EFSA – Consumer perceptions of emerging risks in the food chain

The following article, beside examining EFSA report, will offer many insightful hints about how to build an effective crisis management strategy. Understand and anticipate consumer’s reaction is indeed the key. It will highlight also the ambivalent relationships that most of the consumers have with science and technology, when they mix up with food.

Emerging risks are defined by EFSA as risks “resulting from a newly identified hazard to which a significant exposure may occur or from an unexpected new or increased significant exposure and/or susceptibility to a known hazard” (EFSA, 2007).

Emerging risks in the food chain are characterised by high levels of uncertainty and ambiguity: this potentially makes more difficult to communicate about emerging risks than about “established” and well understood risks.

The lack of appropriate risk’s communications can leave a vacuum that is filled by media speculation or rogue scientific analysis, therefore communication about emerging risks can help prevent the amplification or attenuation of risk perceptions. This pushed EFSA to investigate consumer knowledge and concerns about food emerging risks, as well as consumer needs and preferences with regard to emerging risk communication. The aim of the study was to better understand the views of EU consumers related emerging risks, so as to inform future communication activities around emerging risks at EFSA and Member State National Competent Authorities.

To address these object, EFSA delivered a consumer survey in 25 EU countries, asking just over 6,200 consumers about potential emerging risks related to food safety. The study investigated consumer attitudes of emerging risks through three examples:

  • green smoothies (shake or mixture of raw leafy greens and fruits intended to be consumed as a drink but whose consumption could lead to adverse health effects),
  • plastic rice (fake rice produced using a mix of potatoes, sweet potatoes and plastic, whose ingredients are harmful to consumers’ health)
  • nanoparticles (whose use in the food chain may have significant benefits for food but at the same time may have toxic effects on consumers).

These three examples illustrated emerging risk respectively resulting from: new food consumption trends, food fraud and new technologies.

The study delivered that there were differences between types of emerging risks, and between attitudes to emerging risks in EU Member States. Those differences correlated often – but not always – with, and were partly explained by reference to, variables that also contribute to attitudes to established risks: the perceived level of control over the risk, its natural/man-made character, familiarity with the risk, and public trust. They were also correlated to educational and generational factors.

However, the study did not indicate that emerging risks triggered significantly greater levels of concern than established risks. Rather the study found that consumers tended to be more concerned about established risks than emerging risks. Food fraud, which arguably may include both established and emerging risks, was of greater concern to consumers than other types of emerging risks. Overall, consumers considered green smoothies less risky than nanoparticles, and nanoparticles less risky than plastic rice.

Negative attitudes towards new food technologies may be linked with the perception that scientific advancements benefit the food industry, rather than consumers. This view is, however, contradicted by responses to other elements of the questionnaire that addressed the benefits of science and technology in food, where 78% of the sample agreed that scientific discoveries can help address some food issues.

The study delivered strong evidence of how malleable perceptions of emerging risks are, something which sets them apart from established risks. Indeed, communicating information to consumers about both the nature of emerging risks and the uncertainty surrounding them appeared to have a significant impact on risk perceptions, specially in a context where a very large proportion of the respondents appeared to lack knowledge of the risks discussed. Overall, the most common impact was an amplification of risk perception, although there were also instances of attenuated risk perception. In the case of green smoothies, information about risk and uncertainty led a large number of consumers to revise their risk perception levels upwards. Perceptions changed also for both plastic rice and nanoparticles, although to a lesser extent. These impacts suggest that communications about emerging risks may entail beneficial changes to consumer awareness, especially in situations where precaution may be advised.

If on one hand the study documented a lack of knowledge about the emerging risks used in the survey, on the other it also documented an overwhelming appetite for information about emerging risks, irrespective of the extent of the uncertainty. In general, consumers across the EU indicated that they would like to be informed of emerging risks earlier rather than later, in spite of uncertainties. Besides, consumers indicated that they were generally interested in obtaining not only general information but also information that could help them in making decisions about the risk, such as how to avoid it and how it affects them. Traditional media and the websites of national authorities were the preferred channels of information on emerging risks, while the sources of information that consumers had most confidence in were evaluators (health professionals and scientists) followed by watchdogs (consumer organizations and food safety authorities).

The question arises as to how EFSA and National Competent Authorities in Member States can and should respond to these findings. While the citizens and cultures of the EU are highly diverse, it is advised that organisations responsible for assessing emerging risks and managing both uncertainty and risk should provide a unified and consistent set of messages. This would avoid the risk that different messages may be translated and compared, leading to confusion and distrust. To reassure consumers in Member States and countries to which the EU exports food and beverage products, EFSA should communicate in a unified and consistent manner both what is known and what is uncertain about the possible existence of, and potential significance of, emerging risks. Moreover, given that emerging risks are intrinsically uncertain, EFSA and National Competent Authorities should be clear about the existence of uncertainties. In relation to this particular feature, the literature recommends that information about “those uncertainties that really matter to the magnitude of the risk and its management” is communicated to the public (Kasperson 2014: 1236).

