ENDORSED: 28 October 2021 www.efsa.europa.eu/publications EFSA Journal 2021 

Scientific Opinion advising on the development of harmonised mandatory front-of-pack nutrition labelling and the setting of nutrient profiles for restricting nutrition and health claims on foods.

EFSA Panel on Nutrition, Novel Foods and Food Allergens (NDA):  Dominique Turck, Torsten Bohn, Jacqueline Castenmiller, Stefaan de Henauw, Karen Ildico, Hirsch‐Ernst, Helle Katrine Knutsen, Alexandre Maciuk, Inge Mangelsdorf, Harry J McArdle, Androniki Naska, Carmen Pelaez, Kristina Pentieva, Frank Thies, Sophia Tsabouri, Marco Vinceti, Jean-Louis Bresson and Alfonso Siani

Abstract: Following a request from the European Commission, the EFSA Panel on Nutrition, Novel Foods and Food Allergens (NDA) was asked to deliver an Opinion advising on the development of harmonised mandatory front-of-pack nutrition labelling and the setting of nutrient profiles for restricting nutrition and health claims on foods. This Opinion is based on systematic reviews and meta-analyses of human studies on nutritionally adequate diets, data from the Global Burden of Disease framework, clinical practice guidelines, previous EFSA opinions and the priorities set by EU Member States in the context of their Food-Based Dietary Guidelines and associated nutrient/food intake recommendations. Relevant publications have been retrieved through comprehensive searches in PubMed. The nutrients included in the assessment have been selected based on expert knowledge. Food groups with important roles in European diets have been considered. The Panel concludes that dietary intakes of SFAs, sodium and added/free sugars are above current dietary recommendations and intakes of dietary fibre and potassium are below current dietary recommendations in a majority of European populations. As excess intakes of SFAs, sodium and added/free sugars and inadequate intakes of dietary fibre and potassium are associated with adverse health effects, they could be included in nutrient profiling models. Energy could be included in the model because a reduction in energy intake is of public health importance for European populations. In food group/category-based nutrient profiling models, total fat could replace energy owing to its high energy density in most food groups, while the energy density of food groups with low or no fat content may be well accounted for by the inclusion of (added/free) sugars in the model. Nutrients and non-nutrient components may be included in nutrient profiles for reasons other than their public health importance to allow for a better discrimination of foods within the same food category. 

© 2021 European Food Safety Authority

Food-Based Dietary Guidelines (FBDG) References

United Nations Children’s Fund (UNICEF). Review of national Food-Based Dietary Guidelines and associated guidance for infants, children, adolescents, and pregnant and lactating women. New York: UNICEF, 2020.

Dietary Guidelines for Americans, 2020-2025 (.gov PDF)

EFSA Section 1.4 - Introduction

The Panel understands that the scientific advice requested relates to the identification of: Nutrients and foods, including non-nutrient components of food (e.g., energy, dietary fibre), that are of importance for public health in European populations. These include nutrients and foods that might be consumed in excess, as well as those for which intakes might be inadequate, in the context of current dietary recommendations on healthy diets either by European countries or independent scientific bodies. b) Food groups with important dietary roles in European populations and subgroups thereof owing to their nutrient composition and their (habitual) intake, as recognised by Member States in FBDGs. FBDGs also make distinctions between different foods within these food groups based on their potential to influence, beneficially or adversely, the& overall dietary balance for certain nutrients. The dietary roles of these food groups might differ across Member States owing to the variability of dietary habits and traditions. c) Criteria that could guide the choice of nutrients, including non-nutrient components of food, for the nutrient profiling of foods, with the scope of developing harmonised mandatory FOP nutrition labelling and the setting of nutrient profiles for restricting nutrition and health claims on foods. The Panel also understands that this mandate is not a request to develop a nutrient profiling model or to provide advice on current profiling models already in use for different purposes. The Panel further understands that the mandate is restricted to providing advice on the relationships between nutrients, non-nutrient components, foods and food groups and diet-related chronic diseases and does not cover any considerations related to the sustainability of the food chain. The Panel acknowledges that, in addition to scientific considerations, other issues may be taken into account by the European Commission in establishing nutrient profiling models for the above-mentioned purposes, e.g., feasibility and product innovation.

