The Chamber does not support the introduction of Nutri-Score labelling in Estonia

The Ministry of Regional Affairs and Agriculture has prepared a draft regulation intended to allow Estonian food business operators to use the Nutri-Score label on the packaging of food products marketed in Estonia. The Estonian Chamber of Commerce and Industry does not support the introduction of the label, as the state's preference for a particular trademark could adversely affect competitive conditions, lead to additional costs and create misleading impressions among consumers.

The draft regulation seeks to address a situation in which foreign businesses can use the Nutri-Score label on products sold in Estonia, while Estonian businesses do not have this option. In the Chamber's view, insufficient analysis has been carried out into whether, and to what extent, the current situation has caused problems for Estonian businesses and whether introducing the label would help improve their competitiveness.

It is also unclear why the state wishes to establish separate rules specifically for the use of Nutri-Score. The trademark belongs to France's public health agency, but several other voluntary nutrition labels are also used in the European Union. At present, there is insufficient justification for favouring this particular label over other possible solutions.

If the aim is to provide consumers with clear and comparable food information and businesses with equal conditions of competition, preference should, where possible, be given to a solution that works uniformly throughout the European Union's internal market, rather than encouraging the adoption of one particular trademark in Estonia alone.

A voluntary label could become effectively mandatory
Although use of the Nutri-Score label would be voluntary and the right to use it free of charge, its introduction could involve considerable costs. For example, the nutritional composition of products would have to be analysed, scores calculated and packaging designs changed.

Furthermore, if the state establishes a separate legal framework for the use of the Nutri-Score label and begins promoting it to consumers, this could give businesses using the label a competitive advantage. As the label becomes more widespread, retail chains and business partners may begin to favour those using it, meaning that a label that is initially voluntary could become effectively necessary for businesses to remain competitive. This risk is also acknowledged in the explanatory memorandum, but is treated merely as a perceived risk.

Nutri-Score does not provide a comprehensive picture of how healthy a product is
The Chamber also points out that Nutri-Score's simplified colour and letter scale does not provide a comprehensive picture of how healthy a product is. For example, the label does not take into account how much of a product a person consumes or how frequently they consume it. As a result, consumers may be left with the mistaken impression that a product with a higher rating is always a healthier choice. In the Chamber's view, rather than introducing a new label, the focus should be on making existing nutritional information easier to understand and increasing consumer awareness.

The Chamber also believes that it is important to take the views of businesses themselves into account. Both food-sector representative organisations and the Chamber's own members consider the introduction of the Nutri-Score label unnecessary.