Policy on Health and Nutrition - Lidl Malta
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Policy on Health and Nutrition
Summary
1. Foreword 4
2. Food safety is Lidl's primary objective 5
2.1 Acrylamide 6
2.2 3-Monochloro-propanediol (3-MCPD) 7
2.3 MOSH/MOAH - Migration of mineral oils to food 8
2.4 Pyrrolizidine (PA) and tropane (TA) alkaloids 9
2.5 Pesticides 10
3. Products for a mindful diet 11
3.1 Featured: unbalanced diet and being overweight 11
3.2 Sugar, salt and fat content
in Lidl’s own-brand products 12
3.3 Lidl's commitment to the issue:
20% less sugar and salt by 2025 12
4. Careful ingredient selection 15
4.1 Food colours 15
4.2 Preservatives 16
4.3 Flavours 18
4.4 Fats (hydrogenated fats, trans fatty acids,
saturated and unsaturated fatty acids) 19
4.5 Palm oil 20
4.6 Added vitamins and minerals 21
4.7 Sweeteners 22
4.8 Isoglucose (glucose and glucose syrup) 23
Version 1 – November 2019 2
Summary
5. Products for every dietary need 26
5.1 Free From Lactose and Free From Gluten 26
5.2 Vegetarian and Vegan Alternatives 27
5.3 Organic products 27
5.4 Genetically modified organisms 27
5.5 Lidl's approach to genetically modified food 28
6. Lidl product label 29
6.1 European labelling uniformity 29
6.2 Beyond legal obligations 29
6.3 Visibility to sustainable food production 31
7. Objectives overview 32
Version 1 – November 2019 3
1. Foreword As a leading company in the mass market retail sector in Italy and Europe, Lidl is aware of the responsibility that accompanies its size and role. This policy document describes how the high quality and safety of our products is guaranteed. This is achieved through a thorough selection of suppliers of own-brand products, which must be certified and are constantly checked at production sites. Manufacturers are required to ensure high levels of quality, carefully choosing production methods and ingredients and meeting the objectives that Lidl sets even in the absence of legal regulations. The document also lists the evaluation criteria and objectives that Lidl has adopted regarding a mindful diet. These refer to own-brand products in a fixed assortment and are constantly reviewed together with suppliers. In defining quality criteria, Lidl has focused on the latest health and technical discoveries, which it uses as a basis for the continual checks made on suppliers and own-branded products. With the strategy of reducing sugar, salt and fat in food, Lidl contributes to the health of consumers by promoting a more balanced diet. For this purpose, Lidl is gradually revising the recipes of its products together with its suppliers. The palatability and organoleptic characteristics of products are ensured while recipes undergo the process of optimization. In addition, through targeted cooperation with sports and health promotion organisations, Lidl also aims to spread a culture aimed at promoting physical activity and adequate nutrition. Version 1 – November 2019 4
2. Food safety is Lidl's primary objective The first step in ensuring healthy food for consumers is to ensure controlled and certified safety and quality. The Lidl quality guarantee starts with the careful selection of suppliers: all are certified in accordance with the criteria defined by the International Featured Standard (IFS) or the British Retail Consortium (BRC), which ensure the quality and safety of food products internationally. They are also checked periodically with surprise audits planned by Lidl that verify the production facilities conformance with the highest standards in terms of safety and regulatory compliance. Quality control is carried out not only by a dedicated internal department, but also by well-known independent institutions through a structured analysis plan. These institutions collect samples and carry out comprehensive quality, safety and legal tests. The more frequent the analyses, the more the product is considered to be at risk. The analyses are carried out both on products taken from suppliers during production, and on samples taken directly from the shelves, as well as during the commercial life of the product. With regard to the evaluation of the results of the analyses, the European Union has already set limits for many undesirable substances. These limits are calculated on the basis of several factors, such as effects on humans and frequency of consumption, considering safety factors that ensure that the consumer is not exposed to any risk when the limit is respected. Despite these EU limits, for its own-brand products, Lidl has decided to set even more stringent levels than those permitted by law. For example, the case of pesticide residues: for Lidl these residues cannot be more than a third of the maximum level allowed by law. Lidl imposes these requirements on its suppliers and constantly monitors their compliance. For some undesirable substances, for which health effects are not yet clearly demonstrated, there are still no legal limits. Lidl has decided, using the latest scientific research available, to set precautionary limits and to coordinate activities for the reduction of these substances with producers. Version 1 – November 2019 5
2.1 Acrylamide How does acrylamide form in food? The main influence on the level of acrylamide in food is the so-called Maillard reaction, also called the "browning reaction", which takes place mainly during cooking at high temperatures such as toasting, frying and roasting. This reaction, which develops by reaction from the sugars and proteins contained in food, attributes the sensory characteristics typical of these products, such as a "bread crust" aroma and a "toasted" colour. When the temperature exceeds 120 degrees Celsius, under certain conditions, the process can lead to the formation of acrylamide. Foods with the highest acrylamide content are potato products, such as bagged chips and fries, as well as cereal products and coffee. Why reduce acrylamide? Although the question of the effects that food with high acrylamide can have on human health has been analysed since 2002, no definitive position has been established to date. However, animal experiments have shown that acrylamide could have adverse genetic and carcinogenic effects. What is the current legal situation? There are no legal limits, however, as of 11 April 2018, the Regulation (EU) 2017/2158 has been applied which establishes attenuation measures and benchmark levels for reducing the presence of acrylamide in food. Lidl's commitment to the issue: Even without specific legal requirements, Lidl is committed to constantly reducing the content of acrylamide in its own-brand products. The objective is a threshold far below the EU benchmarks for acrylamide in the product groups particularly involved: Version 1 – November 2019 6
Product category EU benchmark Lidl Target
level [µg/kg] [µg/kg]
Crisp bread 350 200
Breakfast cereals made from bran and whole grains, puffed 300 200
cereals 300 puffed cereals
Breakfast cereals made from wheat and rye 300 100
Breakfast cereals made from maize, oats, spelt, barley and rice
150 100
Potato Chips 750 263
French fries (ready to eat) 500 71
2.2 3-Monochloro-propanediol (3-MCPD)
What is the 3-monochloro-propanediol and where is it found?
