DG SANCO cnsultative dcument Labelling: Cmpetitiveness, Cnsumer Infrmatin and Better Regulatin fr the Eurpean Unin InBev Cmments June 2006 ABOUT INBEV With a glbal turnver f 192 millin hectlitres in 2005, InBev is the wrld s leading beer prducer (14% f wrld prductin). In Eurpe, ur turnver amunted t 39.7 millin hectlitres f beer in 2005. InBev resulted frm the cmbinatin between the Belgian-based Interbrew and the Brazilian AmBev. In Belgium, the rts f ur brewery g back t 1366. Tday, ur prtfli f Belgian beers cntains Stella Artis, Jupiler, Leffe, Hegaarden and Belle-vue. We als have breweries in the UK, France, Germany, the Netherlands, Italy, Spain, Hungary, and Czech Republic. Our business strategy is based n a cmbinatin f lcal brewing and exprt. Fr example, Stella Artis, riginally nly brewed and sld in Belgium has becme ne f ur star flagship prducts and is nw sld all ver Eurpe, indeed all ver the wrld. Cre t InBev s business are ur cnsumers. Needless t say that withut ur cnsumers trust, we wuld be nwhere. We need ur cnsumer t feel cnfident abut ur prduct. They need t knw that when they buy ur beer, they are buying a first class quality prduct. They need t have adequate and crrect infrmatin abut ur beers, which we prvide thrugh a variety f channels, including the labels n bttles and cans. InBev beers cmply with all health, fd, labeling and ingredients regulatins, which are in frce in each market where its beers are sld. Frm an exprt pint-f-view, it is imprtant t standardise labels used fr ne prduct as much as pssible. Needing different labels fr the same prduct, depending n its enddestinatin can mean a significant cst. Fr instance, exprt Stella Artis uses ne label. If we have t adapt these t the French pregnancy warnings, this means we will need t prduce a separate label fr exprts t France. As a respnsible brewer, we very much regret this lss f efficiency, especially as the reasn fr it is smething which we are cnvinced will nt prevent the alchl misuse it is aimed at. STRATEGIC GOAL Labels need t prvide essential cnsumer infrmatin InBev agrees with the verall apprach as set ut in DG SANCO s cnsultatin dcument: labels can prvide the cnsumer with useful infrmatin but they are nt the ONLY means f prviding such infrmatin. Hwever, they shuld remain the 1
preferred tl t prvide NECESSARY infrmatin t the average cnsumer t make an infrmed and safe purchasing decisin. It ges withut saying that the infrmatin prvided n the label shuld nt mislead the cnsumer. InBev agrees with the Cmmissin that in any case, labels shuld prvide cnsumers with necessary infrmatin t enable them t make safe chices. Hence, we label any substances where they might lead t an allergic reactin. We als cmply with the relevant legislatin cncerning addititives. We have n indicatin that there is a demand fr mre infrmatin n the cmpsitin f the prduct t ensure a safe chice. We als attach a lt f imprtance t the reputatin f ur brands. Our brands vuch fr abslute safety f ur prducts and ur cnsumers knw this: we cannt affrd t jepardize the reputatin f ur brands and ur beers are prduced with the finest ingredients using the highest quality and safety standards. Safety in terms f prduct ingredients is nt an issue as we use nly safe ingredients and wrk with a stringent fd grade t measure this safety. T enable the cnsumer t make healthy chices, it shuld be brne in mind that beer, when cnsumed in mderatin, can cntribute psitively t a healthy lifestyle. The majrity f ur cnsumers has nt expressed any interest in being infrmed n the nutritinal characteristics f ur prducts. Few peple are under the impressin that beer will have a slimming effect. Hwever, fr thse wh wuld like t enjy a beer and are lking fr a variety with lwer calries t fit specific dietary needs, thse lwer energy beers can label the reduced energy level. Whereas sustainable chices are cncerned - again with the prvis that n infrmatin shuld mislead the cnsumer such infrmatin shuld in n case mandatrily appear n the label, there are ther, mre apprpriate channels, fr this infrmatin. Fr instance, sme f ur breweries have invested heavily in ensuring that the water is re-used and that we have a sustainable surce f energy fr ur plants. This kind f infrmatin, ur cnsumers can find in ur Citizenship Reprt. We d nt feel this belngs n the label. In terms f sustainable packaging, the infrmatin we put n the label regarding recyling is nt meant t infrm them f the sustainability f ur packaging, it is meant as necessary infrmatin fr prper use/dispsal f the packaging. GENERAL FOOD LABELLING AND NUTRITION LABELLING General Fd Labelling - Scpe f the legislatin We find it unnecessary t have the same infrmatin as n the bttle label available t thse wh cnsume ur beers in a glass in a restaurant. All f ur beer kegs have the necessary infrmatin fr the server f ur beers: Brand name and address f prducer, number f the batch and sell-by date. N further infrmatin is necessary. 2