Jones. Nutrition Journal 2014, 13:34 http://www.nutritionj.com/content/13/1/34

EFSA Panel on Dietetic Products, Nutrition, and Allergies (NDA); Scientific Opinion on Dietary Reference Values for carbohydrates and dietary fibre. EFSA Journal 2010; 8(3):1462 [77 pp.] 

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.

EFSA Section 3.1.2.3 Dietary fibre  

Dietary fibre has been defined in several ways for risk assessment and management purposes. In EFSA’s Scientific Opinion on DRVs for carbohydrates and dietary fibre (EFSA NDA Panel, 2010b), dietary fibre denotes all non-digestible carbohydrates. This includes non-starch polysaccharides, resistant starches, resistant oligosaccharides with three or more monomeric units and other non- 6 digestible, but quantitatively minor components that are associated with the dietary fibre polysaccharides, especially lignin. The most recent definitions of dietary fibre proposed at national and international level are quite consistent, but differences exist regarding whether: a) associated substances (e.g., lignin) are explicitly mentioned, b) the minimum number of monosaccharide units that are required to be included in the definition, and c) the requirement, mainly for extracted, isolated, modified or synthetic carbohydrate polymers, that they have a proven health benefit (Stephen et al., 2017). Most authorities provide non-exhaustive lists of health benefits related to dietary fibre, the most common being in the areas of bowel function, and of lipid and glucose metabolism. The definition of dietary fibre for regulatory purposes in the EU is laid down in Regulation (EU) No 1169/2011. The main characteristics that may mediate the health effects of dietary fibre include viscosity and the capacity to form gels in the intestinal tract, fermentability in the colon, and water-holding capacity.

Dietary fibre helps to maintain normal bowel function and alleviates constipation by decreasing colonic transit time and increasing faecal mass (EFSA NDA Panel, 2010b; Portalatin and Winstead, 2012). Dietary fibre increases stool bulk by enhancing the water-holding capacity of stools (Portalatin and Winstead, 2012). Fermentable components of dietary fibre are metabolised by the microbiota, which stimulates microbial growth and increases faecal bulk (Cummings, 2001). The intake of dietary fibre as found in mixed diets has been inversely associated to the risk of developing CVD and T2DM in prospective cohort studies (EFSA NDA Panel, 2010b). This is supported by the results of recent meta-analyses investigating the relationship between dietary fibre intake and CHD (Threapleton et al., 2013; McRae, 2017), stroke (Zhang et al., 2013; McRae, 2017), cardiovascular mortality (McRae, 2017), and T2DM (Yao et al., 2014). The mechanisms by which dietary fibre could affect CVD and T2DM risk are not fully elucidated but may depend on the characteristics of the different fibre types. The viscosity and gel-forming capacity in the intestinal tract appear to influence glucose and lipid metabolism. Viscous fibres have shown to delay carbohydrate absorption and decrease the postprandial glycaemic responses to carbohydrate-rich meals. They could also lower blood total and LDL-cholesterol concentrations (Bazzano, 2008) by increasing the viscosity of the gut content, enhancing bile acid synthesis and excretion of bile acids and cholesterol in faeces (Ellegård and Andersson, 2007; Wolever et al., 2010; Wang et al., 2017).