The chemical 3-monochloro-propanediol (3-MCPD) and its derivatives called "esters" are contaminants from
food processes present in certain processed plant foods and oils, mainly in palm oil. 3-MCPD and its esters
are formed when foods rich in fat and salt are exposed to high temperatures, as well as in the production of
soy sauce and oil refining. Palm oil too, as a refined food oil, also presents a risk of this unintentional
contamination, while for example olive oil, rapeseed and sunflower oil are less contaminated.
Why should 3-MCPD intake be reduced as much as possible?
It is assumed that free 3-MCPD may be genotoxic and carcinogenic. For this reason, intake should be reduced
as much as possible.
What is the current legal situation?
Soy sauce and soy sauce products have been identified as the main source of 3-MCPD intake through food.
The European Commission has set a legal limit for 3-MCPDs in soy sauces. For fats and oils, however, the legal
limit has not yet been set: it is only possible to carry out an assessment on the tolerable daily dose, also known
as TDI (Tolerable Daily Intake).
In January 2018, the European Food Safety Authority (EFSA) published a new assessment of 3-MCPD and of
3-MCPD fatty acid esters. The TDI has been set at 2 µg/kg body weight. For example, an adult with an average
body weight of 60 kg would have a daily consumption limit if 120 µg of 3-MCPD.
Version 1 – November 2019 7Lidl's commitment to the issue:
Lidl orients its target according to the TDI (Daily Intake) and aims to not exceed 50% of that dose. To reduce
this contaminant, Lidl replaces palm oil with other oils or fats, such as sunflower oil. In some products, where
the use of palm oil cannot be eliminated (for example, in some creams, to ensure its spreadability), suppliers
must select raw materials low in 3-MCPD, in order to comply with the limits imposed.
Target The content of 3-MCPD per portion must not exceed 50% of the Continuous monitoring
TDI. and improvement
Replace palm oil with other oils/fats if possible, from a
technological and organoleptic point of view.
2.3 MOSH/MOAH - Migration of mineral oils to food
What is the migration of mineral oils to food?
Food packaging may contain a certain percentage of recycled materials. These materials potentially contain
mineral oils, which can transfer, or "migrate", to the food they hold. For example, this can happen for food
stored in paper or recycled cartons, as most printing inks contain mineral oils that cannot be removed during
the production process and are consequently able to migrate to food.
The so-called "mineral oil hydrocarbons" (MOH) are predominantly made up of two main fractions: MOSH
(mineral oil saturated hydrocarbons) and aromatics, or MOAH (mineral oil aromatic hydrocarbons).
Why should the transfer of mineral oils to food be avoided?
The final toxicological assessment of mineral oil hydrocarbons has not yet been scientifically evaluated. The
issue is very complex and debated. So far, it is known that MOSH can be absorbed by the body. Experimental
animal studies have shown that they could be deposited to organs and cause possible damage. Some MOAH
may have carcinogenic effects, although this is still under discussion. However, according to today's scientific
knowledge and considering current eating habits, MOSH/MOAH have no acute health effects.
Version 1 – November 2019 8What is the current legal situation?
Due to the lack of data, it is not possible to make a safety-based assessment of the MOAH fraction. For this
reason, the European Food Safety Authority has generally defined that exposure to MOAH is undesirable and
that there are no legal guidelines for MOSH.
Lidl's commitment to the issue:
Even in the absence of legal provisions, Lidl has been working for years with the aim of avoiding the transfer
of MOSH/ MOAH into food. In the optimization process, Lidl is active together with its suppliers in identifying
possible hazardous sources and in preventing contamination of food with these substances, through
increased attention to raw materials and packaging.
Through the checks and investigations carried out in recent years, it has emerged that these contaminants
cannot be completely and immediately eliminated: the process must be gradual. Lidl has determined that its
own-brand products should not exceed the 2 mg/kg limit for MOSH. MOAH should not be detectable in the
product.
Objective Minimize mineral oils residue content in all food products Continuous monitoring
MOSH < 2 mg/kg and improvement
MOAH < LOD (limit of detection)
2.4 Pyrrolizidine (PA) and tropane (TA) alkaloids
What are PAs and TAs?
Pyrrolizidine (PA) and tropane (TA) alkaloids are natural substances that are produced by some plants to
protect against aggression by herbivores, their "predators".
Where are PA and TA present and how do they enter food?
Thousands of plant species around the world may contain pyrrolizidine alkaloids (PA). They are also found in
some commonly used plants, such as herbs, infusions and salads, and PA may also be found in raw honey. PA
and TA can then enter food especially when other wild plants accidentally end up in the agricultural crop.
Why should PA and TA be avoided in food?
Very high consumption of PA could damage the liver and have a carcinogenic effect. TA could compromise
the central nervous system and heart. In 2017, EFSA assessed a risk especially for consumers of large
quantities of herbal teas and plant-based supplements.
Version 1 – November 2019 9What is the current legal situation?
So far, there are no legal limits for PAs in food. However, due to their possible harmful effect on health, the
European Food Safety Authority (EFSA) has set an indicative value for daily consumption of < 0,007 µg PA per
kg of body weight. This value is not considered a potential carcinogenic risk.
For TAs, the EFSA has published an indicative value of 0.016 µg/kg in 2013, which was further reduced for
cereal-based foods: the two most important TAs (atropine and scopolamine) should not exceed the amount
of 1.0 µg per kg.
