CONTRIBUTION REGARDING THE TRIS NOTIFICATION 2023/0510/FR - Decree on the use of certain designations used to describe foods containing vegetable proteins
Prague, Bratislava, November 23rd, 2023
On 23/08/2023, France submitted the French national decree entitled “Decree on the use of certain designations used to describe foods containing vegetable proteins” to the TRIS notification system. This is a decree which should ensure the protection of names of food of animal origin from being used to market their plant-based alternatives and imitations.
On behalf of the Czech Agrarian Chamber, the Agricultural Association of the Czech Republic and the Slovak Agriculture and Food Chamber, we would like to call on the European Commission and EU Member States to support this version of the French decree. We believe that the proposal is in line with many of the objectives of the European Green Deal, whether in terms of strengthening the position of farmers in the supply chain, providing transparent and non-misleading information to consumers on the true origin of food, shortening supply chains or maintaining the development and viability of rural farmers and small and medium-sized farmers.
At the same time, we do not believe that any of the objectives of the European Green Deal will be complicated by this proposal. The European Commission's Farm to Fork strategy promotes the strengthening of the consumption of food of plant origin, but the example of milk and dairy products, the names of which are already protected in the European Union, shows that, for example, protecting the name 'milk' does not lead to the disappearance of the product or a reduction in sales of the food in question. The protection of milk and dairy names is already a relatively successful example, which, although it requires more rigorous implementation by the supervisory authorities of the Member States, does not lead to discrimination between one foodstuff and another, but rather to greater transparency in the market and greater consumer awareness.
We also find it quite worrying that, if we do not protect the names of food of animal origin and in combination with future nutrition labelling schemes, it could easily bring us into a situation where future food labelling in EU gives highest consumption priority to highly processed and wrongly labelled reformulated imitations of foodand allow manufacturers of these artificial products systemically masking their true nutrition value and health impacts. Such a system would seriously mislead European Consumers and incentivize them to make wrong nutrition and health choices. A system that is for sure not to the benefit of our citizens but perhaps only to the benefit of a business model of some Big Food and Big Retail.
Excessive consumption of highly processed foods is strongly discouraged by a number of institutions, including, for example, the FAO - UN, because it is suspected of causing a number of chronic non-communicable diseases, including cardiovascular disease or cancer and obesity. The Joint Research Centre (JRC) has also highlighted the need to include the issue of food processing levels in the debate on sustainable and good nutrition.The promotion of highly processed foods through a nutritional labelling that is overly simplistic and by allowing these foods to use the names of foods of animal origin, does not transparently inform consumers about the content of harmful and/or synthetic substances in the food (while the long-term effects of consuming these substances on human health have often not yet been properly assessed) is unacceptable. This system will only lead to consumer confusion, to their preference for 'green labelled' foods, to a lack of essential nutrients in diet, and may lead to development of non-communicable diseases, i.e. to a development which EU for long attempts to reverse by means of all relevant strategies and contrary to Commissioner Kyriakides own statement: "we will succeed and ensure that sustainable and healthy diets are the easy choice for consumers." 
We find it very worrying that artificial products imitating eggs, fish, honey, meat and other products of animal origin are now allowed to be named in the same way as traditional foods. According to a number of studies these artificial products are nutritionally completely different and incomparable to traditional foods of animal origin. Failure to extend name protection to meat and meat products and other foods of animal origin will only increase consumer confusion and encourage the consumption of highly processed foods. Imitations aim to have the same taste, appearance, texture and preparation as animal foods.
Finally, we would like to remind you that in April 2023, the UN Food and Agriculture Organisation (FAO) published a new report focusing on the role of animal foods in human nutrition. In its report, the FAO states that meat, eggs and milk are essential sources of nutrients, particularly for the most vulnerable populations, and that these nutrients cannot be easily obtained from plant-based foods. These include a range of important macronutrients including protein, fat and carbohydrates, but also micronutrients including essential fatty acids, iron, calcium, zinc, selenium, vitamin B12, choline, carnitine, creatine and taurine. Globally, more than one in two pre-school children (372 million children) and 1.2 billion women of childbearing age are deficient in iron, vitamin A or zinc. According to the FAO, food of animal origin is particularly important at key life stages such as pregnancy, lactation, childhood, adolescence and old age.
The use of species names and traditional names for food of animal origin evokes the impression among consumers that the food is of comparable nutritional value. Incorrect dietary choices can have very serious public health implications and cause malnutrition in consumers who switch from animal to misconceived plant-based production. Vulnerable groups are especially young children, pregnant and lactating women and the elderly. We therefore call on the European Commission to work towards the adoption of harmonised food labelling rules that will protect the names of foodstuffs of animal origin from being misused to label their plant-based imitations, as well as harmonised rules for their marketing and labelling. Until the rules are adopted, we ask the European Commission not to prevent individual countries from adopting legislation that protects the interests of their citizens, both in terms of truthful information and protection of public health.
Mr. Martin Pýcha, President of the Agricultural Association of the Czech Republic
Mr. Jan Doležal, President of the Czech Agrarian Chamber
Mr. Emil Macho, President of the Slovak Agriculture and Food Chamber
 Monteiro, C.A., Cannon, G., Lawrence, M., Costa Louzada, M.L. and Pereira Machado. Ultra-processed foods, diet quality, and health using the NOVA classification system. Rome, FAO. 2019. LINK
 Bock, A.K., Bontoux, L., Rudkin, J. Concepts for a sustainable EU food system, Publications Office of the European Union, Luxembourg, 2022, ISBN 978-92-76-43727-7, doi:10.2760/381319, JRC126575. LINK
 S. Kyriakides, speech, 26th of September 2022: LINK
 Kalyn, M. Colard MD, David P. McCormick, MD. A Nutritional Comparison of Cow's Milk and Alternative Milk Products, August 2021: LINK
 Mudasir, Ahmad, Shahida, Qureshi, Mansoon Hussain Akbar, Shahida Anusha Siddiqui, Adil Gani, Mehvesh Mushtaq, Ifrah Hassan, Sanju Bala Dhull. Plant-based meat alternatives: compositional analysis, current development and challenges. 2022: LINK