The effect of dietary fibre on cardiometabolic risk is generally expected to occur at dietary fibre intakes above the AI (EFSA NDA Panel, 2010b). Average intakes of dietary fibre across European adult populations are in all surveys, except one, below the AI of 25 g/day (data from national dietary surveys) (EFSA NDA Panel, 2010b). A more recent compilation of national intake data compiled by the European Commission is mostly in line with this observation. In children, the AI of 2 g/MJ was exceeded in around half of the surveys; in the other half, mean intakes ranged from 1.7 to 1.9 g/MJ. The Panel considers that adequate intake of dietary fibre contributes to maintaining normal bowel function and normal laxation and contributes to reducing the risk of CVD and T2DM. Taking into account that intakes of a majority of European adult populations are below recommendations, and that chronic disease risk reduction could take place at intakes above those recommended for the maintenance of normal bowel function, the Panel considers that an increase in dietary fibre intake is of public health importance for European populations.

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 re pealing 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. OJ L 304, 22.11.2011, p. 18–63

Perry JR, Ying W (2016) A Review of Physiological Effects of Soluble and Insoluble Dietary Fibers. J Nutr Food Sci 6: 476. 

Thomas Barber, Stefan Kabisch, Andreas F. H. Pfeiffer, Martin O. Weickert (2020) The Health Benefits of Dietary Fiber.  Nutrients 12, 3209.

Chunye Chen, Yuan Zeng, et al (2016) Therapeutic effects of soluble dietary fiber consumption on type 2 diabetes mellitus.  EXPERIMENTAL AND THERAPEUTIC MEDICINE 12: 1232-1242.

Hannah D. Holscher (2017) Dietary fiber and prebiotics and the gastrointestinal microbiota. GUT MICROBES VOL. 8, NO. 2, 172–184.

Joanne Slavin (2013) Fiber and Prebiotics: Mechanisms and Health Benefits. Nutrients, 5, 1417-1435.

JL Slavin, V Savarino, A Paredes-Diaz, G Fotopoulos (2009) A Review of the Role of Soluble Fiber in Health with Specific Reference to Wheat Dextrin.  The Journal of International Medical Research 37: 1 – 17.

Jennifer Huizen  “Soluble and insoluble fiber: What is the difference?” Medical News Today, Aug. 31, 2017.

Ana Sandoiu “Study reveals how much fiber we should eat to prevent disease”  Medical News Today, Jan. 11, 2019.

EFSA Section 3.1.2.7 Calcium and vitamin D 

Insufficient dietary supply of calcium leads to resorption of calcium from bone, causing a loss of bone 1040 mass that can result in osteopenia (i.e., lower than normal bone mineral density (BMD) and osteoporosis 1041 (EFSA NDA Panel, 2015a). Inadequate intakes of vitamin D lead to inefficient absorption of dietary 1042 calcium and phosphorus, and thus causes an impaired mineralisation of bone (EFSA NDA Panel, 2016b).  However, also genotype and environmental and lifestyle factors other than calcium and vitamin D intake play key roles in the maintenance of BMD (EFSA NDA Panel, 2015a).  Combined intakes of calcium and vitamin D at levels of or above 1,200 mg and 800 IU per day, respectively, have been associated with a reduction of the risk of osteoporotic fractures (EFSA, 2009; EFSA NDA Panel, 2010a). Also, there is evidence that intakes of vitamin D and calcium, as compared to calcium alone, reduce the risk of falling (EFSA NDA Panel, 2011a). More recent meta-analyses are in line with these findings (Yao et al., 2019; Thanapluetiwong et al., 2020).

Unlike other vitamins, vitamin D3 can be synthesised in the body following exposure to sunlight or artificial UV-B irradiation. Dietary intake is, however, essential when the endogenous synthesis is insufficient to cover requirements. Factors affecting the endogenous synthesis of vitamin D3 include latitude, season, ozone layer and clouds (absorbing UV-B irradiation), surface characteristics (reflecting UV-B irradiation), time spent outdoors, use of sunscreen, clothing, skin colour and age. As these factors may vary considerably, DRVs have been derived based on the assumption that the endogenous vitamin D synthesis is minimal (EFSA NDA Panel, 2016b). Taking this into account, EFSA has set an AI for vitamin D for adults, including pregnant and lactating women, and children aged 1–17 years of 15 μg/day. For infants aged 7–11 months an AI of 10 μg/day was derived (EFSA NDA Panel, 2016b). These AIs can, however, mostly not, be achieved by dietary intakes alone. Intakes of around 16 μg/day from food alone (i.e., somewhat higher than the AI) were only achieved in high consumers (95th percentile), according to published dietary intake data (EFSA NDA Panel, 2016b). Dietary sources of vitamin D are mostly fatty fish and eggs, food supplements and fortified foods. Small amounts are also provided by meat (Spiro and Buttriss, 2014).

