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Reports and Memo's
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Memorandum on "Measures to improve consumer confidence in foodstuffs"
Table of contents :
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Introduction
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EURO COOP wishes to respond to the Commission's Communication "Priorities for Consumer Policy 1996-1998" and puts forward below its views with regard to the points raised under item 6: "Measures to improve consumer confidence in foodstuffs ".
EURO COOP is the European Community of consumer co-operatives. Its members are the national federations of consumer co-operatives in 13 of the 15 member states of the European Union and in 4 central European countries. Founded in 1957, EURO COOP today represents more than 3,200 local or regional cooperatives, the members of which amount to over 19 million consumers in the European Union and 2 million in the associated countries of central Europe.
It is the aim of the consumer co-operatives to provide information, education, and to protect the interests and the health of consumers. For this purpose, they offer a whole range of services such as the provision of foodstuffs with quality control in their own laboratories, magazines and information brochures distributed in the shops and to members, information and education campaigns and training courses for consumers"
Anxious to respond to the evolution of consumer requirements, the co-operatives have adopted very modern techniques in order to create undertakings which are the most apt to render this service. Today, EURO COOP's members group together more than 15,000 sales points in the EU (over 28,000 in the associated countries of central Europe), which range from the local shop, the last remaining store for the community in remote regions of Europe, to the hypermarket in urban shopping areas.
Organisations of consumers, for consumers, the consumer co-operatives believe in a global approach towards the activities of production and distribution, which takes into account environmental problems, the health of consumers and their social responsibility as undertakings.
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Green Paper on Food Law
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EURO COOP calls on the Commission to ensure that there is a high level of protection, complying with consumers' requests, and that laws are simplified and workable.
EURO COOP's position has always been that legislation should be horizontal and, only when necessary, vertical. Vertical directives should be limited to cases where more specificity is required.
European food legislation has grown up in steps and stages over the past years and the time is certainly ripe to review it.
Referring for example, to the Community health mark, national controls function well. However as, they have to be checked by European Community inspectors, the procedure becomes too lengthy and companies cannot wait long periods before being able to export their products. Laws should be workable and they should be proportionate; they should achieve the outcome for which they are intended.
With regard to other issues, such as the impact of the environment or animal welfare on food policy, it has long been the practice of Co-ops across Europe to take these questions into account when forming co-operative policies. It is the view of EURO COOP that this approach should be adopted by the European Union in drafting the Green Paper and in formulating future action.
The Green Paper has been awaited for over two years and the Commission must find the political will to publish it and must no longer use its absence as an excuse to continue to defer action.
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Simplification of Foodstuffs Legislation
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In the late 1980's, the UK cooperative movement complained regularly to Government and the EC that the vital area of food hygiene was being, if not ignored, treated in a haphazard and piecemeal fashion. It stated at that time its opposition to the continued development of sectoral, vertical hygiene directives, preferring to see a simple and consolidated horizontal hygiene directive encompassing all foodstuffs.
The original draft of the EC General Food Hygiene Directive was in fact derived from proposals formulated by the Cooperative Movement in the UK following the four year campaign of the Cooperative Union on the issue.
Under the General Food Hygiene Directive, the Commission is committed to undertaking a review of all its hygiene legislation by 14 June 1996.
EURO COOP believes that a single set of hygiene rules should be created, incorporating product specific hygiene arrangements in its annexes where these are truly required. Once the single set of harmonised hygiene rules is created, there should be a general review of all product-specific regulation with a view to ensuring that it is understandable and that ambiguities in definitions, terminology, requirements and procedures are removed.
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Food safety
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Risk analysis is the basis of the general Food Hygiene Directive which, as mentioned above, was based on an initiative by the Co-operative Movement.
Risk analysis permits a systematic approach to the identification and assessment of hazards and risks associated with the manufacture, distribution and use of a food product, as well as the definition of preventive measures for their control.
This puts the responsibility for determining the critical aspects of producing safe foods into the hands of the manufacturers and retailers. At the same time it gives food manufacturers the opportunity to improve the efficiency of control by providing a disciplined, systematic approach to the procedures for assuring food safety. It also gives food inspectors the opportunity to obtain a more accurate picture of the effectiveness of process control over a longer time period.
There are, however, weaknesses in the control system and, in our view, these lie at the stage of the primary production. Too much money is spent on traditional end product controls instead of making the HACCP (hazard analysis of critical control points) principle work at the primary production stage. A risk analysis approach at the primary production stage would avoid problems at later stages in the food chain. To take the production of meat as an example, an important part of the official control of meat takes place when it is on sale in the shops and it is then too late to remedy the initial defect. In order to solve the problems, the HACCP principles should reflect "a cradle to grave" approach.
In order to ensure the safety and quality of their products, EURO COOP's members are engaged in many own-control activities, for example:
- quality assurance of foodstuffs sold in Co-op shops and testing and development in own laboratories of own brand products. Preventive action includes the careful selection of Co-op suppliers;
- supplementary controls on perishable and non-perishable foodstuffs by agreement with quality research centres (university laboratories and private laboratories);
- surveys on sanitary conditions at meat processing plant to guarantee a constant improvement in quality;
- the sale by some Co-ops of fruit and vegetables under the label "produced with Co-op care". They are grown according to the system of integrated horticulture using organic methods to combat plant diseases and drastically reducing the use of other chemical products; all chemical treatment after harvesting is eliminated. Such products are controlled at every stage of the production and also through an intensive programme of analyses of residues;
- encouraging producers and consumers of organic food. The growing market of organic food means less use of chemicals in food production and better food safety;
- other members sell own brand fresh meat, which is controlled from the farm to the sales point through inspections at the agricultural enterprise and in the warehouses and subsequently through laboratory analyses.