Lidl's commitment to the issue:
Lidl has committed along with its suppliers to minimize PA and TA in plants that finish in harvests and seeds.
On an international basis, it was agreed with the main honey suppliers that the PA level should be tested in
each batch of raw honey.
Objective Minimize content of Pyrrolizidine (PA) and tropane (TA) Continuous monitoring
alkaloids. and improvement
PA: do not exceed 50% of the TDI
TA: no contamination
2.5 Pesticides
What are pesticides and what are they used for?
Pesticides are chemical or biological products used to protect plants from pests, diseases and weeds. They
play a very important role in the protection of crops.
What is the legislation on pesticides and their residues in food?
A pesticide can only be used in the EU if it has been verified and authorised under a strict procedure. Before
commercial release, the product is extensively tested for its effectiveness, harmlessness for humans and
animals and for its suitability for nature and the environment.
Even if used correctly, pesticide residues can remain on plant products. Therefore, MRLs (Maximum Residue
Levels) are also set for food. These are calculated in order to be as low as possible and to ensure food safety.
MRLs are defined at European level by Regulation (CE) no. 396/2005, and subsequent amendments. Having
different functions (pesticides, herbicides, etc.), the regulation does not set a limit on the different active
substances that may be in the food at the same time.
Version 1 – November 2019 10Lidl's commitment to the issue:
Lidl's goal is to offer food, both fresh fruits and vegetables as well as processed foods, as free from pesticide
residues as possible. For this reason, strict standards are set that are much more restrictive than those
imposed by European regulations:
• Lidl allows residues of active substances up to a third of the legal maximum.
• Overall, the percentage of all residues can amount to a maximum of 80% of the legal limit.
• In total, the number of active substance residue must not exceed five.
Objective Reduce pesticide residues as much as Continuous monitoring
possible. In particular: and improvement
Maximum quantity per single residue:3.2 Sugar, salt and fat content in own-brand products Sugar, salt and fat, in addition to helping to give flavour and body to products, are also fundamental to our metabolism but must be eaten in a conscious and responsible way. Saturated fatty acids A diet high in saturated fat is potentially associated with some cardiovascular diseases. The recommendation of the World Health Organization (WHO)1 is to consume less than 10% of energy through saturated fatty acids. In the case of the recommended calorie intake for an adult, i.e. 2,000 kcal, this level corresponds to 20g of saturated fatty acids per day. Sugar The term "simple sugars" refers to monosaccharides (such as glucose and fructose) and saccharides (such as sucrose and domestic sugar), which are added to foods. The WHO recommends consuming no more than 10% of calories in simple sugar, which, in a diet of 2,000 kcal, corresponds to 50 g of sugar per day2. Salt Excessive salt consumption leads to an increase in blood pressure, resulting in an increased risk of the onset of serious cardio-cerebrovascular diseases. The WHO recommends maximum consumption of 5 grams of salt per day, corresponding to about 2 grams of sodium per day. 3.3 Lidl's commitment to the issue: 20% less sugar and salt by 2025 Based on scientific evidence, Lidl is implementing strict targets for reducing the content of salt, sugar, and saturated fatty acids. The development of recipes for new products takes into account these objectives from the start. In addition, Lidl periodically reviews existing recipes in order to improve them. Of course, it avoids compensating for the reduction of sugar by increasing fat or vice versa. 1 https://www.who.int/news-room/fact-sheets/detail/healthy-diet 2 http://www.who.int/mediacentre/factsheets/fs394/en/ Healthy diet Fact sheet N°394 Updated September 2015 (version: 12/09/2016) Version 1 – November 2019 12
Lidl aims to actively contribute to a mindful diet. For this purpose, the Company constantly checks its range
of own-brand products and analyses them according to the most modern scientific methods.
Objective Reduce the sugar/salt content added to its own-brand products January 2025
by 20% in an ongoing, sales-weighted assortment. The reduction
of sugar focuses on foods that are mainly consumed by children.
The reduction of salt focuses on food categories that are
consumed regularly and generally make up a large part of salt
consumption in the diet.
How will Lidl meet its commitment?
To achieve this objective, Lidl has defined several actions:
• Reducing added sugar and salt content in food
Reducing added sugar/salt in food is the most immediate method of achieving the goal. Sugar is not
replaced with sweeteners or other substitutes, but simply gradually reduced so that people can get
used to consuming foods that are less sweet. Alternatives are offered at the same time without added
sugars.
For example, the desire is to reduce the added sugar content in fruit yoghurts while keeping the
percentage of fruit.
• Portion reduction
Lidl reduces the package size of single-portion food packs with a high calorie intake, so that less sugar
and fewer calories are automatically consumed.
• Lidl’s own-brand products
Lidl offers its customers a wide selection of alternative products containing less sugar and salt.