The prevalence of inadequate vitamin D status, i.e., serum 25(OH)D concentrations of <45 or 50 nmol/L, in Europe was reviewed by Spiro and Buttriss (2014). Studies from Austria, France, Germany, the Netherlands, Spain and Northern Europe showed that the prevalence of serum 25(OH)D concentrations of <45 or 50 nmol/L ranged from about 28 to 67% in adults. For children, data from Austria showed that around 40% of 7-14-year-old children were below this cut-off and that 92% of 13-year old children from Denmark, Finland, Ireland and Poland did not reach serum 25(OH)D concentrations of 45-50 nmol/L. Being at a higher risk of vitamin D inadequacy, the following population groups are often advised to take vitamin D supplements: infants and young children, pregnant and breast-feeding women, older people, individuals with low or no sun exposure, people with darker skin living in Europe (e.g., NICE, 2014; Rusińska et al., 2018).

The Panel considers that adequate intakes of calcium and vitamin D are required for the maintenance of bone mass. A reduction in the risk of osteoporotic fractures and the risk of falling has only been evidenced beyond the PRI at intakes of and above 1,200 mg calcium and 800 IU vitamin D per day. The Panel notes that vitamin D status in European populations is inadequate in a large proportion of children and adults living in Europe and that population groups at particular risk of inadequate status are well known. The Panel also notes that dietary intakes of calcium may be inadequate in adolescents. Even though elderly may have sufficient calcium intakes compared with the DRVs, intakes may not be sufficient to reduce the risk of osteoporotic fractures and the risk of falling, especially if associated with a suboptimal vitamin D status. The Panel considers that whether an increase in calcium intake is beneficial may depend on the population group and that in some cases the recommended intake cannot be achieved through dietary modifications alone. The Panel also considers that vitamin D inadequacy in at-risk populations identified in the national context is ideally addressed by national policies in Member States.

Vitamin D health impacts beyond osteoporosis

Rejnmark L, Bislev LS, Cashman KD, Eirı ́ksdottir G, Gaksch M, Gru ̈bler M, et al. Non-skeletal health effects of vitamin D supplementation: A systematic review on findings from meta-analyses summarizing trial data. PLOS ONE. July 7, 2017.\

Pieter-Jan Martens, Conny Gysemans, Annemieke Verstuyf and Chantal Mathieu. Vitamin D’s Effect on Immune Function. Nutrients 2020, 12, 1248.

Sylvia Christakos, Puneet Dhawan, Annemieke Verstuyf, Lieve Verlinden, and Geert Carmeliet. Vitamin D: Metablolism, Molecular Mechanism of Action and Pleiotropic Effects. Physiol Rev. 2016 Jan; 96(1): 365– 408. Published online 2015 Dec 16. doi: 10.1152/physrev.00014.2015: 10.1152/physrev.00014.2015 PMID: 26681795

Edith Klahol, Marissa Penna-Martinez*, Franziska Bruns, Christian Seidl, Sabine Wicker, Klaus Badenhoop. Vitamin D in Type 2 Diabetes: Genetic Susceptibility and the Response to Supplementation. Horm Metab Res 2020; 52: 492–499.

Stephanie R. Harrison, Danyang Li, Louisa E. Jefery, Karim Raza, Martin Hewison. Vitamin D, Autoimmune Disease and Rheumatoid Arthritis. Calcifed Tissue International (2020) 106:58–75.

