CFG
18/01
Letter dated 17 December
2001 to Adam Scott, Novel Foods Division, Food Standards Agency:
Dear Mr Scott
FSA Consultation on the Proposed European regulations on genetically
modified food and feed, and the traceability and labelling of such
produce
The Consumer’s Food Group discussed the new issues raised by these
proposed regulations at its meeting on 29 October. I am therefore
sending some supplementary comments to my letter of 3 September and
a copy of the Group’s final comments which for completeness you may
make publicly available with other evidence if appropriate.
General Comments
Foodaware strongly reaffirmed the views stated in the earlier letter,
and regretted that the FSA Board did not support the Commission’s
intention to establish a system for labelling based on traceability.
This approach already forms the basis for enforcement of quality,
safety and labelling requirements for some other food products. Systems
of traceability are actively under consideration by the Commission
on Food and Farming for meat. Knowing the origin, method of production
and processing of foods and their ingredients is a necessary part
of a firm’s due diligence and we believe is good business practice.
As such the proposals should not add unduly to costs of production
and distribution. Indeed such costs need to be set against the costs
to individual firms and society of not implementing effective systems
for ensuring safe, wholesome supplies and accurate labelling.
Consumers want to be able to make an informed choice whether to consume
gm food and food containing gm ingredients. While a ‘GM free’ claim
has some attractions, the Group is concerned that such claims should
only be permitted where there is no possibility of adventitious contamination
and the produce comes from a traceable, identity preserved source.
Such an approach could be permitted on a voluntary basis.
Supplementary Response to Specific Questions: Proposed Regulation
on GM Food and Feed
1. Are the proposals an adequate response to consumer demands for
clear, meaningful labelling? What added value do they offer?
Yes. See previous comments. There is a consistently high level of
consumer demand for gm labelling. Recent research by the National
Consumer Council found that two thirds of consumers say it is important
that food made from gm plants is labelled, and a third say information
on gm ingredients is among the three most important pieces of information
provided on food. The Commission’s approach will extend the current
labelling requirements to cover processed products derived from GMOs
where there is none of the gm material present and so would remove
some of the current confusion. We also support the extension of labelling
to feed ingredients so that farmers know what they are giving their
livestock and can facilitate the accurate description of animals sent
for slaughter and onward supply to the dairy, meat and poultry industries.
Research by the National Consumer Council found 8 out of 10 people
want meat and other animal products fed gm feed to be labelled. If
‘gm free labelling’ is introduced, it will be necessary to identify
whether an animal has been fed on such ingredients to check the accuracy
of any claims.
2. Thresholds
As previously stated, we accept that it is necessary to set thresholds
for adventitious contamination, and believe the limit should be the
lowest technologically achievable. It is not acceptable for unapproved
gm material to be permitted in food on sale in the EU, and believe
that at the very least a risk assessment of such substances should
be carried out which is equivalent to that established for novel foods.
3. Labelling - Are the requirements adequate? Can they be enforced?
The overarching principle which should apply to labelling for gm produce,
food and feed containing gm ingredients is that it should be accurate
and not mislead. To that extent we oppose the introduction of statements
that a product ‘may contain gm materials’ which we believe to be unhelpful
and will not help consumers to make an informed choice.
4. Applications and approvals
The regulatory approach should be based on openness and transparency
in both the approval process and the scientific assessments on which
regulatory judgements are based. Although the detailed arrangements
and working methods of the European Food Authority have yet to be
determined, we believe the Authority should include lay people on
its scientific advisory committees and acknowledge the valuable contribution
that such representatives have made to the UK’s scientific advisory
committees in recent years.
We support the development of unique codes to facilitate traceability
and enforcement but this should be done internationally on a collaborative
basis so that they are not used as non-tariff barriers to trade.
We also believe that benefit could be gained from long term monitoring
of any animals fed on a diet including gm food to inform the safety
assessments and ensure that unexpected consequences can be identified.
I hope that this supplementary information clarifies and reinforces
our position. Foodaware is content for this response to be made publicly
available.
Yours sincerely
Ann Davison
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