Version 1 – November 2019 13How to measure progress? Lidl measures its progress based on the average reduction of sugar/salt per 100 g of food or 100 ml of beverage, weighted per unit sold per year in Malta. This means that, within a given food category, the total amount of added sugar and salt will be detected for products sold in a given year by Lidl, and divided by the total volume/weight of products sold. By comparing this relationship with the corresponding one from the previous year, the progress made can be seen. This assessment is made on the principal items in the assortment and on different suppliers, in order to be able to determine the total amount of added sugar sold by Lidl Malta in a year. In order to reduce the amount of added sugar sold the following year, Lidl must intervene both on the type of products sold (promoting the sale of variants without added sugar or products that do not contain sugar) and on the recipes of the individual products, requesting that suppliers involved decrease the added sugar. The same approach is applied to the salt content in its products. Lidl's main focus on reducing sugar is on foods that children are willingly consume, such as biscuits, fruit drinks, candy, yogurt, ice cream. The reduction in salt concentrates on food groups that are consumed regularly by the entire population, such as bread, ready meals, pizzas, sauces, savoury snacks, meat products. Legal limits for modifying recipes Product optimization options vary depending on the type of reference, ingredients, and processing methods, so Lidl adapts its goals to suit the individual product. Sometimes the options are limited because for a particular product there are specific legal provisions. For example, foods with a Protected Designation of Origin (PDO) must comply with the strict PDO specifications, which means that, for example, any fat content cannot always be reduced. Likewise, jams must contain a minimum quantity of sugar. Version 1 – November 2019 14
4. Careful ingredient selection The quality of a product starts with the selection of ingredients. Customers expect products that are satisfying in both quality and flavour. The following points describe the aspects that Lidl pays great attention to. 4.1 Food colours What are food colours and why are they used? The use of food colours makes products more attractive and palatable, since colour directly connects our mind to a specific taste. For example, red makes us perceive products as fruitier, while green more acidic. In addition, colours help us identify products, such as in a multi-flavour candy package: we know immediately that the pink ones will have the strawberry flavour and the yellow ones, lemon, without having to taste them all to find out. Why are some food colours controversial? According to scientific studies, some azo food colourings such as quinoline yellow, could cause hyperactivity and attention deficits in children. The EU Food Additives Regulation lists these food colourings and stipulates that, if present, they must be accompanied by the warning "May have an adverse effect on activity and attention in children". What is the current legal situation? In the European Union, food colourings are governed by the Food Additives Regulation. These substances require legal approval, preceded by a safety review by the European Food Safety Authority. Food colourings must be marked on food packaging in which they are contained and with the suffix "Colour", followed by their name or "E" identification number. In order to ensure maximum transparency, Lidl always indicates the name of the substance on the label (not the code) for all additives, except when there are space limits. In order to ensure maximum transparency, Lidl always indicates the name of the substance on the label (not the code) for all additives, except when there are space limits. Version 1 – November 2019 15
Lidl's commitment to the issue:
For many years, Lidl has had the objecting of avoiding the use of azo food colouring in food. These can only
be present in spirits, as they are not intended for children. In addition, Lidl is also distancing itself from
quinoline yellow, carmine, erythrosine and green S food colourings.
If "colouring" a product is necessary, foods are preferable that are coloured, for example, with beet root or
carrot extract instead of an artificial red colour.
Objective Monitor all products containing food colourings to determine December 2020
whether the use of such additives is necessary, and prefer the
use of natural food colourings in case their use is strictly
necessary.
Replace azo food colourings with natural food colouring.
Avoid quinoline yellow, carmine, erythrosine and green S
completely.
4.2 Preservatives
What are preservatives and why are they used?
Preservatives are food additives that protect food. They prevent dangerous pathogenic microorganisms from
developing on the product and allow for greater shelf life.
Why are some preservatives controversial?
The effect of some preservatives is controversial due to a controversial correlation between preservatives
containing sulphites (used in wine and dried fruit for example) or the derivatives of benzoic acid (used for
example in pickled vegetables or fish products) and allergic reactions in particularly sensitive individuals.
Similarly, the effect of nitrites in meat products is being discussed, as there is a suspicion that it may
encourage the development of a group of compounds called "nitrosamines", some of which may be
carcinogenic. On the other hand, nitrites reliably prevent the formation of lethal bacteria and are therefore
the safest and most effective means of storing meat products, such as cured meats.
Version 1 – November 2019 16What is the current legal situation?
As with all additives, the safety of individual preservatives is also assessed by the European Food Safety
Authority (EFSA). In general, authorisation is granted only if it is proven that the substance is "technologically
necessary" (in this case for shelf life) and safe for health. Preservatives must be labelled with the term
"preservatives" followed by the name or the corresponding letter "E".
In order to ensure maximum transparency, Lidl always indicates the name of the substance on the label (not
the code) for all additives, except when there are space limits.
Lidl's commitment to the issue:
Lidl aims to minimise preservatives, or eliminate them completely, but without compromising food safety.
For example, in the case of sausages and meat, it is not possible to eliminate preservatives to avoid the
formation of microorganisms, possibly lethal, such as Botulinum.
Lidl has established with its suppliers that, during the production process, food is made safe and long-lasting
using appropriate technologies, if possible, without preservatives. For example, it is already possible to do
without preservatives completely in beverages through so-called "aseptic" filling (bottling in sterile
conditions).
Other preservatives are classified as "not recommended for children". Again, Lidl wants to give top priority to
their elimination, if technologically possible. Nitrite salts already described are among the preservatives that
are not recommended and which the use can be maintained, for safety reasons, only in meat products.
Objective Reduce the use of preservatives as much as possible or eliminate December 2020
them completely if this does not compromise food safety.
Continuous research with appropriate technologies aimed at
making products long-lasting and safe even without the use of
preservatives.
17
Version 1 – November 20194.3 Flavours
What are flavours and why are they used?
Flavours are substances that are added to foods to give them a particular or more intense smell and flavour.
They are often used to recover flavours that have degraded during processing or to prevent loss in case of
long durability.
Lidl's commitment to the issue:
For Lidl a moderate use of flavours is important, so that the natural taste of food is not lost. Lidl therefore
intends to use flavours only where they are strictly necessary, avoiding them where they are not needed.
If flavours are added to food, natural extracts or flavours obtained from the foods for which the flavour is
named must be used. For example, in the case of a natural cherry flavour, at least 95% must come from
cherries.
Again, the recipes are optimized without sacrificing taste. Only in case the desired aromatic profile cannot be
obtained without flavours or through the use of natural extracts or flavours, are artificial flavours also used.
Objective Avoid artificial flavours as much as possible, replacing them with December 2020
natural flavours or extracts.
Subject products with flavours to checks to determine if the use
of flavours is actually necessary.
