Feasibility study for a dedicated
database containing all Union
and domestic labelling rules and
providing a simple way to
identify concrete mandatory
labelling requirements per
product
Executive summary
November 2014
Title:
Executive summary of the feasibility study for a dedicated database
containing all Union and domestic labelling rules and providing a simple way
to identify concrete mandatory labelling requirements per product
Project number: 2014.1032
This executive summary has been prepared in 2014 for the European Commission,
Directorate
General
Internal
Market
and
Services
under
Contract
No
MARKT/2013/083/E2/ST/OP.
Key Subjects:
Food labelling, information to consumers, database
Publisher:
European Commission, Directorate General Internal Market and Services
Performing Organisations:
Project leader:
Daniel Traon (Arcadia International E.E.I.G.)
Contact: [email protected]
Authors:
Arcadia International: Daniel Traon, Laurence Amat, Filippa Lofstrom, Francesco
Montanari
infeurope: David Kliever, Evelyne Huybrecht, Laurie Causton
SIRENE: Patrick Sarrazin, Olivier Scotti
The information and views set out in this study are those of the author(s) and do not
necessarily reflect the official opinion of the Commission. The Commission does not
guarantee the accuracy of the data included in this study. Neither the Commission nor
any person acting on the Commission’s behalf may be held responsible for the use
which may be made of the information contained therein.
DOI: 10.2780/29545
ISBN: 978-92-79-35145-7
© European Union, 2014.
Reproduction is authorised provided the source is acknowledged.
The European Commission mandated Arcadia International E.E.I.G. and infeurope S.A. to
perform a feasibility study on a dedicated electronic storage system (the “database”)
containing all Union and domestic food labelling rules and providing a simple way to
identify concrete mandatory labelling requirements per food product. The study has been
conducted between January and October 2014.
Context of the study
Whilst the existing EU regulatory regime on labelling of foodstuffs harmonises mandatory
food information to a great extent, it also allows, under certain conditions and in
accordance with a legally established procedure, for the introduction of additional
mandatory labelling requirements at national level for specific categories of foods. The
resulting legal framework may be perceived as complex by stakeholders. The
identification and familiarisation with horizontal and vertical food labelling rules at both
EU and national level may prove cumbersome, particularly as far as Small and Medium
Enterprises (SMEs) are concerned.
The creation of a database grouping all existing labelling obligations may help food
business operators (FBOs) in identifying and understanding the rules with which they
should comply. The database would become a central repository for all compulsory EU
and national level legislation.
The European Retail Action Plan (ERAP) adopted in 2013 proposes actions to achieve a
single market in retail by addressing key obstacles that hinder the smooth functioning of
this sector. It highlights that a dedicated database could lead to increased transparency
in food labelling rules, as well as facilitating access to EU and national labelling
obligations. This has been translated into Action 9 of the plan, which states that “The
Commission will examine the feasibility of setting up a dedicated database containing all
EU and domestic food labelling rules and providing a simple way to identify labelling
requirements per product”.
In parallel to the above mentioned ERAP communication, discussions on the possibility of
creating such a database already took place in the context of the revision of Directive
2000/13/EC on the approximation of the laws of Member States relating to the labelling,
presentation and advertising of foodstuffs that led to the adoption of Regulation (EU) No
1169/20111 which shall apply from 13 December 2014.
Objective, scope and methodology
The purpose of the study is to provide an initial assessment of the feasibility of possible
options for creating a database including, at least, all mandatory EU and national food
labelling requirements in order to support the Commission in its reflections on setting up
such a tool.
In pursuit of the above, the Commission has specified the following particular objectives
for the current study:

Examine the feasibility of an electronic storage system providing public access to
regulated information about labelling of food products, including obligations
arising from both EU and national legislation;

Evaluate the potential usage by and effectiveness of such a system for FBOs and
possibly for final consumers. Effectiveness can here be understood as the ability
to overcome actual issues and problems which FBOs are facing when it comes to
1
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, amending Regulations (EC) No 1924/2006 and
(EC) No 1925/2006 of the European Parliament and of the Council, and repealing Commission
Directive 87/250/EEC, Council Directive 90/496/EEC, Commission Directive 1999/10/EC, Directive
2000/13/EC of the European Parliament and of the Council, Commission Directives 2002/67/EC and
2008/5/EC and Commission Regulation (EC) No 608/2004 Text with EEA relevance.
Page I
identifying information which they must place on the labels of the products they
market;

Estimate the costs and evaluate the benefits of such a system considering the
different options identified; and

