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Brussels, le 28 April 2000
Euro Coop calls for the safety of animal feedingstuffs, as a prerequisite
for the safety of foodstuffs
Euro Coop, the European Community of Consumer Co-operatives wishes to support the recent Commission's proposals for safer animal feed, and to address the following consumer-related comments to the ongoing debate within the European Institutions.
Since its creation in 1957, Euro Coop's major objectives have been to promote, defend and represent consumer interests at European level. Euro Coop currently represents more than 3200 local or regional co-operatives, membership of which amounts to over 19 million consumers in the European Union and 2 million in the associated countries of central and Eastern Europe.
A key element for consumer co-operatives activity is concern for people, and it is their task to act for the good of consumers by providing them with healthy and safe food, along with clear and complete information. To fulfil this objective, consumer co-operatives throughout Europe have developed highly demanding food policies throughout their food chains.
In its comments on Commissioner David Byrne's strategy on EU food policy of 17 November 1999, Euro Coop already stressed the importance of a coherent animal feed legislation, and agreed that it is essential to ensure a reliable quality of animal feed, as it is the first prerequisite to guarantee food safety.
Considering the serious food scares, such as the mad cow disease or the dioxin crisis, and the fact that safety of food from animal origin begins with safe animal feed Euro Coop supports the recent Commission's proposals for safer animal feedingstuffs, and wishes to address the following comments.
1. New safeguard measures to deal with emergencies in the feedingstuffs sector and to strengthen controls on animal feed
Rapid alert system for feed to be integrated in the existing rapid alert system for food
Euro Coop welcomes the Commission's proposal to extend its existing special powers in the food sector to the feed sector. Indeed, it is important that action can be taken quickly, whenever a serious risk arises. We therefore support any proposal allowing the Commission:
- to take the initiative to suspend or lay down special conditions for the marketing within the Community and exports to third countries of feed products likely to pose a serious risk
- to intervene directly and take interim measures with immediate effect in the event of a serious risk to public health, animal health or the environment.
Furthermore, Euro Coop supports the integration of a rapid alert system for animal feed into the rapid alert system for food. Such a system will be effective and credible only if all stakeholders in the food chain consider themselves as having the duty to inform the authorities if they have any knowledge about contamination or any irregularity in a consignment of products used for animal feed.
Euro Coop further agrees that Member States must have adequate contingency plans to deal with serious feed risks and that they should be obliged to inform the Commission as soon as a serious contamination or risk in feed or the food chain is detected.
2. Traceability / Responsibility of the whole food chain's actors
Euro Coop has always argued for measures giving priorities to consumer protection and answering the "global approach" principle, which covers all foodstuffs from stable to table. As the safety of foodstuffs from animal origin starts with safe feedingstuffs, it is crucial to be able to trace back the material in case a problem arises, or simply as a matter of transparency and consumers' information.
Therefore, Euro Coop supports the principle of traceability, but underlines that this can only be achieved through trustful documentation along the food chain, and again, through all stakeholders in the food chain considering themselves as having the duty to take active responsibility for their part of the chain.
Furthermore, Euro Coop calls for the feed manufacturing industry to be subjected to the same rigorous requirements and controls as the food-producing sector.
3. List of ingredients and Maximum residues limits
Euro Coop agrees on the need to clearly define which materials can or cannot be used in animal feed and therefore supports both a rapid expansion on the current negative list in the short term and the introduction of a positive list of feed materials in the long term.
Euro Coop supports a list of ingredients whose use is prohibited in compound feedingstuffs.
- As regards, contaminants in feed materials in general and dioxins in particular, Euro Coop considers that setting a maximum residues limit is just the starting point. The maximum residue limit should in no case be static. Euro Coop considers that the target should be zero.
- As regards the introduction of the obligatory qualitative and quantitative declaration of all materials included in the compound feedingstuffs, Euro Coop underlines that focus must be put on safety issues, and that those declarations' requirements should be balanced with those applicable to foodstuffs.
Euro Coop takes the view that the Commission should clearly encourage the Member States to carry out a monitoring programme for contaminants in feedingstuffs.
4. Bovine Spongiform Encephalopathy
Euro Coop welcomes the Commission's proposal for the introduction of an EU-wide BSE testing/monitoring programme.
As regards forthcoming proposal for a revision of Community legislation in order to exclude fallen animals and condemned material from the feed chain, Euro Coop wish to recall its December 1997 answers to the Commission's consultation paper on meat and bone meal. Euro Coop still supports the exclusion of fallen animals and all condemned material from the feed chain, and calls for the ban on the use in feedingstuffs of all animals excluded from the food chain.
We also called for a ban on the use of all animal protein in the feeding of ruminants in the long term.
5. Further actions needed in the field of animal feedingstuffs
- Genetically modified feed:
Bearing in mind the "farm to table" principle Euro Coop takes the view that any legislation on genetically modified organisms should be consistent and should therefore cover end food stuffs as well as primary products and feed stuffs.
Euro Coop calls on the Commission to stick to its September 2000 time table as regard the legislative proposal on novel feed, in particular of genetically modified organisms and feeding stuffs derived therefrom.
- Antibiotics used in animal feed:
Euro Coop calls on the Commission to pursue the prohibition of antibiotics used as growth promoters in the EU.
Euro Coop has always taken strong position on the potential risks to human and animal health, which may result from the excessive use of antibiotics as used as additives in feedingstuffs. In that respect, Euro Coop wishes to recall its demand for a total ban of all antibiotics used as growth promoters in feedingstuffs within the European Union.
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