While new information should translate into updated messages as time goes on, consumers could also contribute to risk assessment if risk communicators were to enrol them in the process; for instance, consumers can contribute information on their exposure to the risk that risk assessors can then evaluate and take into account.

In other words, risk communication could operate as an exchange between consumers and risk communicators/assessors, rather than as a one-way transmission of risk information from experts to consumers. This is even more so the case with emerging risks, where there is a lack of available evidence to “correct” consumers’ risk perceptions.

Food Labeling Contrast between China and EU Regulations (Part I)

Today I publish another useful article written by Quinn Hulk, Food and Drug Administration of Beijing – Food Law Advisor and our country contributor for China. You can contact Quinn Hulk directly via e-mail at hulkquinn@163.com.

1. Basic introduction

China National Standard GB7718-2011 General Rule for the Labeling of Pre-packed Foods (hereinafter referred to as GB7718-2011) was promulgated by the Ministry of Health (now National Health and Family Planning Commission of PRC) on 20-04-2011 and entered into force on 20-04-2012, repealing China National Standard GB7718-2004.

China National Standard GB28050-2011 General Rule for Nutrition Labeling of Pre-packed Foods (hereinafter referred to as GB28050-2011) was promulgated by the Ministry of Health (now National Health and Family Planning Commission of PRC) on 12-10-2011 and entered into force on 01-01-2013.

Regulation (EU) No 1169/2011 was first published on 25-10-2011 and entered into force on the 20th day following its publication in the Official Journal of the European Union. Considering the various situations among European nations and in order to allow transitional preparation, it sets out different dates for its application. Apart from 2 exceptions, point (l) of Article 9(1) and Part B of Annex VI, which shall apply from 13th Dec 2016 and became applicable from 1st January 2014, the regulation applied from 13th Dec 2014.

2. Scope

GB7718-2011 applies to the label of pre-packed food directly and indirectly provided to consumers. It does not apply to the package for the protection of pre-packed foods in transport and storage, unpacked foods as well as site-selling foods.

As for the unpacked foods, provisions available include Article 54 of Food Safety Law and Regulations on the Hygiene of Unpacked Food(a ministerial regulation still effective but not practicable, barely noticed anymore because it’s made in accordance with Food Hygiene Law, which has been repealed and abolished on 1st June of 2009, replaced by the old version of Food Safety Law

Reg. (EU) No 1169/2011 applies to food business operators at all stages of the food chain. It applies to all foods intended for the final consumer, including foods delivered by mass caterers and foods intended for supply to mass caterers. It also applies to catering services provided by transport undertakings when the departure takes place on the territories of the Member States to which the Treaties apply.

Compared with Chinese regulations, Reg. (EU) No 1169/2011 has a much wider scope. It covers basically all foods at all stages.


Reg. (EU) No 1169/2011

List of mandatory particulars

Article 9


Labeling information of pre-packed food supplied directly to consumers 4.1

Name of food Name of food
List of ingredients List of ingredients
Allergens Recommended, not mandatory
The net quantity of the food The net quantity of the food and specifications
The quantity of certain ingredients or categories of ingredients Quantitative indication of ingredients
The date of minimum durability or use by date Production date and quality guarantee period (shelf life)
Any special storage conditions or conditions of use Storage conditions
Name or business name and address of the food business operator Name, address, contact information of food manufacturers and food distributors
Country of origin or place of provenance
Instructions for use where it would be difficult to make appropriate use of food in the absence of such instructions
The actual alcoholic strength by volume for beverages containing more than 1.2% alcohol
Nutrition declaration Nutrition label
Product standard code
License No. of food manufacturing certificate


Ionizing radiation processed food or ingredients
Genetically modified foods
Quality grade if stipulated so in product standard


Reg. (EU) No 1169/2011

Presentation of mandatory particulars

Article 13


Basic requirements


In Reg. (EU) No 1169/2011, Article 13 requires that the x-height can be equal to or greater than 0,9 mm only when the largest surface of packaging or containers has an area of less than 80 cm2. Under normal circumstances, the x-height should be equal to or greater than 1,2 mm.


In GB7718-2011, the height of character should not be less than 1,8mm when the maximum surface area is larger than 35cm2. When the maximum surface area is larger than 10 cm2but less than 35 cm2, the height of character can be less than 1,8mm. The visibility and legibility should not be reduced nonetheless.
Reg. (EU) No 1169/2011 has a minimum size of character. GB7718-2011 doesn’t limit the minimum size.