Provide analytical conclusions with regard to the best option for a possible storage
system and the steps to be taken to set it up.
The study covers the EU-28 and all relevant food sub-sectors along the whole food
supply chain from primary production to final consumers. It mainly focuses on food
information to consumers, i.e. the information which FBOs must provide to consumers.
Other labelling obligations that may be required in the context of Business-to-Business
(B2B) relationships are not within the scope of the study.
The results presented in this report build on a large consultation exercise, which
included:

Face-to-face interviews with key EU stakeholders and mainly those identified as
potential issuers and users of the database;

Three specific surveys: a survey addressed to SMEs, another addressed to
national competent authorities (NCAs), and a last targeting stakeholders; and

Face-to-face interviews with owners/managers of existing databases that have
been analysed in order to identify specific technical IT characteristics of potential
interest for the creation of the food labelling database.
Key findings related to the analysis of the policy context and the
stakeholders
In a first step the study describes the complexity of food labelling legislation, and
identifies all of the different categories of actors within the food supply chain that are
concerned by food labelling. In a second step the study translates these expectations
(the vision) into practical terms (the general concept).
Content characteristics and content management: The regulated information to be
included in the database is publicly available. There are no significant barriers for its
accession. However, this information exists in different formats and languages and comes
from different sources, making its compilation a complex and time-consuming exercise. If
too little time is dedicated to the management of the regulated information, the level of
accuracy could be too low, leading to the rejection of the database by end-users. The
study reveals that one additional difficulty would be deciding on how to assign specific
labelling requirements to dedicated food categories, as regulatory texts are based on
several different food categorisation approaches.
Information technology needs: The technological platform (i.e. the IT system) that needs
to be developed is not seen as being of a complex nature. The best approach for the
publication of the information is to create a web platform. Several existing Commission
web solutions offer concrete examples of the desired overall approach for each of the
selected options but the best technical alternative would be to create a new application.
Expectations regarding the creation of a food labelling database: A large number of
stakeholders were invited to present their expectations (i.e. needs) with regard to a
future database via interviews and surveys. Most of them have indicated that the system
should provide detailed information on how to correctly label their products. For them,
the database should translate the listing of obligations per group of products into a list of
practical tasks indicating in detail how to write compliant labels.
A majority of National Competent Authorities favour the creation of a database as it
would bring clarity and would provide a comprehensive list of requirements. However six
NCAs out of 28 have clearly expressed that the creation of a database would lead to
additional burden for them and that a database is not required as one of their mandates
is to advice FBOs on labelling compliance.
Page II
Profile of future end-users: The potential future users of the database are the FBOs and
the competent authorities in charge of food labelling rules as well as those in charge of
official controls (labelling compliance). Each group of stakeholders has a specific and
diverse profile when considering criteria such as the number of labels to be generated
per operator, the number of labelling obligations with which to comply per label, and the
overall labelling complexity. At primary production level, the labelling complexity is
rather low as products are mainly mono-ingredient and the number of labels per FBO is
limited. At processing 2+ level, FBOs manufacture multi-ingredient products and labelling
obligations have to be considered for each individual ingredient in the recipe. Retailers
have a unique profile as they have to label multiple categories of food in the context of
their own-branded products labels (i.e. private labels).
The specific profile of SMEs: The majority of SMEs does not have in-house any legal
expertise on food labelling issues. Also, staff and resources are generally limited. As a
consequence, this has an impact on the amount of time which they can invest in
researching food labelling requirements applicable to their products. Therefore, the needs
of SMEs are quite specific in that these operators are looking for detailed information.
While large companies can afford to buy legal external expertise to design their label and
therefore would benefit from a database that merely lists all regulated information, SMEs
would prefer instead to have access to a detailed set of information that, derived from
the regulated information, could provide practical advice on “what to write on the labels”.
The main (potential) barriers for the use of a food labelling database can be ranked as
follows (from the most to the least important):

Lack of knowledge about the existence of the database;

Costs associated with the use of the database;

Lack of multi-lingual content;

Difficulty for individual users to easily identify the information of interest, and only
this, out of all regulated information;

Difficulty in understanding food labelling obligations in practical terms; and

Difficulty in assuring full accuracy of the “regulated information” in the system.
From creating a vision to the description of the options
The development of any information system starts by creating a long-term vision to
guide decisions and meet objectives. Therefore, a general concept has been designed by
taking into consideration all the above mentioned findings related to the content of the
database, the IT technological approach, the non-uniform profile of potential end-users,
and the potential barriers and the challenges for the use of the database.
From this general concept, the study identifies the key functionalities and features of the
database. The five key requirements ranked by priority order (from the most to the least
important) read as follows:

User interface: web design and website functionalities answering to the need to
provide a single access point to end users;

Multilingualism of both the IT interface and of the content of the database (the
regulated information);

Categorisation of rules (IT approach to food classification);

Extended search functionalities;

