CFG
41/07 final
Letter dated 17 December
2007 from Foodaware to Janet MCkenzie, Food Labelling and Marketing
Terms Branch, Food Standards Agency:
Dear Ms McKenzie
Revision of Food Standards Agency Food Labelling Guidance
on Country of Origin
I am extremely sorry that we missed the deadline of 13 December
for our response to this consultation, and hope that we are nevertheless
not too late for our views to be included.
Foodaware has supported country of origin labelling for many years,
and considers it is even more important now that consumers are actively
seeking information on the source of foods, and many would like
to choose local produce where it is available. We welcomed the original
guidance on origin labelling in 2002 and so we make only brief comments
on the proposed changes which members discussed at their December
meeting. We note that in preparing this guidance you have consulted
with the devolved administrations and members feel strongly that
this guidance should apply throughout the UK so that the Agency
is promoting a consistency in approach despite the voluntary nature
of the guidance itself.
Members queried why FSA has consulted on this revised guidance at
this time, when it is widely expected that the European Commission
will bring forth new proposals before the end of the year including
origin labelling. Presumably, FSA will have to consult in due course
on the Commission proposals so the timing of this document seems
premature. It is extremely costly in time and resources for consumer
groups to respond to the many consultations which are now produced,
and we think that this duplication could have been avoided by a
slight delay until the EU proposals were known.
Our members take the view that the advice to catering establishments
is wholly inadequate given that people are increasingly consuming
food outside the home and want in many cases to know where it comes
from. Para 22, at the very least, should cross reference the other
parts of the guidance which are relevant for catering outlets and
restaurants.
Most of the examples of origin marking in the guidance relate to
meat and meat products and the text suggests that origin information
should be given for principle meat and dairy ingredients. In 2002
we suggested that EU country of origin should also be given for
poultry meat and eggs. Consumers want more information for a variety
of reasons and should not be misled about the origin of any ingredients.
Issues of perceived risk or a desire to choose or avoid products
from particular places may be relevant to fish and shellfish, or
to fruit and vegetables. The examples should be more broadly based
and cover all the above food categories, as well as processed produce
such as pasta containing American wheat which may mislead purchasers.
I hope these comments come in time to be taken into account, and
look forward to receiving feedback on the results of the consultation
in due course.
Yours sincerely
Susan Knox
Chairman
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