Ao, T.; Kikuta, J.; Ishii, M. The Effects of Vitamin D on Immune System and Inflammatory Diseases. Biomolecules 2021, 11, 1624

Cynthia Aranow, MD. Vitamin D and the Immune System. J Investig Med. 2011 August; 59(6): 881–886.

Ao T, Kikuta J, Ishii M. Update on recent progress in vitamin D research. The effects of vitamin D in autoinflammatory diseases. Clin Calcium. 2017;27(11):1551-1559.

Piumika Sooriyaarachchi, Dhanushya T Jeyakumar, Neil King, Ranil Jayawardena. Impact of vitamin D deficiency on COVID-19. Clin Nutr. ESPEN, 2021 Aug;44:372-378

Maryam Nasiria, *, Javad Khodadadia , Sedigheh Molaei. Does vitamin D serum level affect prognosis of COVID-19 patients? International Journal of Infectious Diseases 107 (2021) 264–267.

Kai Yin and Devendra K Agrawal. Vitamin D and Inflammatory Disease. J Inflamm Res. 2014; 7: 69–87.

Vitamin D and EU Insufficient Intake

Shining a light on vitamin D deficiency in Europe | Horizon 2020 (europa.eu)

Kevin D Cashman,* Kirsten G Dowling, Zuzana Skrabáková et al. Vitamin D deficiency in Europe: pandemic? Am J Clin Nutr 2016;103:1033–44

Paul Lips, Kevin D Cashman, Christel Lamberg-Allardt, et al. Current vitamin D status in European and Middle East countries and strategies to prevent vitamin D deficiency. European Journal of Endocrinology (2019) 180, P23–P54.

Role of food groups in European diets as addressed in food-based dietary guidelines of EU Member States Twenty-eight FBDGs from 27 EU Member States were considered in this Opinion, as compiled by Wollgast et al. (2018). Belgium had two FBDGs, one for Flanders and one for Wallonia...

Legumes and pulses: Legumes and pulses provide carbohydrates, dietary fibre and protein and are also rich in micronutrients. Recommendations in FBDGs to consume legumes span from consumption of 1-2 times per week to up to 3-4 times per week. The consumption of legumes and pulses is specifically encouraged in six FBDGs and in another 10 the substitution of meat with legumes and pulses is recommended. Canned legumes and pulses may contain significant amounts of added sodium.  The associated FoodEx 2 term name is ‘legumes’ at level 2, nested within ‘legumes, nuts, oilseeds and spices’ (level 1).

Meat and meat products (including offal): Meat is a good source of high-quality protein, iron, zinc, some vitamins (e.g., vitamin A and D) and MUFAs. Meat and meat products may, however, contribute significantly to the intake of SFAs and added sodium in case of processed meat. Most FBDGs recommend limiting meat intake typically to around 300-600 g per week, mainly choosing lean meats, and not eating meat every day. Some FBDGs specifically suggest reducing consumption of red meat and processed meat. As alternatives to meat, fish, eggs, pulses and products thereof, including tofu, and mycoprotein-based foods as well as seitan are mentioned.

Nutritional Composition of Novel Plant-Based Meat Alternatives and Traditional Animal-Based Meats (PDF)
2021. Journal of Food Science & Nutrition. Caleb J Swing, Tyler W Thompson, Octavio Guimaraes, Ifigenia Geornaras, Terry E Engle, Keith E Belk, Cody L Gifford and Mahesh Narayanan Nair

