Message 001
Communication from the Commission - TRIS/(2026) 2798
Directive (EU) 2015/1535
Notification: 2026/0541/SE
Notification of a draft text from a Member State
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MSG: 20262798.EN
1. MSG 001 IND 2026 0541 SE EN 06-10-2026 SE NOTIF
2. Sweden
3A. Kommerskollegium
3B. Livsmedelsverket
4. 2026/0541/SE - C50A - Foodstuffs
5. Regulations amending the Swedish Food Agency’s regulations (SLVFS 2005:9) on the use of the Keyhole symbol
6. Foodstuff
7.
Regulation (EC) No 1924/2006 concerning nutrition and health claims made on foods: Article 23
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8. The purpose of the Keyhole symbol is to make it easier for consumers to choose healthier food alternatives in different food groups. By choosing products marked with the Keyhole symbol, consumers automatically consume more fibre and whole grains, less salt and sugar, and healthier fats. The scientific basis for the ‘keyhole’ criteria are the Nordic Nutrition Recommendations (NNR). The NNR were updated in 2023, which is why the regulations now need to be amended.
The Keyhole label is voluntary to use. In addition to Sweden, the Keyhole label is also used in Denmark, Iceland, Norway, the Faroe Islands and Lithuania. There is also an agreement with North Macedonia allowing them to use the Keyhole symbol. There is a Nordic agreement between Sweden, Denmark, Norway and Iceland. Denmark, Norway and Iceland have similar regulations in their national legislation as LIVSFS 2005:9. The other countries that have agreements with the Swedish Food Agency to use the Keyhole label must, in accordance with those agreements, comply with the provisions of LIVSFS 2005:9. In the light of the above, the Agency has concluded that it is not necessary to include a mutual recognition clause.
9. The regulations govern the use of the Keyhole symbol, which is a symbol for what is referred to as nutrition claims. The Swedish Food Agency proposes amendments to the Swedish Food Agency’s regulations (SLVFS 2005:9) on the use of the Keyhole symbol. The proposal primarily concerns nutritional changes aimed at ensuring that the criteria for the Keyhole label are in line with the Nordic Nutrition Recommendations (NNR). The proposal has been drawn up in cooperation with Denmark, Norway and Iceland, which have regulations equivalent to LIVSFS 2005:9 in their national legislation. A substantively similar proposal for amendments, with the exception of the linguistic adjustments, is also being circulated in Denmark, Iceland and Norway.
A longer transitional period is proposed to allow producers time to adapt production and labelling to the revised criteria. In this revision, the main focus has been on reducing salt content in different food groups (so that the total salt intake by the population can be reduced, thus contributing to supporting the Nordic Nutrition Recommendations), increasing the requirements for whole grains and fibre for bread (with an increased content of fibre and whole grains, more products can contribute to increasing the population's intake) and including seeds (with the exception of sunflower seeds and linseeds). NNR 2023 recommend that seeds be included as part of a varied and fibre-rich diet, as they provide dietary fibre, protein, vitamins and beneficial fatty acids. Finally, the criteria for plant-based or partly plant-based products are adjusted so that they are brought into line with the criteria applicable to meat or certain meat products with the same intended use.
In addition, a change is proposed to the permitted fat content in foodstuff group 6, so that requirements apply only to the amount of saturated fatty acids. It is also proposed that seeds and nuts shall not be included in the calculation of the quantity of whole grains. Finally, it is proposed that the criterion relating to added sugar be removed from minced meat in food group 24b and that the requirement concerning saturated fatty acids in food group 3 be removed.
Otherwise, the Swedish Food Agency also proposes some minor linguistic changes.
9a. The action is taken with the aim of promoting public health by making it easier for consumers to choose healthier alternatives within different food groups. By choosing products bearing the Keyhole label, consumers can, amongst other things, increase their intake of fibre and whole grains, reduce their intake of salt and sugar, and consume fats with a more beneficial fatty acid profile.
The scientific basis for the Keyhole criteria is provided by the Nordic Nutrition Recommendations (NNR), which were updated in 2023. The Swedish national dietary guidelines have also been updated on the basis of NNR 2023. Therefore, in order for the Keyhole to continue to provide guidance in line with current scientific knowledge, the criteria in the regulations need to be adapted.
The criteria also provide food producers with guidance on developing healthier products by clarifying the nutritional criteria for what can be labelled and marketed with the Keyhole symbol within different food groups.
If the criteria are not updated, there is a risk that over time the labelling will be based on outdated scientific evidence and will no longer fully support consumers and food businesses in line with current nutritional recommendations. The proposed amendments thus ensure that the Keyhole can continue to contribute consistently and systematically to the promotion of healthier eating habits.
9b. The Keyhole is a long-established, voluntary labelling scheme. The labelling is not limited to Swedish products but may also be used for imported products, provided that the criteria are met. There are no indications that the labelling has had a negative impact on the internal market or cross-border trade. Nor have any comments been received during the consultation process to suggest that such an impact exists. The proposed amendments are therefore not expected to have any adverse impact on the internal market.
In order for the Keyhole to continue to guide consumers and contribute to the development of a healthier range of products, the criteria must be based on up-to-date scientific evidence. If the criteria are not updated, there is a risk that consumers will be guided by out-of-date criteria and that the relevance of the labelling – and confidence in it – will decline.
The Swedish Food Agency has considered retaining the current criteria. However, this would mean that the criteria would not be adapted to NNR 2023 and the updated national dietary guidelines. Information or guidance on the new nutritional recommendations alone is also not considered sufficient, as it is the criteria in the regulations that determine which products may be labelled and presented with the Keyhole.
The Swedish Food Agency therefore considers that an update of the criteria in the regulations is necessary in order for the labelling to continue to fulfil its intended purpose.
9c. The proposed amendments are not deemed to affect the internal market. The Keyhole is a voluntary label, and the criteria apply in the same way regardless of the Member State in which the products were manufactured.
For companies using the label, the amended criteria may mean that certain products need to be adapted to continue to meet the criteria or that the label can no longer be used for certain products. The transitional period has been extended following consultation with the food business operators concerned in order to allow sufficient time for adaptations. The need for adaptations that arises must be weighed against the public interest that the measure aims to meet, i.e. to promote public health by guiding consumers to healthier alternatives and contributing to the development of a healthier product range.
If the criteria are not updated, there is a risk that the Keyhole label will no longer reflect the current scientific evidence and will therefore become less useful as a guide for consumers and food businesses.
Against this background, and taking into account the fact that the labelling is voluntary and applied regardless of the origin of the products, the Swedish Food Agency considers that the possible restrictions resulting from the amendments are proportionate to the public health objective pursued.
10. References in the basic texts: Basic texts have been forwarded under a previous notification:
2020/0396/S
11. No
12.
13. No
14. No
15. Yes
16.
TBT aspects: No
SPS aspects: No
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European Commission
Contact point Directive (EU) 2015/1535
email: grow-dir2015-1535-central@ec.europa.eu
