On Tuesday, 3 March 2026, the Polish Ministry of Health held a meeting on the harmonisation of front-of-pack nutrition labelling systems (FOPNL). The meeting was attended by representatives of public administration and industry organisations. Joanna Olszak, food law expert at IGI FOOD LAW, also participated in the meeting and took the floor in the discussion on the regulatory status of the Nutri-Score system in Poland.
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FOPNL systems are front-of-pack labelling schemes that indicate a product’s nutritional value, either by repeating selected nutrients from the nutrition declaration (e.g., NutrInform Battery) or by providing an overall nutritional assessment through symbols, letters, or colours (e.g., Keyhole, Nutri-Score). The European Commission had initially intended to select (or develop) a single mandatory system at the EU level; however, these efforts have been suspended. According to the presentation delivered during the meeting, in May 2025, the Commission informed stakeholders that work on harmonised FOPNL had been put on hold due to the complexity of the topic and strong divergence of Member States’ positions.
A representative of the Ministry of Health indicated that, in line with the European Commission’s position, the use of FOPNL schemes on products placed on the Polish market should be based on appropriate national legislation.
In particular, it was highlighted that the Commission considers Nutri-Score – to the extent it conveys a positive message (e.g., a green “A”) – to be potentially within the definition of a nutrition claim. As a result, it falls within the scope of Regulation (EC) No 1924/2006. Consequently, such a system may only be used within a Member State if it has been adopted at national level in accordance with Article 23 of that Regulation.
It was clearly stated during the meeting that, with regard to food produced in Poland, the use of Nutri-Score-type labelling would require the adoption and notification of a national legal act. At the same time, it was emphasised that food products originating from Member States that have officially adopted Nutri-Score may continue to be marketed in Poland under the principle of the free movement of goods.
The meeting has a formal follow-up. The Ministry of Health requested that stakeholders submit their views on the use of Nutri-Score and other FOPNL systems that require national notification. The deadline for submission of positions has been set for 15 April 2026.
The Ministry has therefore asked industry organisations to take a position on the future of FOPNL systems in Poland.
From a market perspective, this constitutes a clear signal that the administration expects a defined direction: whether Poland should adopt one of the existing systems (such as Nutri-Score) or rather move towards discontinuing the use of such schemes for products manufactured in Poland. This is also reflected in the presentation, which outlined two possible scenarios: (i) adoption of Nutri-Score as a national system with notification of the relevant legislation, or (ii) withdrawal of the system from use on products produced in Poland.
If Poland does not decide to adopt any FOPNL system that requires a national legal basis, food business operators will need to discontinue their use, at least for products placed on the Polish market.
For some manufacturers and retail chains, this may require revising labelling and packaging materials. The available information also indicates that the issue remains open and is currently subject to further consultation with stakeholders.
We remain available to address any questions regarding the application of EU and national food law requirements.
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