EFSA Section 3.2.3 - Food Groups Conclusions 

Conclusions:  Food groups with important and specific dietary roles in European diets include starchy foods (cereals and potatoes), fruits and vegetables, legumes and pulses, milk and dairy products, meat and meat products, fish and shellfish and products thereof, nuts and seeds, and non-alcoholic beverages, as recognised in FBDGs in Member States. However, the dietary roles of& these food groups and their relative contribution to the overall diet may vary across individual countries owing to the variability of dietary habits and traditions.  Dietary recommendations made in FBDGs by EU Member States reflect the available evidence on the consumption of certain food groups and their relationship with chronic disease risk, as reviewed in Section 3.2.2. Emphasis is put on increasing the consumption of whole grains, fruits and vegetables (in a wide variety), nuts and seeds, fish and water. Specific food products within some of these food categories that are high in SFAs, sugars and/or sodium owing to food processing are generally discouraged. Most FBDGs recommend limiting meat intake, some suggesting specifically the reduction of unprocessed red and processed meat consumption. FBDGs encourage regular consumption of fat reduced milk and dairy products, the consumption of legumes and pulses instead of meat, and the consumption of vegetable oils rich in cis-MUFAs and cis-PUFAs instead of fats high in SFAs. The Panel notes that food groups with an important role in the diet of European populations and subgroups thereof have been identified by Member States in FBDGs. The Panel also notes that FBDGs also distinguish between different products within these food groups based on their potential to influence, beneficially or adversely, the overall dietary balance for certain nutrients.

IFT Food Processing Toolkit (PDF)
IFT-developed Advocacy Toolkit that provides helpful fact-based information to assist with communication on the topic of food processing

EFSA Section 3.3: Choice of nutrients and non-nutrient components of foods for nutrient- profiling 

The choice of nutrients and non-nutrient components of food to set nutrient profiling models, the purpose of restricting claims on foods and the purpose of FOP labelling, should be driven by their public health importance for EU populations, as discussed in Section 3.1.

Dietary intakes of SFAs, sodium and added/free sugars on one hand, and dietary fibre on the other, are respectively above and below current recommendations in a majority of European populations, and could be considered for inclusion in nutrient profiling models based on their public health importance for European populations.

Energy could be included in nutrient profiling models because a decrease in energy intake is of public health importance for European populations owing to the high prevalence of overweight and obesity and the positive relationship between high energy dense-diets and risk of weight gain. The energy density of foods and of dairy-based beverages is mostly determined by their fat and water content, owing to their extreme energy values, while the energy density of non-alcoholic water-based beverages is mostly driven by their sugar content. In certain food groups (e.g., cereal products), dietary fibre may additionally contribute to the energy density of foods. Differences in water content may confound energy comparisons across foods and are bigger across food groups (e.g., between solid foods and beverages) than within food groups. This confounding is a great disadvantage when energy is used in nutrient profiling models intended for application across the board. Still, energy may be a suitable criterion if applied within food groups, where the water content is relatively consistent across products in the group. In food group/category-based nutrient profiling models, total fat could replace energy owing to its high energy density in most food groups, while the energy density of food groups with low or no fat content (e.g., water-based non-alcoholic beverages, jams and marmalades) may be well accounted for by the inclusion of (added/free) sugars in the model. However, total fat does not allow the discrimination of foods based on the nutritional quality of their fat content. Therefore, total fat cannot replace SFAs in nutrient profiling models, unless food products in a group are relatively homogeneous regarding their fat quality (e.g., milk and dairy products). In addition to sodium, for which intakes are above recommendations, other vitamins and minerals of public health importance could be considered, mostly because their intakes in European populations or certain subgroups thereof are lower than recommended. These include potassium, iron, calcium, vitamin D, folate and iodine (see Section 3.1.2).

Some nutrients and non-nutrient components may be included in nutrient profiling models for reasons other than their public health importance to allow for a better discrimination of foods within the same food category. In this context, n-3 LC-PUFAs, for which fish and shellfish including products thereof are almost the only dietary source, could be included in nutrient profiling models owing to the large differences among fish species regarding the content of these fatty acids. This is despite current uncertainties on whether intakes may be below current recommendations in some EU Member States. Another consideration in the choice of the nutrients and non-nutrient components to be included in a nutrient profiling system is the feasibility of the nutrient profile in practice. The larger the number of components included, the more complex the nutrient profile becomes in its application.