Reg. (EU) No 1169/2011

Distance selling

Article 14


No such provisions


Reg. (EU) No 1169/2011

Omission of certain mandatory particulars

Article 16


Exemptions of particulars


List of ingredients and a nutrition declaration shall not be mandatory for beverages containing more than 1.2% by volume of alcohol, unless Union provisions require otherwise. Vinegar, salt, solid sugar, monosodium glutamate can be exempted from presenting the information of quality guarantee period together with alcoholic beverages which contain more than 10% by volume of alcohol.
Only the following information shall be mandatory for the packaging or containers the largest surface of which has an area of less than 10cm2.

(1)    the name of the food

(2)    any ingredient or processing aid listed in Annex or derived from a substance or product listed in Annex causing allergies or intolerances used in the manufacture or preparation of a food and still present in the finished product, even if in an altered form

(3)    the net quantity of the food

(4)    the date of minimum durability or the “use by “date

The list of ingredients, however, shall be provided through other means or shall be made available at the request of the consumers.

Only the name of the food, net quantity, name and address of the manufacture (or distributor) are required when the maximum surface area is less than 10cm2.
For glass bottles intended for reuse which are indelibly marked and bear no label, ring or collar, only the following information are mandatory

(1)the name of the food

(2)any ingredient or processing aid listed in Annex or derived from a substance or product listed in Annex causing allergies or intolerances used in the manufacture or preparation of a food and still present in the finished product, even if in an altered form

(3)the net quantity of the food

(4)the date of minimum durability or the “use by “date

(5) a nutrition declaration

No such provisions.
Nutrition declaration is not mandatory for the foods in Annex V, unless otherwise stipulated by Union provisions.  


Reg. (EU) No 1169/2011

Quantitative indication of ingredients

Article 22


Quantitative indication of ingredients


If the ingredient or category of ingredients is emphasized on the labeling in words, pictures or graphics, the quantitative indication of an ingredient or category of ingredients shall be required. If one or more valuable and characteristic ingredient or category of ingredients is emphasized in the labeling or instructions, the quantitative indication of an ingredient or category of ingredients shall be required.
No such provisions If it is emphasized that the content of one ingredient or category of ingredients is comparatively low or does not exist, the quantitative indication of the ingredient or category of ingredients shall be required.
If the ingredient or category of ingredients appears in the name of the food or is usually associated with that name by the consumer, the quantitative indication of an ingredient or category of ingredients shall be required. If the ingredient or category of ingredients is just mentioned in the name of the food and no emphasis is made in the labeling, the quantitative indication of an ingredient or category of ingredients is unnecessary.
If the ingredient or category of ingredients is essential to characterize a food and to distinguish it from products with which it might be confused because of its name or appearance, the quantitative indication of an ingredient or category of ingredients shall be required. No such provisions.


Reg. (EU) No 1169/2011

Date of minimum durability, ‘use by’ date and date of freezing

Article 24


Quality guarantee period

Annex C.4

Date of minimum durability Best before… It is highly suggested that you consume the food before…
Best before end… Consume the food best before…
Use by… Best before…
Frozen on… Best before the date….
Consume the food best before the date…
Quality guaranteed period until…
Quality guaranteed period…months(or days, weeks, years)


Reg. (EU) No 1169/2011

Storage conditions or conditions of use

Article 25


The indications of storage condition

Annex C.5

In cases of where foods require special storage conditions and/or conditions of use, those conditions shall be indicated. Store in normal temperature.

Store in refrigeration.

Store in freezing area.

Store in dark place.

Store in cool and dry place.

To enable appropriate storage or use of the food after opening the package, the storage conditions and/or time limit consumption shall be indicated, where appropriate. Store in xx-xx℃.
Please put the product in cool and dry place.
Store in normal temperature and keep refrigerated after opening.
Temperature:≤xx℃,Humidity: ≤xx%

10. Article 13 of Reg. (EU) No 1169/2011 stipulates that food information shall be marked in a conspicuous place in such a way as to be easily visible, clearly legible and, where appropriate, indelible. GB7718-2011 does not have such provisions, which leads to the fact that many MSEs adopt cost-saving way to label the information. In law enforcement practice, we have found that many people (especially so-called ‘professional defective-food buyers’) deliberately erase the poorly labeled food information such as production date in order to extort money from big supermarkets by filing a report to local jurisdictional FDAs. Some supermarkets are likely to erase it and reprint a new production date, which is also illegal.

Overall speaking, Reg. (EU) No 1169/2011 provides a much more detailed and comprehensive provision concerning food labeling information. GB7718-2011 is comparatively less consumer-oriented, which contributes to the fact that local FDAs at provincial and city level are plagued by ‘professional defective-food buyersand spend most of the administrative resources on trivialities and are forced to leave the real food safety problems unattended due to high work burden, lack of food science knowledge and most of all, a bureaucratic system.