Version 1 – November 2019 184.4 Fats (hydrogenated fats, trans fatty acids, saturated and unsaturated fatty acids) What are saturated and unsaturated fatty acids and what are they used for? Fats and oils contain saturated and unsaturated fatty acids. These differ in their nutritional property: too high a content of saturated fatty acids in the diet increases the risk of cardiovascular disease. For this reason, a healthy diet should contain an adequate amount of unsaturated fatty acids. An important subset of unsaturated fatty acids are omega 3 and omega 6 fatty acids. These perform important functions for the body, have an anti-inflammatory effect and are considered capable of preventing diseases in the cardiovascular system. Lidl's commitment to the issue: Lidl aims to give preference to unsaturated fatty acids over saturated acids. For example, in some chocolate creams, some of the palm oil has been replaced with other oils that contain a high percentage of unsaturated fatty acids. How do trans fatty acids form and what effects do they have? In the group of unsaturated fatty acids there are also unwanted substances: trans fatty acids. Most trans fatty acids can be formed by the hydrogenation of vegetable oils, which is performed to change liquid oil into solid fat, for example in margarine production. Partially hydrogenated fats are used in food production for their good technological properties (creamy consistency, high plasticity). Trans fatty acids can have negative health effects and are therefore among the elements Lidl considers undesirable in food products. What foods are trans fatty acids found in? Trans fatty acids can be found mainly in products such as snacks, biscuits, wafers, fried foods and spreads. Fried foods contain a greater amount of trans fatty acids only when cooked in partially hydrogenated fats and oils. Version 1 – November 2019 19
What is the current legal situation?
In Malta there is no legal regulation for the general content of artificial trans fatty acids in food. In other
European countries such as Denmark, Austria, Hungary, Iceland, Norway, Latvia and Switzerland, a legal limit
has already been established. For example, in Denmark the content of artificial trans fatty acids in food may
not exceed 2g/100g of fat.
Lidl's commitment to the issue:
Lidl's objective is to ensure a maximum content of trans fatty acids in products of 2 g per 100 g of fat. To this
end, the company refrains from using hydrogenated fats where possible. In some cases, as in the production
of margarine, there is no alternative, since sunflower oil can only solidify through the hydrogenation process.
Objective Trans fatty acid content should not exceed 2 g/100 g of fat. Continuous monitoring
Improve the composition of fatty acids by using alternatives to and improvement
saturated fats.
Conversion from palm oil/fat to sunflower oil or other
unsaturated fats. No use of hydrogenated fats if technologically
possible.
4.5 Palm oil
Where does palm oil come from and what benefits does it offer?
Palm oil is extracted from the fruit of the tropical oil palm. Since the oil palm produces fruits all year round,
it is particularly productive and very efficient compared to other oily plants. For its physical properties, palm
oil is very versatile in use. Unlike other naturally more fluid vegetable oils, palm oil is solid and therefore does
not have to be solidified before being used.
Intensive cultivation of oil palms presents important social and environmental challenges. Due to the need to
occupy land for plantations, large expanses of tropical forests have been eliminated, endangering the natural
habitat of many animal species and biodiversity. To counter this trend, the Roundtable on Sustainable Palm
Oil (RSPO)3 was created, whose members, including Lidl, have committed to the eco-sustainable cultivation
of palm oil. For example, no primary forests and ecologically valuable forest areas are eliminated in favour of
plantations (more information about this certification is available at https://www.rspo.org/).
3 https://www.rspo.org/
Version 1 – November 2019 20What effect does it have on health?
Palm oil has a high content of saturated fatty acids. If you consume a diet with many saturated fatty acids this
could lead to an increase in triglycerides in the blood. In addition, the high heating that palm oil is subjected
to during processing promotes the risk of the formation of some esters of fatty acids (3-MCPD) considered
carcinogenic. For more information on 3-MCDd, see the dedicated paragraph.
Lidl's commitment to the issue:
The goal of Lidl is to use, where present in the recipes, exclusively palm oil produced in a sustainable way,
certified according to the RSPO Segregated international scheme. By the end of 2020 it will be applied to all
products in the continuous own-brand range.
Objective Where palm oil is present, use only sustainably produced oil with December 2020
RSPO Segregated4 certification.
4.6 Vitamin and mineral fortification
What function do vitamins have for humans?
Vitamins are organic compounds that the human body takes in with food. They are mainly found in plant-
based foods such as fruits, vegetables and cereals. Animals take them in with feed and therefore they are
also found in meat, fish, eggs, milk and in their respective derivatives. Vitamins have a variety of functions for
the human organism: for example, vitamin C is involved in the functioning of our immune system, while
vitamin A plays an important role for eyesight.
What function do minerals have for humans?
Minerals are inorganic nutrients found in plant-based and animal-based foods. They serve a variety of
functions for the metabolic and growth processes of the human body: for example, calcium helps with the
construction of bones and teeth, while iron is important for blood formation and oxygen transport.
4 For non-edible products, such as personal/home care, the goal is that all will be RSPO MB certified by the end of 2020.
Version 1 – November 2019 21What are the effects of foods enriched with vitamins and minerals? Foods enriched with vitamins and minerals should compensate for nutritional deficits. Excessive intake, however, can have negative health effects. In Italy, the intake of vitamins and minerals is considered sufficient. With few exceptions, needed vitamins and minerals are absorbed in sufficient quantities through a balanced diet. In general, there is no additional requirement for vitamins or minerals, except in particular cases of need. Lidl's commitment to the issue: Lidl abstains from a generalized and wide-ranging vitaminization or mineralization in food. Vitamins and minerals are eventually added only in selected products, such as multivitamin drinks (vitamins), sports drinks, meat substitutes (vitamin B12), vegetable alternatives to milk (calcium), margarine and iodized kitchen salt. 4.7 Sweeteners What are sweeteners and what are they used for? Sweeteners are simple sugar substitutes made synthetically (e.g. aspartame) or naturally (e.g. stevia). They are practically calorie-free and much sweeter than sugar, so they should only be used in small doses. The use of sweeteners is a viable alternative to reduce the calorie content without sacrificing sweet taste. They are used especially in soft drinks and chewing gum. Why are sweeteners controversial? Sweeteners have been controversial for a long time. The question of whether sweeteners help to lose weight or increase hunger, leading to sudden weight gain is still the subject of much scientific research. There is also little evidence about the long-term effects of sweeteners, but their consumption has sometimes been linked to a higher risk of cancer, behavioural changes and premature births. The use of sweeteners for children is particularly controversial. When children consume sweeteners, they can get used to the intense sweetness of industrially produced products and thus lose the perception of what less-sweet natural food tastes like. Because of their lower body weight, the acceptable daily intake (ADI) can be quickly exceeded. However, it has been calculated that in general there is no health risk if foods and drinks containing sweeteners are consumed in moderation in a balanced diet. Version 1 – November 2019 22
What is the legal situation with regard to sweeteners?
