CFG
30/05
Letter dated 15 November
2005 from Foodaware to Chris Pratt, Head of the Hygiene Policy and
Legislation Unit, Food Standards Agency:
Dear Mr Pratt
Consolidation of EU Food Hygiene Legislation: labelling of
raw milk cheese – Foodaware comments
We have been alerted to this consultation, concerning the labelling
of raw milk cheeses with the term ‘made with raw milk’,
by one of our Observer members, Sustain. We gather that whether such
labelling should be mandatory or voluntary is being actively discussed
in Brussels in advance of the implementation of the food hygiene legislation
due to apply from 1 January 2006. While Foodaware was not included
in the original consultation list, we trust that you will be interested
in our views on this subject.
Firstly, we were under the impression that the European Commission
had been clear that the labelling of raw milk cheese ‘made from
raw milk’ was compulsory, not voluntary, both under preceding
legislation and under the forthcoming food hygiene legislation. It
is worrying to hear that such cheeses are only being labelled on a
voluntary basis in the UK at present and that compulsory labelling
is being questioned by the UK in discussions in Brussels.
We gather that HUSH (the UK E. coli Support Group) have carried out
a number of surveys that have shown that raw milk cheese is not routinely
labelled in many retail outlets and that staff are not always able
to give accurate information where labelling is absent. This is despite
the fact that the Specialist Cheese Makers Association recommends
that raw milk cheese be labelled. This situation indicates that the
voluntary approach is not working.
Therefore, not only is the consumers’ right to make an informed
choice about cheese purchases being denied at present, but some vulnerable
consumers may also be putting their health at risk.
While the health risks may be low, they do exist and pregnant women
and other vulnerable groups are specifically advised to avoid unpasteurised
dairy products. The Advisory Committee on the Microbiological Safety
of Food (ACMSF) recommended in the 1995 report on Verocytotoxin-Producing
Escherichia coli (VTEC) that cheese made from raw milk from cows and
other species should be labelled so that consumers can identify it.
The Government, in its response, recognised the importance of such
safety information but recommended that it be included in guidance
to the regulations rather than in the regulations themselves. In reaching
this decision, it appears that the Government was mindful that ‘many
cheese-makers already label their products as recommended’ and
that significant quantities of such cheese were sold without packaging
or mandatory labels. In 2001, the Scottish Task Force report on E.
coli 0157 also stated that cheeses made from unpasteurised milk should
be clearly identified at retail level to permit the consumer to make
an informed choice.
Dealing with this issue through labelling seems a sensible solution.
We cannot understand why the FSA should consider it necessary take
legal advice in an attempt to undermine the EC position and justify
a continuation of voluntary labelling which is not working effectively.
Compulsory labelling of raw milk cheese would ensure appropriate health
protection for consumers, enable them to exert their right to choose
and, at the same time, provide a level playing field for producers
and retailers. We urge the FSA to revise its position and recommend
that such cheese should be fully labelled for the reasons stated above.
Please note that, further to our letter of 8 November, these comments
are now final. We are grateful to Sustain and HUSH for drawing this
issue to our attention.
Yours sincerely
Susan Knox
Chairperson
cc Jeanette Longfield, Sustain
Steve Nash, HUSH
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