Competere has submitted its response to the public consultation launched by the Swedish Food Agency on the revision of the Nordic Keyhole regulation. Our contribution aims to support a balanced, science-based approach to consumer information, grounded in freedom of choice and respect for individual and cultural diversity.

Download the full contribution

The document highlights the importance of strengthening tools that effectively inform consumers, while cautioning against approaches that risk oversimplifying nutrition and limiting informed choice.

Supporting a Well-established and Credible System

The Nordic Keyhole stands out as one of the longest-running front-of-pack schemes in Europe and a robust example of a category-based approach to nutrition information. By enabling comparisons within food groups, it supports more informed choices without penalising specific products or ingredients, nor creating market distortions for products that do not carry the label.

Over time, the system has contributed to greater transparency and consumer awareness, while preserving fair competition. Updating the Keyhole scheme’s criteria in line with evolving science, the Nordic Nutrition Recommendations, and changes in consumer behaviour, culture, and society is therefore both necessary and constructive. At the same time, maintaining a credible, science-based voluntary scheme remains essential to ensure trust among consumers, industry, and public authorities. 

Preserving Clarity and Avoiding Fragmentation

Maintaining a clear and coherent framework across the Nordic region remains essential. The coexistence of multiple front-of-pack labels within the same market risks generating confusion and weakening the effectiveness of established systems. Indeed, a proliferation of competing schemes may ultimately reduce transparency rather than improve it, while creating imbalances driven more by market power than by scientific robustness. 

The Limits of Simplified Scoring Models

Prescriptive scoring and warning-based models, such as the Nutri-Score-type systems, risk oversimplifying nutrition by reducing complex dietary realities to a single aggregated score. This approach does not reflect how foods are actually consumed – within broader dietary patterns, portion sizes, and diverse lifestyles – and often applies uniform criteria that overlook individual differences and needs.  

As a result, these systems tend to guide choices rather than support informed decision-making, providing limited contextual information. They may also generate unintended effects, from encouraging reformulation strategies aimed at improving scores rather than quality, to disadvantaging traditional products and smaller producers, and influencing consumer behaviour in ways that do not necessarily lead to healthier overall diets. 

From Simplified Labels to Informed Choices

The evolution of consumer information is increasingly shaped by digital technologies. Tools such as QR codes, apps, and AI-based systems can provide more detailed and contextualised information, enabling individuals to better understand how products fit within their overall diet and lifestyle.

This shift opens the way to more personalised approaches to nutrition, where information is tailored to individual needs rather than reduced to generalised scores. In this perspective, transparency, data protection, and user control become essential elements.

Looking Beyond Food Alone

Health outcomes are influenced by a broader set of factors that go beyond diet. Physical activity, sleep, stress, and sedentary behaviours all contribute significantly to overall wellbeing.

Raising awareness around these dimensions – including the impact of increasingly digital and sedentary lifestyles – is key to developing more effective and comprehensive public health strategies.

A Forward-looking Approach

Rather than multiplying simplified labelling systems, a more effective path lies in strengthening existing, credible tools while investing in better information and innovation.

The priority should remain clear: enabling individuals to make informed and conscious choices, while preserving diversity, supporting producers, and reflecting the complexity of nutrition and lifestyles.