Proposed draft amendments to the General Standard for the labelling of prepackaged foods: Quantitative Ingredient Declarations (QUID)

Two alternative proposals concerning quantitative ingredient declaration (QUID) requirements are presented, the ‘original’ and the ‘alternative’ proposals.  Foodaware’s views on these are set out below.

The original proposal (circulated October 2000)

Our overall view is to strongly support the original proposal discussed by Codex at its meeting in May this year.  In particular, we would welcome the shift to a requirement for mandatory QUID declarations to be given in ingredient lists for every ingredient (including those within compound ingredients) comprising more than 5% of the food by weight.  This would represent an important improvement on the current requirement for QUID declarations only when special emphasis is placed on the presence of valuable or characterising ingredients, or on the low content of one or more ingredients.  

Moreover, we understand that, under this proposal, any ingredient emphasised on the label by words or pictures, or normally associated with the food by consumers, would also attract a mandatory QUID declaration.  This would need to be given in close proximity to the words or images emphasising it, or beside the common name of the food, in lettering at least 50% as large as the common name.  We also strongly support these aspects of the proposal.

Our only concern is that some important ingredients might still ‘slip through the net’ where they were present in quantities of less than 5%.  For example, where a food is making a health claim based on some attribute of the food (usually a particular ingredient) but where this ingredient is not specifically mentioned on the label in either words or pictures.  We would like clarification as to whether, in such cases, the ingredient would still require a QUID declaration on the basis that it was a ‘characterising’ ingredient.  We believe this should be the case.

The alternative proposal (May 2001)

On the other hand, we are very concerned that the ‘alternative’ proposal is much weaker from a consumer protection point of view.  Notably, the voluntary nature of the requirement and the fact that only ingredients essential to or associated with a food, those emphasised on the label, mentioned in the name, or comprising more than 25% of the food by weight, would trigger a QUID declaration.   This proposal would not improve existing Codex requirements in any significant way and would not adequately fulfil consumer requirements for full ingredient information on food labels.  Foodaware, is therefore disappointed that the original proposal seems to have been so drastically weakened

In sum, the adoption of the ‘original’ proposal would significantly strengthen the Codex labelling standard by ensuring that consumers are given much fuller ingredient information than is required by the current standard.  Consumer groups have been calling for full, clear and mandatory QUID declarations for many years and the ‘original’ proposal would go a considerable way towards achieving that goal.

30th November 2001