Exporting of content for further ad hoc use outside the database.
It then analyses the technical characteristics of eleven different databases to examine
whether existing structures could be used for setting up the new system. None of the
existing or available products is able to fully serve all the requirements that have been
identified. However several interesting features that may be used as concrete examples
when creating the database. This is particular the case in terms of filtering and searching
Page III
functionalities, multilingualism, content management governance, and the classification
of regulated information per product categories. Finally, none of the tools analysed
includes user-friendly functionalities related to the export of the content in a structured
manner.
Presentation of the options
The analysis of the above-mentioned tasks led to the identification of four options on how
to set up, implement and maintain the EU food labelling database. Each of these options
has been assessed by presenting their advantages and disadvantages as opposed to the
current “status quo” position. The design of the general concept is based on a step-bystep approach, meaning that adjustments are made from one option to the next with the
objective of obtaining a final result which is the achievement of the long term vision. The
following options were formulated:

Option 1: Maintaining the status quo – this option is the baseline to which the
costs and benefits (strengths and opportunities) of each option can be compared;

Option 2: Database with all legal texts and corresponding articles per
group of products;

Option 3: Option 2 + summaries + food product categorisation;

Option 4: Option 3 + modules on translation of technical terms and on
ingredients;

Option 5: Long-term objectives (including Option 4 with additional features
and modules).
When it relates to the governance of the database and especially the management of the
regulated information (content management), the entry and update of national
information could take the form of two different approaches:

First approach (approach 1): nationally regulated food labelling requirements
would be collected via local food lawyers and experts in food labelling that would
be identified by the EU secretariat. National competent authorities would be
invited to validate any national information before it would be submitted at EU
level;