EFSA Section 3.3: Choice of nutrients and non-nutrient components of foods for nutrient- profiling 

The choice of nutrients and non-nutrient components of food to set nutrient profiling models, the purpose of restricting claims on foods and the purpose of FOP labelling, should be driven by their public health importance for EU populations, as discussed in Section 3.1.

Dietary intakes of SFAs, sodium and added/free sugars on one hand, and dietary fibre on the other, are respectively above and below current recommendations in a majority of European populations, and could be considered for inclusion in nutrient profiling models based on their public health importance for European populations.

Energy could be included in nutrient profiling models because a decrease in energy intake is of public health importance for European populations owing to the high prevalence of overweight and obesity and the positive relationship between high energy dense-diets and risk of weight gain. The energy density of foods and of dairy-based beverages is mostly determined by their fat and water content, owing to their extreme energy values, while the energy density of non-alcoholic water-based beverages is mostly driven by their sugar content. In certain food groups (e.g., cereal products), dietary fibre may additionally contribute to the energy density of foods. Differences in water content may confound energy comparisons across foods and are bigger across food groups (e.g., between solid foods and beverages) than within food groups. This confounding is a great disadvantage when energy is used in nutrient profiling models intended for application across the board. Still, energy may be a suitable criterion if applied within food groups, where the water content is relatively consistent across products in the group. In food group/category-based nutrient profiling models, total fat could replace energy owing to its high energy density in most food groups, while the energy density of food groups with low or no fat content (e.g., water-based non-alcoholic beverages, jams and marmalades) may be well accounted for by the inclusion of (added/free) sugars in the model. However, total fat does not allow the discrimination of foods based on the nutritional quality of their fat content. Therefore, total fat cannot replace SFAs in nutrient profiling models, unless food products in a group are relatively homogeneous regarding their fat quality (e.g., milk and dairy products). In addition to sodium, for which intakes are above recommendations, other vitamins and minerals of public health importance could be considered, mostly because their intakes in European populations or certain subgroups thereof are lower than recommended. These include potassium, iron, calcium, vitamin D, folate and iodine (see Section 3.1.2).

Some nutrients and non-nutrient components may be included in nutrient profiling models for reasons other than their public health importance to allow for a better discrimination of foods within the same food category. In this context, n-3 LC-PUFAs, for which fish and shellfish including products thereof are almost the only dietary source, could be included in nutrient profiling models owing to the large differences among fish species regarding the content of these fatty acids. This is despite current uncertainties on whether intakes may be below current recommendations in some EU Member States. Another consideration in the choice of the nutrients and non-nutrient components to be included in a nutrient profiling system is the feasibility of the nutrient profile in practice. The larger the number of components included, the more complex the nutrient profile becomes in its application.

CODEX General Standards for Cheese (PDF) 
CODEX Standard 283-1978.This Standard applies to all products, intended for direct consumption or further processing, in conformity with the definition of cheese in Section 2 of this Standard. Subject to the provisions of this Standard, standards for individual varieties of cheese, or groups of varieties of cheese, may contain provisions which are more specific than those in this Standard and in these cases, those specific provisions shall apply.

The Panel concludes that:

• food groups with important and specific dietary roles in European diets include starchy foods (cereals and potatoes), fruits and vegetables, legumes and pulses, milk and dairy products, meat and meat products, fish and shellfish and products thereof, nuts and seeds, and non-alcoholic beverages, as recognised in FBDGs in Member States. The dietary roles of these food groups and their relative contribution to the overall diet may vary across individual countries owing to the variability of dietary habits and traditions.
• dietary recommendations made in FBDGs by EU Member States reflect the available evidence on the consumption of certain food groups and their relationship with chronic disease risk. Consumption of whole grains, fruits and vegetables, nuts and seeds, fat-reduced milk and dairy products, fish and water is encouraged, whereas food products high in SFAs, sugars and/or sodium owing to food processing are generally discouraged, even within these food categories. FBDGs also encourage regular consumption of legumes and pulses instead of meat (particularly red meat and processed meat), and the consumption of vegetable oils rich in cis-MUFAs and 1457 cis-PUFAs instead of fats high in SFAs. 1458
• dietary intakes of SFAs, sodium and added/free sugars are above current dietary recommendations in a majority of European populations; excess intakes of these nutrients are associated with adverse health effects and therefore they could be considered for inclusion in nutrient profiling models based on their public health importance for European populations;
• energy could be included in nutrient profiling models because a decrease in energy intake is of public health importance for European populations; in food group/category-based nutrient profiling models, total fat could replace energy owing to its high energy density in most food groups, while the energy density of food groups with low or no fat content (e.g. water-based non- alcoholic beverages, jams and marmalades) may be well accounted for by the inclusion of (added/free) sugars in the model.
• intakes of dietary fibre and potassium are below current dietary recommendations in a majority of European adult populations; inadequate intakes of dietary fibre and potassium are associated with adverse health effects and therefore dietary fibre and potassium could be considered for inclusion in nutrient profiling models based on their public health importance for European populations;
• dietary intakes of iron, calcium, vitamin D, folate and iodine are below current dietary recommendations in specific sub-groups of European populations only in which dietary modifications alone may not be sufficient (or appropriate) to fulfil the nutrient requirements; inadequate intakes of these nutrients are usually addressed by national nutrition policies in Member States and/or individual advice;
• nutrients and non-nutrient components of food may be included in nutrient profiling models for reasons other than their public health importance to allow for a better discrimination of foods within the same food category.

The Panel concludes that:

• food groups with important and specific dietary roles in European diets include starchy foods (cereals and potatoes), fruits and vegetables, legumes and pulses, milk and dairy products, meat and meat products, fish and shellfish and products thereof, nuts and seeds, and non-alcoholic beverages, as recognised in FBDGs in Member States. The dietary roles of these food groups and their relative contribution to the overall diet may vary across individual countries owing to the variability of dietary habits and traditions.
• dietary recommendations made in FBDGs by EU Member States reflect the available evidence on the consumption of certain food groups and their relationship with chronic disease risk. Consumption of whole grains, fruits and vegetables, nuts and seeds, fat-reduced milk and dairy products, fish and water is encouraged, whereas food products high in SFAs, sugars and/or sodium owing to food processing are generally discouraged, even within these food categories. FBDGs also encourage regular consumption of legumes and pulses instead of meat (particularly red meat and processed meat), and the consumption of vegetable oils rich in cis-MUFAs and 1457 cis-PUFAs instead of fats high in SFAs. 1458
• dietary intakes of SFAs, sodium and added/free sugars are above current dietary recommendations in a majority of European populations; excess intakes of these nutrients are associated with adverse health effects and therefore they could be considered for inclusion in nutrient profiling models based on their public health importance for European populations;
• energy could be included in nutrient profiling models because a decrease in energy intake is of public health importance for European populations; in food group/category-based nutrient profiling models, total fat could replace energy owing to its high energy density in most food groups, while the energy density of food groups with low or no fat content (e.g. water-based non- alcoholic beverages, jams and marmalades) may be well accounted for by the inclusion of (added/free) sugars in the model.
• intakes of dietary fibre and potassium are below current dietary recommendations in a majority of European adult populations; inadequate intakes of dietary fibre and potassium are associated with adverse health effects and therefore dietary fibre and potassium could be considered for inclusion in nutrient profiling models based on their public health importance for European populations;
• dietary intakes of iron, calcium, vitamin D, folate and iodine are below current dietary recommendations in specific sub-groups of European populations only in which dietary modifications alone may not be sufficient (or appropriate) to fulfil the nutrient requirements; inadequate intakes of these nutrients are usually addressed by national nutrition policies in Member States and/or individual advice;
• nutrients and non-nutrient components of food may be included in nutrient profiling models for reasons other than their public health importance to allow for a better discrimination of foods within the same food category.