In addition to our own view of the topics, we regularly want to shed light on other perspectives and let external people have their say on our blog. Today we publish a conversation with Sarah Melina Siebel, Director Internal Market at spiritsEUROPE:

To kick off, could you kindly explain background and context of the new product label?

It all started with a discussion on why spirit drinks were exempted from the provision of consumer information – which is mandatory for basically all other foodstuffs that you can place on the EU’s Internal Market. There are some good historical and practical reasons for the exemption, given that the production standards and labelling rules for spirits are already tightly regulated under EU law.

Still, whenever consumers were looking for the calorie content of their favourite drink, they were depending on googling around, hoping that the information they would find was correct. With our Memorandum of Understanding (MoU), we want to put an end to this. We ensure that consumers have easy access to reliable, correct and meaningful information – both on the bottle itself as well as online.

In a nutshell, the background to our MoU is that we, as a sector, want to provide full transparency when it comes to consumer information. For us it is crucial that this information is provided in a meaningful, easy to understand way.

What are you most proud of regarding this initiative?

That – so far, at least – we have fully delivered on our commitments. Changing labels is a much more complex and costly process than I had imagined when we kicked off the process. It’s fantastic to see the results of our work in my local supermarket and to be able to show to my friends that our work is making a visible difference!

This is certainly a great achievement! Congratulations! I can however imagine that you also encountered some challenges along the way. Would you mind sharing what they were?

The greatest challenge is the fundamental difference between self-regulation and legally binding rules! When you have legally binding rules, the task is simply to implement them by the deadline provided in the law. In self-regulation, you need to define the rules with your members first. That takes time, as products, traditions and views across Europe differ!

So, it seems that voluntary industry initiatives rather than binding legislation can be an effective tool to achieve the intention of the co-legislators. Could you tell me about your experience with that process? Was the cooperation with policy makers always constructive or did you also face opposition? Especially the European Parliament has often called for binding rules, hasn’t it?

In our case– self-regulation, or better co-regulation, has delivered quick and meaningful success. I prefer the term co-regulation as the European Commission has been an important dialogue partner in the process. They e.g. gave suggestions on which elements our Memorandum of Understanding could contain and attended the signing-ceremony in Paris in June 2019 – which sent an important signal to the sector. Having the EU Health Commissioner attending your launch event showed the members that something big is happening. Also now, the EU COM is interested in how we progress. They keep pushing us – like a good coach. The European Parliament has also provided support in the process, offering us the chance to present our initiative in relevant hearings and meetings.

What is your position on health warnings such as suggested in Europe’s Beating  Cancer plan as by the Commission in February 2021?

Consumer information needs to be proportionate, meaningful, and evidence-based. These principles must guide the discussions on any new proposals regarding health warnings that the Commission may want to present in 2023. From a practical point of view, two things are important for us: as we are just going through a costly and complex label changing process with the Memorandum, we need to be mindful about the timing and extent of any future changes. What we need is a long-term, reliable framework of EU labelling rules so we can plan and invest accordingly. As part of such a process, we also need harmonised rules. Any renationalisation of labelling rules in the EU’s Internal Market would add unnecessary complexity and costs and must be avoided. These are important principles to keep in mind as we approach the debate in 2023.

Your sector can certainly be seen as a frontrunner in the field of digital labelling. Can you briefly explain how it works?

It’s easy – and fun! By scanning a QR code on a bottle, you will be able to access all relevant product-specific information online! The IT backend for this technology is our E-label Platform which we are developing together with the wine sector. The platform is entirely funded by industry means and will be open to all producers. The beta version of the Platform will be piloted in in the next two months for full operational deployment shortly thereafter.

In Spain, the national trade association has teamed up with GS1 Spain to develop a dedicated national digital labelling solution in line with the Memorandum’s commitments. Thanks to the project, already today consumers can access product-specific information from their mobile phone by scanning the barcode. The project’s rollout has been a great success, with 41% of spirit bottles on the Spanish market already providing online consumer information directly through this system.

What learnings you can pass on for other sectors? Either in cooperating within an industry or working with politics on the issue?

Cooperation, consensus and trust – on all ends! Every perspective is relevant – even if it may not be easy to incorporate at first. But then again, this is how we work – on association level, on EU-level, you name it.

Would you say that the future lies in providing consumer information on digital labels rather than conventional on-pack-labelling?

This is not about ‘either – or’ but about ‘as well as’. I think on-pack information will always play an important role. Online information is an amazing way to go beyond the space of a physical label – which is obviously very limited. As technology evolves, so must we as an industry and so must the legal rules in the EU – which so far do not say a word about digital labelling. If we want to keep up with the pace of our times and with consumer expectations, that needs to change. Hence the Commission definitely needs to find ways to integrate digital labelling rules when they revise the general EU Food Labelling Regulation in 2022.

Thank you very much! That was certainly an insightful interview!

Sarah Melina Siebel, SpiritsEUROPE