As with all food additives, sweeteners are regulated substances subject to safety assessment prior to market
authorisation. The acceptable daily intake (ADI) is determined for each individual sweetener in evaluating its
impact on health. In order to ensure constant safety, sweeteners are subject to re-evaluation even after
authorisation, if necessary, and the ADI is adapted by the European legislature according to new research.
Lidl's commitment to the issue:
The reduction of sugar (see Chapter 3) does not mean that Lidl replaces it with sweeteners, to prevent
customers from getting used to a more intense and artificial level of sweetness. Lidl intends for its customers
to gradually become accustomed to the less sweet taste of their own-brand products.
However, Lidl also caters to those customers who want to consume low-calorie foods, without sacrificing
familiar sweetness. Freeway Cola, for example, is offered in both a sugary version and a sugar-free version,
sweetened with sweeteners (Cola Light and Cola 0% sugar). This way, Lidl customers can decide for
themselves whether or not to drink the version with sweeteners.
Again, the optimization of recipes is always subject to the principle that the development of the new product
should not be at the expense of taste or safety.
4.8 Isoglucose (glucose and glucose syrup)
What is isoglucose and what is it used for?
Isoglucose, glucose-fructose syrup, fructose-glucose syrup and high fructose corn syrup are all types of sugar
syrup made with different amounts of glucose (the "simplest" sugar) and fructose (“fruit sugar").
Table 2 - Definition of Isoglucose
Name Fructose Content Source
Isoglucose 10% or more Wheat, corn, potatoes
Glucose-fructose 5%- 50% Wheat, corn, potatoes
Fructose-glucose > 50% Wheat, corn, potatoes
High fructose corn syrup (mainly used in Min. 42% often 55% Wheat, corn, potatoes
USA)
Version 1 – November 2019 23Glucose-fructose syrup is produced from starchy plants such as corn or wheat, by breaking up starch into its individual components, sugars. Fructose is sweeter than both glucose and table sugar (sucrose). It is sweeter if it contains a sugar syrup. By increasing the amount of fructose in sugar syrup, you can achieve a sweetening power higher than that of common sugar. In addition to the higher sweetening power, glucose-fructose syrup is used in foods primarily for technological reasons, such as greater solubility or better consistency. If a food contains glucose-fructose syrup or other sugar syrups, it will be listed in the ingredients list. According to the regulation on sugars for human consumption, the label will not be labelled "Isoglucose", but "glucose- fructose syrup" or "fructose-glucose syrup", depending on the amount of fructose used. Nutritional information is listed in the "sugars" category. This is required by law and listed by Lidl on its own labels. Why is glucose-fructose syrup controversial? The European Commission had imposed a limit on the portion of the sugar market occupied by glucose- fructose syrup. This restriction was removed 1 October 2017. The European Commission therefore expects the production of glucose-fructose syrup to increase significantly by 20265. However, the addition of isoglucose mixtures containing a high percentage of fructose to processed foods can lead to an increase in fructose consumption, which can have negative effects on metabolism. 5 https://ec.europa.eu/agriculture/sites/agriculture/files/markets-and-prices/medium-term-outlook/2016/2016-fullrep_en.pdf (August 8, 2018) Version 1 – November 2019 24
Fructose intolerance: It is estimated that each person consumes about 40 grams of fructose6 daily. However,
one in three people may experience stomach and bowel problems due to intolerance from an intake of 25g.
Healthy individuals, and especially children, may have problems if they consume more than 35g of fructose
per meal. If consumed in higher amounts, the body has difficulty absorbing it completely and it can cause
symptoms such as bloating, flatulence or diarrhea7.
Potential side effects on health: According to various studies, excessive fructose intake could lead to an
increased risk of being severely overweight (obesity), diabetes, metabolic disorders and cardiovascular
disease8.
Unlike glucose, fructose is metabolized in the liver. Excessive fructose intake can cause what is known as "non-
alcoholic fatty liver", comparable to a fatty liver from excessive alcohol consumption. It is estimated that 30%
of the population in Europe suffer from non-alcoholic liver steatosis. The health effects can be diabetes and
hypertension9. Consuming whole fruit (apples, pears, etc.), as part of a balanced diet, does not cause the
problems described above. It is impossible to ingest enough fructose in this way to cause damage. For
example, it is difficult to imagine eating 13 oranges, but you can easily imagine drinking a litre of orange juice
produced with 13 oranges.
Production: in addition to the health aspects, another criticism of glucose-fructose syrup is that sugar syrup
can be produced from genetically modified corn. However, there is also a labelling requirement for
ingredients derived from starched produced directly from genetically modified plants (e.g. corn) and the same
applies to glucose-fructose syrup10.
Lidl's commitment to the issue:
Lidl prefers to avoid the use of genetically modified foods and has already committed to reducing the use of
glucose-fructose syrup in its products. With regard to the use of fructose-glucose syrup, in parallel, Lidl took
the first steps to eliminate it at the beginning of 2017.
