CFG
26/07 final
Letter dated 31 August
2007 from Foodaware to Stephen Knight, Food Labelling and Marketing
Terms Branch, Food Standards Agency:
Dear Mr Knight
UK National Food Labelling Provisions
Foodaware supports the principle of full and accurate labelling on
products to enable consumers to make informed choices and to contribute
to the principles of fair competition in the market. We have expressed
concern in the past about national derogations and exemptions from
European laws which undermine the principles of fair and equitable
treatment for consumers wherever they live, and which can distort
competition between domestic products and imports. Therefore, we are
generally supportive of the Commission’s review of labelling
law and will comment in detail on the proposals when they emerge.
In our comments to DG SANCO on its consultation[1],
we noted that ‘there is little justification for many of the
differences in labelling requirement between pre-packed foods, non-pre-packed
foods and those packed on the premises’.
Exemptions from general rules always make comparisons more difficult
for consumers, and, in principle, we believe that foods packed on
the premises should be fully labelled. Information on durability is
essential for the safety of those who eat perishable products and
should be required on all products where shelf life affects safety
or quality. We nevertheless acknowledge some of the benefits of flexibility
identified in the FSA consultation particularly for suppliers of non-prepacked
products, those sold at the farm gate, and those provided for charitable
events.
Our regard to the specific recommendations are views are as follows:
1. Regulation 4(3)b – Provident
Societies including WI Markets Ltd
We support the recommendation that this provision should be allowed
to lapse as it can be covered by the retention of provisions for produce
pre-packed for direct sale.
2. Regulation 4(3)c – Charities
Provision
We recognise the value to charitable organisations, schools, community
groups and non-profit-making bodies of one-off sales of bakery produce
and preserves donated by individuals in support of fund-raising activities.
There is an obvious inconsistency in that such produce is not required
to comply with the general food labelling requirements in relation
to ingredients, safety information or information concerning allergens,
but is required to carry gm information where appropriate. We support
the view that an appropriate and proportionate approach to labelling
foods prepared other than in the course of a business should be negotiated
at EU level.
3. Regulation 18(1)e –
Fortified Flour We strongly support the view that consumers
should be informed of nutrients added to flour and that these should
be listed. We support the option to do nothing, so this provision
will drop. We have some reservations about the establishment of a
threshold below which labelling would not be necessary, as it would
undermine the principle of informed choice and potentially cause problems
for those who suffer from allergic reactions.
4. Regulation 18(2) – Added
Ingredients Provision It is not clear in the proposal how
the current UK provision differs in practice from the existing UK
requirement. Since there are generally accepted definitions of products
such as cheese, butter, vinegar etc we support the view that it should
only be necessary to identify individually any added ingredients and
so support Option 2.
5. Regulations 20(3)b and 21(3)b
– Manner of Presentation
– Consumers now understand the meaning of ‘use by’
and ‘best before’ dates on products which offer a valuable
food safety protection measure. We agree that any ambiguity in the
current Directive should be clarified so that these terms can continue
to be used.
6. Regulation 21(1)b –
Flour Confectionary Provision
As stated above, the exemption of flour confectionary products packaged
in crimp cases or wholly transparent packaging from full labelling
requirements is not justified particularly where those products are
produced on a regular basis, for example, by large retailers in store.
We support the FSA proposal that this exemption should be dropped.
7. Regulation 26(3) and 26(3)A
– Minor Accompaniment Provision
These regulations exempt food sold in individual portions or supplied
as a minor accompaniment to another food from much of the labelling
requirements (eg sachets of sauce in a restaurant). Information which
is so small that it cannot be read by the naked eye is wholly unhelpful
to consumers and adds cost. We support the proposal that the FSA should
seek a negotiated solution to the issue of the size of packaging which
would require full ingredients listing, provided the requirement to
state known allergens is retained.
Yours sincerely
Susan Knox
Chairman
1 Comments by Foodaware on 'Labelling:
Competitiveness, Consumer Information and Better Regulation for the
EU - a DG SANCO Consultative Document' CFG 15/06
|
