Front-of-pack nutrition labelling: a tussle between EU food law and national measures

In May 2020, the European Commission published its Farm to Fork Strategy, which committed to propose harmonised mandatory front-of-pack nutrition labelling (‘FoPNL’) to help empower consumers to make informed, healthy food choices. This article explores how EU food information law regulates FoPNL, and the implications for the development of effective FoPNL. First, it argues that regulating FoPNL effectively at EU level is important to promote both a high level of consumer protection and the functioning of the internal market. Secondly, it demonstrates that not only is EU law currently an obstacle to the development of effective FoPNL at national level, but that Member States also promote schemes which are incompatible with the provisions of EU law. Thirdly, it concludes by presenting how the EU should harmonise FoPNL with a single EU-wide mandatory scheme or, should the EU fail to agree on a specific scheme, for the EU to adopt a legislative framework which allows Member States to introduce effective, mandatory FoPNL schemes at national level.