contrary, it would be a good idea to ensure that consumers receive an education that can help them interpret even the most complex labels. Isn’t affording an opportunity for everyone to understand a product composition, to read a complete label and not a traffic light, an even more legitimate objective to pursue?

  1. Delhomme, V. (2021). Front-of-pack nutrition labelling in the European Union: A behavioural, legal and political analysis. European Journal of Risk Regulation, 12(4), 825-848. doi:10.1017/err.2021.5
  2. EFSA NDA Panel (EFSA Panel on Nutrition, Novel Foods and Food Allergens),Turck D, Bohn T, Castenmiller J, de Henauw S, Hirsch-Ernst KI, Knutsen HK, Maciuk A, Mangelsdorf I,McArdle HJ, Naska A, Pelaez C, Pentieva K, Thies F, Tsabouri S, Vinceti M, Bresson J-L and Siani A,2022. Scientific Opinion on the scientific advice related to nutrient profiling for the development ofharmonised mandatory front-of-pack nutrition labelling and the setting of nutrient profiles forrestricting nutrition and health claims on foods. EFSA Journal 2022;20(4):7259, 48 pp.
  3. Chantal, Julia, Hercberg, Serge & World Health Organization. Regional Office for Europe. (‎2017)‎. Development of a new front-of-pack nutrition label in France: the five-colour Nutri-Score. Public health panorama, 03 (‎04)‎, 712 – 725. World Health Organization. Regional Office for Europe. License: CC BY-NC-SA 3.0 IGO
  4. Grunert, K. G., & Wills, J. M. (2007). A review of European research on consumer response to nutrition information on food labels. Journal of Public Health, 15(5), 385–399.
  5. Cappellini, M., In salita la battaglia dell’Italia: nasce in Europa il coordinamento pro-Nutriscore, Il Sole 24 Ore, Febbraio 2021.
  6. DeAndreis, P., 2020, Spanish Producers Join Chorus of Concerns Over Nutri-Score – Olive Oil Times, Accessed 6/23/2021,
  7. Wikipedia contributors, Food labelling and advertising law (Chile), Wikipedia, The Free Encyclopedia, Last revision: 23 November 2021 21:13 UTC, Date retrieved: 27 December 2021 21:47 UTC, ,revision history statistics, Page Version ID: 1056837018
  8. European Commission, 2020. Making our food fit for the future – new trends and challenges. Available online:
Additional sources not cited in the text
  • Barilla Foundation & Research Unit on Nutrition, Diabetes and Metabolism, University of Naples Federico II, 2021. A one health approach to food, the Double Pyramid connecting food culture, health and climate.
  • Santé Publique France, Nutri-Score, Accessed 6/9/2021, Published on December 4, 2020,
  • Storcksdieck S genannt Bonsmann, G Marandola, E Ciriolo, R van Bavel, J Wollgast, Front-of-pack nutrition labelling schemes: a comprehensive review, EUR 29811 EN, Luxembourg, Publications Office of the European Union, 2020, ISBN 978-92-76-08971-1, doi:10.2760/436998, JRC113586.
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