- Alchlic beverages: what shuld / shuld nt appear n ur labels Beer is n nvelty prduct, it has been part f the Eurpean diets and cultures fr centuries. Even if the cnsumer may nt be aware r nly partly aware f the ingredients f beer, the familiarity with the prduct seems t have a reassuring effect and ur cnsumers d nt tell us that there is an infrmatin gap cncerning ur beers. The Cmmissin s OPTEM study cnfirms this: mst cnsumers d nt lk beynd the basic infrmatin such as the brand name, the degree f alchl and the type f beer. The study als pints ut that the cmments made n this subject are remarkably hmgeneus. N majr differences are nted accrding t cuntry, gender, r scial status. 1 When cnsidering the effects and cnsequences f labelling legislatin, we wuld als like t pint ut that in the case f beer, the cnsumer very ften will nt see the label. This is the case when draft beers are served. Fr example: in Belgium, 39% f ur beers be are sld in kegs fr n-trade use, i.e. withut a label. We als find that ur labels are intrinsic t the lk and feel f ur prducts, especially the frnt labels. Many f these have nt been changed fr a lng time and we wuld nt like t see them changed. We wuld als like t pint ut that a label fr ur beer bttles is finite : there is nly s much infrmatin yu can try t cram n there. This is cntrary t cans r t tetrapack packaged fds. Therefre, InBev feels that there are nly a few elements MANDATORY fr mentin n the beer label, in rder t avid any cnfusin fr the cnsumer s purchasing decisin: Brand name self-explanatry: it is the reputatin f ur brands that sells ur beers. The brand name will stand fr reassurance and the knwledge that they are buying a tp-quality prduct. Alchl strength we want t give ur cnsumers clear infrmatin abut the alchlic nature and alchl strength f ur prducts Net quantity self-explanatry Address f manufacturer r packager r EU seller the brand name alne will nt prvide adequate infrmatin shuld there be a cnsumer cmplaint. Allergens as ur beers may cntain a trace f substances which may cause an allergic reactin in sme peple (e.g. barley), we apply the EU allergen legislatin in rder t prvide sufficient infrmatin t any allergy sufferers. 1 Eurbarmeter OPTEM Qualitative Study: The cnsumers attitudes regarding prduct labelling May 2005, p. 43 3
Aspartame, plyls, glycyrrhizinic acid, caffeïne etc.. we fllw the legislatin: if levels f these substances are abve scientifically recgnized safe threshlds, this shuld be indicated n the label. This will nt be the case in ur prducts. Elements that culd be VOLUNTARY infrmatin n the beer label, t prvide extra infrmatin are: Ingredients Beer with an alchl cntent f abve 1.2% abv currently has an exemptin fr the cmpulsry declaratin f ingredients in fdstuffs. This dergatin t the rule makes gd sense. Cntrary t slid fds, the ingredients that g int beer underg several transfrmatin prcesses (e.g. fermentatin and filtratin) s that very little f the material that was riginally cmbined, remains in recgnisable frm in the final prduct. Because f this specificity f the brewing prcess, ingredient labelling will nt give the same kind f infrmatin t the cnsumer as des ingredient labelling fr ther fds. The OPTEM study cnfirms that the cnsumer des nt feel he needs infrmatin n the ingredients that g int beer 2 Our wn experiences with cnsumers cnfirm this: we d nt receive demands fr ingredient listing, the very large majrity f cnsumer questins cncern allergic risks, where we respect the legislatin and prvide the necessary infrmatin. Hwever, when it is felt that there is misinfrmatin r a misunderstanding abut the ingredients f beer, the brewer shuld be able t indicate his ingredients n the label. Ingredient listing will be difficult frm a practical pint f view fr thse brands using n back label r nly a neck label. We shuld nt frget that fr the minrity f cnsumers wh are interested in this infrmatin, there are ther channels t btain it: eg thrugh brand websites, brewery visits, etc.. Nutritin labelling (see belw) Date f minimum durability r use-by date Beer is nt a perishable prduct but its taste will change ver time. It is therefre in the cmmercial interest f the prducer t indicate a best by date. Fr the cnsumer wh usually has sufficient knwledge f the effect f time n their beer this infrmatin has limited use, as the OPTEM study affirms. 3 Hwever, fr ur custmers in the trade, the indicatin f a date is a crucial element t help them rtate their stcks and t be able t apply the FIFO principle crrectly: first in, first ut. 2 Eurbarmeter OPTEM Qualitative Study The cnsumers attitudes regarding prduct labelling May 2005, p.42 3 Eurbarmeter OPTEM Qualitative Study The cnsumers attitudes regarding prduct labelling May 2005, p.42 4