Lidl's long-term goal is to use glucose-fructose syrup only where technologically necessary.
6 Volynets V, Kuper MA, Strahl S et al. (2012) Nutrition, intestinal permeability, and blood ethanol levels are altered in patients with
nonalcoholic fatty liver disease (NAFLD). Dig Dis Sci; 57: 1932-1941 (August 8, 2018)
7 https://www.verbraucherzentrale.de/Fruchtzucker (August 8, 2018)
8 Bray, George A. et al. (2004) Consumption of high-fructose corn syrup in beverages may play a role in the epidemic of obesity. The
American Journal of Clinical Nutrition, Volume 79(4):537-543 (August 8, 2018)
9 Weiss J, Rau M, Geier A (2014) Non-alcoholic fatty liver disease: epidemiology, clinical course, investigation, and treatment. Deutsches
Ärzteblatt Int 111: 447–452.
10 https://www.transgen.de/datenbank/zutaten/2531.isoglucose.html (August 8, 2018)
Version 1 – November 2019 25If a product contains glucose-fructose syrup, the fructose content should be less than 42%. In this way Lidl
ensures that no high fructose corn syrup is used.
Objective Use glucose-fructose syrup only where strictly and technically January 2025
necessary.
If a product contains glucose-fructose syrup, the fructose
content should be less than 42%, avoiding the use of high
fructose corn syrup (HFCS).
5. Products for every dietary need
A healthy diet is vital to our best quality of life. Today, Lidl's customers are increasingly mindful of their own
food choices. Both personal preferences and the increasing incidence of intolerances and allergies play a key
role. Lidl wants to be able to offer the right products for every need and offers a wide range of products to
suit all tastes and needs, from lactose-free or gluten-free foods to organic products.
5.1 Free from Lactose and Free from Gluten
Milk as a food offers many advantages: it contains nutrients such as proteins, calcium and vitamins, essential
components of a balanced diet, but not everyone tolerates it. In fact, more and more people suffer from
lactose intolerance, a disorder that leads to stomach pain and other symptoms as a result of consuming dairy
products.
People who are lactose intolerant should not necessarily avoid drinking milk. Lidl
customers can choose from a selection of lactose-free products, such as milk or yogurt,
that they can enjoy without giving up taste.
Gluten is another natural component present in some types of products that many people cannot tolerate,
suffering from gluten intolerance or celiac disease. Gluten is a protein complex contained in cereals such as
wheat, spelt, rye, oats, barley and many others. People who suffer from celiac disease do not tolerate these
types of cereals or any food that contains even traces of it.
In order to communicate transparently with its customers, Lidl labels its own-brand
gluten free products in a specific way.
Version 1 – November 2019 265.2 Vegetarian and Vegan Alternatives
Lidl also offers vegetarian and vegan foods in its own-brand product range. Consumers can recognize them
by the yellow V-label, which certifies the product. The logo ensures that all ingredients and food additives
meet the relevant criteria to be identified as "vegetarian" or "vegan".
With its own line "My Best Veggie", Lidl offers its customers numerous products for a
vegetarian and vegan diet, such as fresh, frozen and to-go dishes.
5.3 Organic products
Lidl has been offering organic food products featuring the official EU organic logo for
many years. In order to use the EU's organic logo on the label, a product must meet
the strict criteria set by European regulations.
Lidl has also established an internal quality assurance system by monitoring it throughout the production and
supply chain. This allows the company to consistently ensure high quality and compliance with all legal
requirements.
Lidl's long-term goal is to continuously expand the supply of organic products based on market demand. In
this way Lidl aims to meet the needs of its customers for better nutrition, a healthy diet and a sustainable
lifestyle.
5.4 Genetically modified organisms
Genetically modified foods must be indicated as such on the label. The law includes foods containing
genetically modified organisms (GMOs), GMO-based foods and foods containing ingredients prepared with
GMOs. Lidl does not sell genetically modified foods.
What actions does Lidl take with its suppliers?
To exclude any GMOs, Lidl requires its suppliers to have a documented risk assessment. Lidl believes that it
is important to take measures even at the beginning of the supply chain to exclude, or avoid, GMO
contamination during cultivation, transport and processing.
Version 1 – November 2019 27Most of the world's soybean production is still genetically modified, although more GMO-free soybeans are
being grown due to increased demand.
Soy is a key component of animal feed for the production of many animal-based products. Where soy cannot
be replaced with other protein-based feed, Lidl prefers to use soy produced in the European Union over soy
be used by non-EU countries. Internationally, Lidl has been working on the Lidl soy initiative since 2017, with
the aim of gradually increasing the global percentage of certified, sustainable and GMO-free soybeans and
improving the environmental, living and working conditions of local farmers who cultivate it.
5.5 Lidl's approach to genetically modified food
In 2015, Lidl introduced the first "NO GMO feed" certified products for Milbona-brand milk. Since then, this
initiative has been extended to other dairy products such as cheeses.
No genetically modified feed was used for these products in accordance with current legislation.
What does the "NO GMO feed" seal mean?
This symbol was established in 2009 by the German Ministry of Agriculture and
Food. Foods that have such a symbol meet high standards and do not contain
genetically modified or components derived from them.
