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Paper short abstract

Composite food data exposes power imbalances in EU data governance. Using Open Food Facts as a case, the paper shows how access rights, openness, and stewardship can transform fragmented, proprietary food information into a public data commons.

Paper long abstract

This paper examines composite food data as a critical site for understanding how power circulates through contemporary data infrastructures. Beginning from the observation that “you can see the nutrient data in a hundred grams”—a phrase that renders data seemingly stable and comparable—the analysis shows how nutritional information is in fact shaped by legal, commercial, and organisational architectures that determine who can access it, under what conditions, and with what guarantees of accuracy. Composite food data, especially for branded and frequently reformulated products, sits at the intersection of public‑health needs, proprietary control, and regulatory ambiguity. Although legally classified as non‑personal, these datasets are deeply relational, tied to everyday consumption, household decision‑making, and public‑interest research.

Drawing on documentary analysis and fieldwork with nutrition compilers and open‑data practitioners, the paper argues that the central challenge is not data scarcity but uneven access. Current European data law—split between the GDPR’s restrictive logic and the Data Act’s circulation‑oriented logic—struggles to accommodate socially essential but commercially protected datasets. The case study of Open Food Facts (OFF) illustrates how crowdsourced infrastructures can reconfigure access by combining open licensing, provenance tracking, and rights‑enabled data contributions. OFF demonstrates both the potential and the limits of open data: while it expands transparency and comparability, it also depends on sustained stewardship and unresolved legal questions around database rights and derivative works.