Instructins fr use it is in the cmmercial interest f the prducer t indicate this n the label if there are instructins applicable Origins/prvenance we d nt find that this is an issue with ur cnsumers. The OPTEM study 4 cnfirms this and states that the cnsumer has sufficient knwledge f the rigin f the beer thrugh the brand name. This infrmatin shuld therefre nt be bligatry. Special strage cnditins this is relevant infrmatin fr the quality f the prduct, nt fr the safety. Again, it will be in the prducer s cmmercial interest t prvide infrmatin abut special strage cnditins when he finds that this is relevant. Mst cnsumers, hwever, seem t be fairly well infrmed abut where yu shuld r shuld nt stre yur beer t preserve the quality. We d nt cnsider this t be mandatry infrmatin. Inisatin we d nt feel this is relevant fr ur prducts but when it is relevant, it culd be put n the label The Cmmissin dcument mentins the pssibility t make labelling f substances likely t have adverse health effects in certain grups f cnsumers bligatry. We feel that the allergen legislatin and that n aspartame, plyls, glycyrrhezinic acid, caffeine, etc already meet this requirement. Mixed drinks like alcpps shuld be treated the same as the categry f drinks they belng t, which depends n the alchl base they are given (wine, beer, spirits). Nutritin Labelling We d nt feel that the large majrity f cnsumers has a wish fr mre infrmatin n the nutritinal prfile f ur beers. The main reasn fr mandatry nutritin labelling frm a regulatr s pint f view is t ensure that the cnsumer is nt under any misleading impressins abut the nutritinal prfile f certain fds. We find that fr beer, this is seldm the case, the cnsumer usually categrizes beer as a pleasure prduct. The chice fr beer is nt mtivated by a search fr specific nutritinal characteristics. The cnsumer chice will be determined by the taste, as well as its thirstquenching and relaxing effect. Of curse, thse cnsumers wh wuld like t enjy a beer while they are n a diet, may be lking fr a variety with lwer calries. Beers with that prfile can either make a nutritinal claim n the level f energy, r can print a nutritinal prfile f the prduct n the label. We believe these cnsumers t be a minrity hwever, therefre it seems lgical t make this infrmatin vluntary rather than mandatry. 4 Eurbarmeter OPTEM Qualitative Study The cnsumers attitudes regarding prduct labelling May 2005, p.43 5
In terms f the Cmmissin s suggestin t use a single system f symbls and clurs t increase visibility f key infrmatin, we wuld like t pint ut that there is a risk f versimplifying the infrmatin, which will lead t misinfrmatin rather than clearer infrmatin. We are very cncerned abut any suggestins that these infrmatin keys shuld appear n the frnt label. We d nt favur any adaptatin f ur frnt labels. OTHER FOOD ISSUES GMO labelling InBev nly uses ingredients frm suppliers whse prductin prcesses satisfy all natinal regulatins. Our beers are prduced frm agricultural raw materials such as barley, wheat, maize and hps. Currently, there is n cmmercially available genetically mdified (GM) barley, wheat r hps. Hwever, in sme parts f the wrld GM maize is already n the market. In several markets, such as Eurpe, InBev has secured cntractual agreements with the maize suppliers t deliver nly identity preserved (nn-gm) maize. In cnsequence, nne f ur beers brewed in these cuntries cntain genetically mdified agricultural raw materials. Health warnings n alchlic beverages InBev brands nly use health warning labels n their bttles r cans when legally bliged t d s. In all ther circumstances, we prefer nt t use n-pack health warning labels as they are nt prven t be effective t reduce the ccurrence f risky drinkers, ntably drinking by heavy drinkers 5 r pregnant wmen 6. Whilst in cuntries where n-pack health warning labels were intrduced, there was sme increase reprted in awareness f, expsure t, and recgnitin f warning labels n drinks cntainers, research has failed t demnstrate a change in drinking behavir as a result f expsure t them 7. In the absence f evidence that health warning labels are effective in reducing alchlrelated harm, we prefer t cncentrate ur effrts n ther, mre effective appraches such as educatin targeted twards specific risk grups such as yung peple, pregnant 5 Andrews J.C. (1995) Effectiveness f alchl warning labels: A review and extensin. American Behaviral Scientist, 38:622-32 6 Hankin J.R., Firestne I.J., Slan J.J. et al (1996); Heeding the Alchlic Beverage Warning Label during pregnancy: Multiparae versus Nulliparae. Jurnal f Studies f Alchl, 57: 171-177 7 Grube J.W. and Nygaard P. (2001); Adlescent drinking and alchl plicy, Cntemprary Drug Prblems 28/ 87-131 and Agstinelle G. and Grube J. (2002); Alchl cunter-advertising and the media: A review f recent research, Alchl Research and Health 26: 15-21 6
wmen and drink drivers. We feel this is the key t reducing alchl misuse in the lng term. Beer, when cnsumed in mderatin, as is dne n the vast majrity f ccasins, can frm part f a healthy lifestyle. We disagree with the unnecessary stigmatisatin f ur prduct (which a health warning label prvides) and prefer cncentrating ur effrts and resurces n prmting respnsible cnsumptin and fighting irrespnsible use f ur prducts thrugh dedicated prgrammes. This can be dne specifically t fight fetal alchl syndrme by wrking tgether with the peple pregnant wmen trust the mst: their dctr. This des nt mean that we underestimate the pssible negative cnsequences f inapprpriate beer cnsumptin by a minrity f drinkers, but any initiative t fight alchl misuse shuld be judged n the extent t which it actually cntributes t reducing misuse. We find that clear infrmatin is imprtant, t prvide individuals with the guidance t make better infrmed decisins abut the prducts they buy and abut their cnsumptin. This is why all InBev prducts are very clear as t their nature and in particular the strength f the alchl. 7