Objective Increase products in the own-brand continuous assortment with Continuous monitoring
the "NO GMO feed" seal. and improvement
Version 1 – November 2019 286. Lidl product label The own-brand label was developed to give customers a quick and clear overview of all the important information about a food and its ingredients. All the information on the packaging reflects the characteristics of the product contained in it. 6.1 European labelling uniformity The Regulation (EU) 1169/2011 on the communication of food information to consumers defines the requirements for food labelling and information, applicable requirements across the EU. These include: • the name of the food; • the list of ingredients and in particular allergens (highlighted, usually in bold); • the date of the minimum durability or the expiration date; • the net amount of food; • the name or company name and address of the food industry operator responsible for labelling; • nutritional statement. 6.2 Beyond legal obligations Lidl comes forward to be as transparent as possible in the labelling of its own-brand products, and, in addition to the requirements of EU Regulation 1169/2011, also provides the following information: Clear nutritional information: Lidl presents all nutritional information and ingredients in a uniform typeface so that customers can make a quick assessment with a special table, except where there are space limitations. The table shows at a glance what nutrients are contained in a given product and the caloric intake of the food. If a portion is indicated, the calories per portion is also declared and the percentage of reference intake calculated according to the recommended daily requirement for an adult under Regulation (EU) 1169/2011. Statements on lactose and gluten-free products and allergens are also clearly stated on the Lidl product labels. Version 1 – November 2019 29
Nutritional values Ø/100 g Ø/150g portion % RI*
Calories 685 kJ/164 kcal 1029 kJ/247 kcal 12%
Fat 10.0 g 15.0 g 21%
including saturated fatty acids 7.0 g 10.5 g 53%
Carbohydrates 15.9 g 23.9 g 9%
including sugars 14.8 g 22.2 g 25%
Protein 2.4 g 3.6 g 7%
Salt 0.08 g 0.12 g 2%
*Reference Intake (RI) Reference Assumptions for an Average Adult (8400 kJ/2000 kcal)
The shelf life is indicated in the same field of view as the product name, net weight and alcohol content.
Information about fish origin is highlighted in a yellow text field. Lidl also adopts the same methods in the
case of preserved fish and processed foods containing a large percentage of fish.
Portion size: In addition to mandatory nutritional information, food operators can voluntarily provide
nutritional information about the single portion size. Calorie content and nutritional information can be
indicated as a percentage of the so-called reference intake. The reference daily intake is based on a diet of
2000 calories, which represents the reference daily intake of an adult person. Currently there are no
requirements on the portion size indication; these can be set by the operator desired. Lidl indicated portion
size, expressing them in the most meaningful and realistic way possible. For example, on own-brand frozen
pizza there is the nutritional declaration of whole pizza and the same applies to chocolate bars. In this case,
Lidl products do not show percentage values based on a single portion on the front side of the package. The
reason for this choice is to be found in the difficulty of determining the "correct portion size" for all, whether
children, women or men. Since the reference daily intake is based on an average adult, Lidl chose not to
indicate a percentage of the daily requirement for foods that are also aimed at children.
Version 1 – November 2019 306.3 Give visibility to sustainable food production Lidl prides itself on working closely with non-profit organizations and fostering sustainability standards to offer its customers food produced according to social and environmental responsibility criteria. Many of the items that Lidl sells are certified for sustainability such as Bio, Fairtrade, MSC, ASC, Friend of the Sea, UTZ, Rainforest Alliance, etc. Regarding fair trade, Lidl was one of the first companies in the sector to introduce Fairtrade-branded certified products. Since then Lidl has expanded fair trade cooperation and was one of the first partners in the international programme on the use of sustainable cacao. For more information on the sustainability of cacao, you can visit the Lidl website at: https://corporate.lidl.com.mt/sustainability/subitems/purchasing- policies/subitems/cocoa Version 1 – November 2019 31
7. Objectives overview
Objective
Acrylamide Respect Lidl's target levels for all relative product Continuous
groups. monitoring and
See details in the table in paragraph 2.1. improvement
3-Monochloro- The content of 3-MCPD per portion must not Continuous
propanediol (3-MCPD) exceed 50% of the TDI. monitoring and
Replace palm oil with other oils/fats when improvement
possible from a technological and organoleptic
point of view.
MOSH/ Minimize mineral oils residue content in all food Continuous
MOAH products: monitoring and
MOSH < 2 µg/kg improvement
MOAH < LOD
Pyrrolizidine (PA) and Minimize content of Pyrrolizidine (PA) and tropane Continuous
tropane (TA) alkaloids (TA) alkaloids: monitoring and
Food safety
PA: do not exceed 50% of the DGT improvement
TA: no contamination
Pesticides Reduce pesticide residues as much as possible, Continuous
in particular: monitoring and
• Maximum quantity per single residue:Food colours Monitor all products containing food colourings to December 2020
determine whether the use of such additives is
necessary, and prefer the use of natural food
colourings in case their use is strictly necessary.
Replace azo food colourings with natural food
colouring.
Avoid quinoline yellow, carmine, erythrosine and
green S completely.
Preservatives Reduce the use of preservatives as much as possible December 2020
or eliminate them completely if this does not
compromise food safety.
Continuous research of appropriate technologies
aimed at making products long-lasting and safe even
without the use of preservatives.
Flavours Avoid artificial flavours as much as possible, replacing December 2020
them with natural flavours or extracts.
Subject all products with flavours to a check to
determine if their use is actually necessary.
A mindful diet
Fats (hydrogenated fats, Trans fatty acid content should not exceed 2g/100g Continuous
trans fatty acids, saturated of fat. monitoring
and unsaturated fatty Improve the composition of fatty acids by using and
acids) alternatives to saturated fats. Conversion from palm improvement
oil/fat to sunflower oil or other unsaturated fats. No
use of hydrogenated fats if technologically possible.
Palm oil Where palm oil is present, use only sustainably December 2020
produced oil with RSPO Segregated 7 certification.
Glucose-fructose syrup Use glucose-fructose syrup only where strictly and January 2025
technically necessary. If a product contains glucose-
fructose syrup, the fructose content should be less
than 42%, avoiding the use of high fructose corn
syrup (HFCS).
Genetically modified Increase products in the own-brand continuous Continuous
organisms assortment with the "NOGMO feed" seal. monitoring
and
improvement
Acronyms:
MRL: Maximum Residue Levels
TDI: Tolerable Daily Intake
LOD: Limit of Detection
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