1. QUESTION: May I use the ‘plate-fork’ icon for products covered by the nutrition commitment?
ANSWER: NO. The icon is only intended for the Commitment50 website to distinguish the nutrition commitments from other commitments. The icon is also used in the dissemination of information about the nutrition commitment model. The icon may not be attached to products because it might be confused with the Better Choice Heart Symbol and interpreted as a nutrition claim.
2. QUESTION: Can the commitments directly refer to product groups/products (such as soup, breakfast cereal, juice drink or tomato puree)?
ANSWER: YES. The aim is that the commitment is product category-specific and covers a distinctive food/food product group so that the measure can be considered significant and the reporting is clear. If the commitment only applies to a single product (Sally's Soup or Tommy’s Tomato Puree), you must ensure that the nutrition commitment cannot be used in any product-specific advertisement if the requirements laid down in the regulation on nutrition and health claims are not met. Read more in the guidelines for the nutrition commitment.
3. QUESTION: Are the claims made in the commitment linked with the legislation on nutrition and health claims?
ANSWER: YES. If you use nutrition claims for your product, they must always be in accordance with the requirements laid down in the regulation. See the regulation on nutrition and health claims: http://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX%3A32006R1924
However, you can prepare you nutrition commitment so that the changes in the composition of the product are smaller than what is allowed under the regulation. In that case, you may not present the claims in any product-related marketing but you can announce in your corporate communications that you have joined the nutrition commitment. You can give the number identifying your commitment. For examples of how you can announce your participation in your corporate communications, see the guidelines for the nutrition commitment.
4. QUESTION: Can I use the commitment in consumer marketing and information?
ANSWER: YES when your nutrition commitment meets the requirements laid down in the regulation on nutrition and health claims. Regulation on nutrition and health claims: http://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX%3A32006R1924
See separate guidelines for corporate communications in section 3.
5. QUESTION: Can I include more than one content area in one commitment?
ANSWER: Under the commitment system, you can enter more than one measure in a single commitment. However, it is easier to make all commitments as separate commitments. This also makes the reporting and follow-up easier. Consumers can also get a better idea of the measures included in the commitments when they are specified. The commitments should also be specific so that they can be monitored in the system of nutrition commitments. For this reason, we recommend that extensive commitments covering several content areas or containing several measures are given as separate nutrition commitments and named so that the heading tells what the content is about
6. QUESTION: Why are fibre and/or whole grain cereal not included in the content areas?
ANSWER: There are eight content areas for nutrition commitments: salt, quality of fats, sugar, vegetables, products for children, portion and package sizes, lunches and recipes. Three of them (salt, quality of fats and sugar) are directly connected with nutritional content. These have been selected in accordance with the EU reformulation programme. Encouraging the use of fibre and whole grain cereal is essential for improving the nutrition of the population. In the nutrition commitment, fibre is included in the ‘vegetables’ content area and the commitments enhancing the fibre content of food products and fibre intake should be entered into this area. In such cases, the fact that the aim is to increase fibre content should be clearly indicated in the name of the commitment.
Operators should also make nutrition commitments helping to increase the fibre content of food products and encouraging the use of whole grain cereal in the content areas ‘products for children’, ‘lunches’ (and snacks) and ‘recipes’. There are examples on enhancing the fibre content of food products as well as on increasing fibre intake and the use of whole grain cereal in the guidelines for the nutrition commitment.
7. QUESTION: Can I edit my commitments after they have been published?
ANSWER NO. You can no longer edit your commitments after they have been made public information. Reports on approved commitments are produced at least once a year as part of the annual report. If at that that stage it is concluded that the measure proposed in the commitment has not been implemented, the commitment is removed from the system. If a target or a measure is changed, a new commitment must be made. Thus, you can only introduce changes by making a new commitment and by reporting on the progress on the previous commitment.
After the commitment has been saved and sent to the system for approval and you notice an error in it, you can change the commitment as long as the approval process is pending (for about one week). No changes are possible after the commitment has been made public information.
8. QUESTION: How long will be commitment be in effect and how long will it remain public information?
ANSWER After their approval, the commitments will remain public information until the end of 2020, unless it is stated in the annual reports that the measures laid out in a commitment have not been implemented or a commitment has been replaced with a new commitment that is monitored and on which reports are produced. This means that after its publication, each commitment remains in effect at least until the next annual report, in which the implementation of the measures is reported for the first time. In a campaign that has its own separate deadlines, the reports should be submitted at the end of the campaign and always in the next annual report at the latest.
9. QUESTION: Why is 2015 set as the earliest base year?
ANSWER: The year 2015 or the period after that is considered as the starting point for the measures. The national targets are based on the Finnish nutrition recommendations issued by the National Nutrition Council in 2014. For this reason, the year 2015 can be considered as the starting point for the nutrition commitment and changes in the nutrition of the population after that are monitored in the system. The year 2015 is also set as the starting point the reformulation programme of the EU. This makes comparisons between Member States possible.
10. QUESTION: Can I make general comparisons between a product presented in my commitments and other products in the same category?
ANSWER: YES but only at general level. You can explain in your corporate communications that the amount of a nutrient contained in a product/the product group is reduced (salt, saturated fats, added sugar or energy) or increased (fibre, unsaturated fats or vegetables) so that it is easier for consumer to make healthy choices and improve their diet. For example, you can state that ‘we are helping consumers to reduce their salt intake’ or ‘we are helping consumers to increase their use of vegetables’ or ‘we are improving the quality of snacks by increasing their fibre content’. Under the regulation on nutrition and health claims, the comparative claims (lesser claims) must, as a rule, show that the reduction is significant compared with other similar products in the market, taking into account extensive comparisons.
See the regulation on nutrition and health claims: http://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX%3A32006R1924