Second approach (approach 2): nationally regulated food labelling requirements
would be collected via a national contact point, held within the national competent
authority on food labelling (1 national contact point–NCP per Member State), that
would be identified in collaboration with the EU secretariat. The NCP would be
responsible for the identification, structuring, validity and accuracy of the provided
information.
Assessments of the options
The advantages and disadvantages of each option were compared with the aim of
facilitating the selection of the preferred approach. Each option was assessed against a
set of criteria that was developed to measure the overall suitability of each of them.
These criteria and the results of the assessment are presented below.
Criteria
Option 2
Option 3
Option 4
Option 5
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Ability to meet the EC requirements
-
Single access point
Access to ALL regulated information
Allow for further extension
Offer searching and filtering functionalities
Integrate notifications to prevent duplication
Other enhancements
Page IV
Criteria
Deliverability - how easy is it to move from the
current situation to that proposed by the options?
Ability to address identified issues
Acceptability of the options by stakeholders
Timescale - how long is the option likely to take
to be fully implemented?
Governance & resourcing (Approach 1)how much will the current governance and
resourcing arrangements need to change to
implement the option?
Governance & resourcing (Approach 2) how much will the current governance and
resourcing arrangements need to change to
implement the option?
Standardisation - to what level will the current
arrangements need to be standardised?
Flexibility - how easily can the proposed
systems be changed to include new data, storage
arrangements or processes?
Benefits and users experience - what are
the perceived benefits of the option?
Risks - the likely risks of implementing the
option.
Option 2
Option 3
Option 4
Option 5
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Scoring: From evidence of no change (=) to evidence of substantial advantages of the option
Costs of the options
The next step of the assessment has been to estimate the costs for operating each
option. For this purpose a cost model has been developed. Although the estimation of
costs has to consider several uncertainties, the unit costs that have been considered
under this study are averages which are used in the field of IT development. When it
relates to the volumes (e.g. the number of working days for developing an IT module),
estimations are mainly based on the study research.
The detailed total costs associated with all four options are presented in the tables and
figures below.
Comparison of the total costs of each Option for the 5 first years
Option
Option
Option
Option
2
3
4
5
Total costs
€ 622,000
€ 1,567,000
€ 2,770,000
> € 2,770,000
Comparison of the total recurring costs of each Option for the 5 first years
Option
Option
Option
Option
2
3
4
5
Total costs
€ 336,000
€ 714,000
€ 1,222,000
> € 1,222,000
Comparison of the total one-off costs of each Option
Option
Option
Option
Option
2
3
4
5
Total costs
€ 286,000
€ 853,000
€ 1,548,000
> € 1.548,000
Page V
Comparison of the one-time costs as regards infrastructure and governance
costs of each Option
1,800,000 €
1,600,000 €
1,400,000 €
1,200,000 €
1,000,000 €
Governance
800,000 €
Infrastructure
600,000 €
400,000 €
200,000 €
0€
Option 2
Option 3
Option 4
Option 5
Distribution of the one-time costs (Commission vs. MS vs Stakeholders) of each
Option
First approach - approach 1
Second approach - approach 2
1,800,000 €
1,600,000 €
1,400,000 €
1,200,000 €
1,000,000 €
Stakeholders
MS
800,000 €
COM
600,000 €
400,000 €
200,000 €
0€
Option 2
Option 3
Option 4
Option 5
This cost analysis clearly identifies that the main costs for the development of the
database lie in the content management (i.e. identification, accurate structuration and
compilation of the regulated information in the IT solution). The IT costs (e.g. costs for
the development and the IT maintenance of the system) are rather low. Additional
significant costs are devoted to training of end-users to secure an optimal buy-in by both
FBOs and public bodies.
The Commission bears the large majority of the costs in all options. However budgetary
implications of FBOs increase when new modules are created (Option 4 and Option 5).
Page VI
Conclusions
The study does not identify any blocking factor which would make setting up the
database unfeasible. The content of the database is public information and therefore
publicly available. The complexity comes from the different sources of information that
have to be consulted at both EU and national level. The IT approach is rather simple for
all options and the technological solution integrating all key requirements is not regarded
as a complex task. The preferred IT technological approach is to develop a web-based
solution (web-portal that ideally be placed under a Commission website).
The majority of stakeholders met and contacted during the study have clearly mentioned
their interest in a dedicated database. When the large majority of NCAs have indicated
their interest for the creation of a pan European database, six NCAs have clearly
expressed that they are not in favour of the creation of a database as they consider that,
in case of doubt, FBOs can call the competent authorities directly to receive advice on
how to correctly label their products for the domestic market or for marketing in other EU
Member States.
This considered, the question of feasibility should be approached by considering the costs
associated with the development and the maintenance of the database: “the database is
feasible, but at what cost?”
While it is observed that all regulated information is publicly available, several issues lead
to a degree of complexity, e.g. the large number of sources of information at different
levels (EU vs. national), several languages, information not classified on the basis of a
harmonised food categorisation system, several responsibilities in different DirectoratesGeneral of the Commission at EU level and in different ministries at national level for all
required regulated information, etc.
Content management is perceived as a complex task (and therefore a costly task) by a
majority of stakeholders and by competent authorities and which may lead to a certain
level of inaccuracy. Lack of full accuracy is considered as one of the major threats to the
database: if the database turns out not to be fully accurate, end-users will immediately
reject the database after identification of the first inaccurate item.
Option 5 is the only one that fully responds to all requirements and expectations
expressed by stakeholders and competent authorities during the consultation. It supports
the vision which is to allow each FBO (the small ones as well as the big ones) to print out
its mock-up labels for all the products which he/she is marketing. However, due to the
complexity of the requirements under that option, it seems more realistic to start the
implementation of a lower option (Option 2 or Option 3) first.
Option 2 already offers a large range of strengths and opportunities as it is able to meet
the majority of the key requirements.
Option 3 satisfies the requirements better than Option 2 as far as the presentation of
regulated information in food categories is concerned, thereby allowing end-users to
identify the required information. By adding summaries, Option 3 presents more practical
information for end-users who are not familiar with the legal language and related
terminology. The acceptability of this option is also greater than for Option 2 as this
solution provides a product approach and allows for the identification of specific
requirements for specific groups of products. This option also allows users to extract
structured information from the system for further ad hoc usages by public and/or
private stakeholders.
The main cost centre is related to content management activity. While the IT costs for
setting up the database are more or less average, the effort and resources to structure,
publish and maintain the content (i.e. the regulated information) of the database are
quite significant. Costs for operating Option 2 are significantly lower for each cost item
than for Option 3.
Page VII
Recommendations
Both Option 2 and Option 3 are workable options for the initial step of building the
database. Option 4 and Option 5 can then be used as steps to evolve towards the longterm solution (the vision). This approach allows the cost and impacts on stakeholders
and authorities to be borne over time, without reducing future end-user expectations.
The selection of Option 2 or Option 3 depends on the budget that will be made available.
Accuracy shall not be compromised for any reason and therefore an appropriate budget
should be allocated to ensure that the information provided is complete.
It is recognised that the implementation of Option 2 or Option 3 will require progress
through a number of steps and will require significant time to deliver. In order to
maintain focus, and to show all potential future end-users that there is a strong
commitment towards a vision in the longer term, the study team recommends that a
clear strategic roadmap and vision would be agreed and published showing the proposed
end target model, the proposed steps for moving towards this from the current situation
and the principles that will underpin this development.
The set-up of strong governance would support the implementation of this roadmap. It is
also recommended that all stakeholders are involved as early as possible in the
development of the database regardless of the selected approach (Option 2 or Option 3).
Page VIII
KM-04-14-016-EN-N
DOI: 10.2780/29545
ISBN: 978-92-79-35145-7