CFG
06/02
Letter dated 29 March
2002 from Foodaware to Keith Gregory, Food Labelling Division, Food
Standards Agency:
Dear Keith Gregory
Advice on country of origin labelling
Foodaware is pleased to forward you its comments on the FSA consultation
on country of origin labelling.
Foodaware supports clear labelling about the place of origin of the
food, and has already expressed this demand on various occasions.
Labelling is not solely a matter of enabling consumers to make
informed choices. It must also aim to encourage greater responsibility
on the part of producers, processors, retailers and consumers.
Foodaware is very concerned about the enforcement of the labelling
provisions. We are aware of the existing mechanisms for checking whether
food is from the places it states. If origin labelling is to be extended
and improved, we would like to have further clarification about the
enforcement level and its appropriateness. For example, what implications
will this have for Environmental Health Officers at the local level?
Will the Food Authenticity Working Party have a role?
More specifically, Foodaware comments on the FSA draft for consultation
are as follows:
Paragraph 27:
FSA draft states "If the place of origin of the food is not the
same as the place of origin of its ingredients, it may be necessary
to provide information on the origin of the ingredients".
Foodaware agrees with the examples given in this paragraph, but recommends
that the requirement to provide information on the origin of ingredients
should be reinforced. The second part of the first sentence should
be amended as follows " it should be necessary to provide
information on the origin of the ingredients".
Paragraph 28:
Foodaware insists that the origin of the product must be clear.
Paragraph 29:
We would like to emphasize that there can be problems with non-prepacked
food, especially with fruit and vegetables.
Paragraph 31:
Foodaware supports this recommendation
Paragraph 32:
Foodaware supports this recommendation.
Paragraph 33:
Foodaware supports this recommendation. Foodaware is concerned that,
for example, when a meat product is imported but packed in Britain,
it can be labelled "British". Another example is that meat
raised in one place can be moved, to Scotland for instance, for 'finishing',
thereby becoming a premium product.
Paragraph 34:
Foodaware supports this recommendation, which should cover all primary
produce.
Paragraph 35:
Foodaware supports this recommendation
Paragraph 36:
Foodaware feels that such declarations are of limited use. Nevertheless,
as stated in the FSA recommendation, they are more helpful than no
information at all. Some consumers may, for ethical reasons, wish
to avoid products from certain countries.
Paragraph 37:
Foodaware strongly supports this recommendation. Placing this information
in the same field of vision is essential.
Paragraphs 25 and 26 of the Annex:
Foodaware believes that consumers would also like to know the EU country
of origin for eggs and poultry meat.
We hope that these comments will be useful and duly taken into account.
Please do not hesitate to contact us if you need any further clarification
or information.
Yours sincerely
Lucy Harris
UK Co-ordinator
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