The new proposal was published this week and is now set for debate at parliamentary and council level. Article 14 says that mandatory particulars should be printed on the package or label in characters of a font size of at least 3mm and "be presented in a way so as to ensure a significant contrast between the print and background".
This is a vital point for marketers and product designers, who would have to significantly alter the design of packs to accommodate the rules. This could result in compromised branding and aesthetics, consumer confusion, and maybe even bigger packages.
The CIAA has called the 3mm minimum "unworkable". While it agrees that legibility is a key issue and manufacturers want to present clear information to consumers, the regulation has to take into account real life constrains.
In an interview with FoodNavigator.com last week, Sabine Nafziger, director of consumer information, diet and health issues, said the proposal would change dramatically the physical representation of a product.
"The article puts legibility in question with brand recognition."
While the 3mm minimum relates to mandatory information, the branding, she said, is considered as voluntary. However branding plays a key part for consumers to recognise a product, so if the appearance has to change considerably they may well end up confused.
"We will strongly fight if [branding] is put into question," said Nafziger.
To avoid having to skip non-mandatory but nevertheless important information off the label, CIAA would prefer the font-size to be linked to the printable area.
Nafziger rejected the idea that legibility can be addressed solely by font size.
"You also have to consider issues like different shapes and sizes of packs, contrast and colours," she said. "If it is so simple, companies would do it already."
The smallest font size on a pack of McVities Chocolate biscuits purchased in the UK is 1mm; a can of Coca Cola purchased in France has some lower case lettering that measures under 1mm (measurements by Foodnavigator.com).
Xavier Durieu, secretary general of EuroCommerce, said that 3mm is larger than the size used by most newspapers. "Are they not legible?" he asked.
He also predicted that the requirement will cause pack sizes to increase, a consequence that goes against efforts to reduce packaging waste.