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Official control systems
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As the Commission states in its Communication "public authorities throughout the European Community operate a system of controls designed to assure that food on the market is wholesome ".
The members of EURO COOP do not believe that harmonisation of controls at EU level would solve the problems. Many national systems are excellent and work well and to change them could have more negative than positive effects.
However, EURO COOP notes that there are different approaches to the interpretation and implementation of the 1989 Directive on the official control of foodstuffs, which lead to unfair trading conditions. The Commission should ensure that there is even-handed enforcement of the Directive.
An important problem which needs to be addressed urgently is that of EU laws introduced to ban certain products, substances or practices. If the consumer mistrusts public controls in general, it is because the member states are not able to control their own laws on bans. An example here is the ban on the use of hormones in the production of meat.
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Food Labelling
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After years of discussions leading up to the amendment of the 1979 directive on the labelling and presentation of foodstuffs, many people, both consumers and producers alike, feel that the present regulatory situation no longer complies with present day requirements. It is not clear that the information on the label is helpful to the consumer. The question is of course problematic due to the fact that there is a general demand for more and more information and limited space on labelling.
EURO COOP's six objectives for EU food labelling policy are:
- The information on the label should be directed primarily at consumers.
- The label should be informative for consumers.
- The law should be user-friendly.
- The law should not prevent producers and retailers from giving additional consumer information if they wish to do so.
- The dates of implementation of new legislation should take into account the timescales' of both producers and retailers.
- Proposals for new labelling requirements should take account of the fact that there is limited space on the label.
These should be the basis of any EU action on labelling.
Food labelling needs to be reviewed and simplified. In any review of EU policy, a good general test of what must be indicated as a priority on labelling is to examine how the consumer can use the information given. EURO COOP is prepared to discuss further the question of food labelling internally and to provide an input to Directorate-General XXIV at a later stage.
The proposed Community rules on quantitative ingredient declaration constitute a very positive step in the right direction. To give, on the other hand, a negative example, we feel that the EU has failed with the nutritional labelling directive; the Member States have had to adopt legislation which was generally inferior to their national laws. The consumer co-operatives have never been happy with this directive in terms of content. They were forced to change from good Co-op schemes and are no longer allowed to add additional, useful information. The Commission is committed to submit a report to the European Parliament and to the Council on the application of the present Directive by 1 October 1998. At the same time, it shall submit to the Council any appropriate proposals for amendment. This review should be undertaken in good time.
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Claims
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There is a need for EU legislation on claims. EURO COOP wrote to Commissioner Bonino on 7 November 1995 emphasising the need for food claims to be regulated at European level. EURO COOP does not agree with Mrs Bonino's response dated 13 February 1996, which states that the Commission considers that the matter is already partially covered by the provisions of the general directive on labelling and that a solution to the problem of misleading advertising resulting from claims could be included in the misleading advertising directive.
Functional foods are gradually coming onto Community markets. The use of health and nutrition claims are already being discussed in Codex. Common rules for the use of claims regarding foodstuffs would make it easier for consumers when such foods are marketed.
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Consumer consultation
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EURO COOP deplores the fact that for some considerable time there has been little consultation of the European consumer groups on food policy, either formally or informally. The Advisory Committee on Foodstuffs, on which EURO COOP is responsible for co-ordinating the consumer representation, has not met since December 1994, despite the fact that important pieces of legislation have been brought forward, for example the directives on foods for particular nutritional purposes.
EURO COOP calls on the Commission to commit itself to full consultation both within the Advisory Committee and bilaterally with the consumer organisations.
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Conclusion
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The foodstuffs sector is highly regulated and in general, to a satisfactory level. Consumers are however questioning more and more the quality and safety of food. It is the duty of the whole food chain to retain the confidence of the consumer.
Consumers often have well-founded fears about unhygienic production methods, unnecessary additives, hormones in food, animal welfare, etc. The claims and counterclaims of lobby groups, government scientists and producers and, not least, the blow-up given by the media to any real or imaginary food scare, leaves the consumer in an uneasy state of anxiety and badly in need of balanced advice.
EURO COOP believes that, in order to restore consumer confidence, the EU should place more emphasis on consumer education and information.
The consumer co-operatives are already very active in this field, particularly with regard to foodstuffs. We refer below to a number of activities carried out by EURO COOP's members:
- full informative labelling of all own-brand products.
- issuing of information leaflets on, for example, food safety through correct food handling procedures, diet and health, additives, food allergies, genetically engineered foods, etc.;
- provision of "free phone" consumer advisory services;
- organisation of information campaigns on matters of topical interest and importance in the foodstuffs sector,
- consumer workshops for schools including information on "food and new technologies";
- leaflets and folders on healthy eating and drinking, with recipes and tips;
- provision of nutritional advice for the various age groups of the population;
- permanent co-operative centres for consumer education providing up-to-date and accurate nutritional information;
- organising meetings with experts on healthy eating schemes;
- issuing of periodicals which emphasize the importance of a healthy diet;
- publication of educational kits for schools, consisting in books, videos, commodities describing "what to eat at meal-times" for a healthy lifestyle;
- school initiatives for young consumers with educational material for children at nursery and primary school level;
- educational intineraries for school children in Co-op supermarkets.
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