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Brussels, 5 april 2000
Re:Proposal for European Parliament and Council Regulation establishing a system for the identification and registration of bovine animals and regarding the labelling of beef and beef products and repealing Council Regulation (EC) No 820/97- 99/0204 (COD)
Dear Sir/Madam,
In view of the European Parliament plenary vote on the compulsory beef labelling system scheduled on 14 April next, Euro Coop wishes to support the objective of full traceability for beef but considers that the Commission proposal 99/0204 (COD) in reference fails to achieve this. Instead it requires information on the consumer label which is of very limited interest to consumers.
Euro Coop, the European Community of Consumer Co-operatives, is concerned about the potential outcomes of the Commission proposal and calls on the European Parliament to take the following consumer-oriented arguments into account in its final decision.
The Draft Regulation has been brought forward by the Commission in haste with the aim of fending off criticism from the European Parliament, but without giving enough consideration to how to achieve the desired goal in the most effective way. Already a number of Member States have had grave problems in setting up the computerised databases and reliable proof of origin systems required to comply with the current law.
Generally speaking, Euro Coop considers that the problem related to the safety of beef and beef products should be solved with appropriate controls and the necessary risk assessment/management in the whole chain and not with excessive and compulsory information which make the final product more expensive unnecessarily.
Getting more into the details, Euro Coop considers that the Draft Regulation :
- does not inform consumers about what they want to know - which is the country of origin
Article 13. will require the consumer label to carry six and (on our reading of "also" in Article 13.5) eventually ten pieces of information.
Most of this is information for the supply chain not for consumers.
In our experience consumers want to know where the meat "came from". The places of slaughtering and deboning do not answer that question and neither does the date of slaughter. It is impossible to understand the purpose of the declaration on ideal minimum maturation period. Consumers do not want to know that meat came from "the EC" or a group of third countries.
- muddles up information on traceability for the supply chain with information for consumers
This will create problems for all elements of the meat trade without making much difference to traceability. For example, ensuring that the date of slaughter is correct is problematic because meats are matured for different lengths of time so different meats with different kill dates are packed on the same day.
It will be extremely difficult to implement the law in any medium to high volume meat plant, and practically impossible in butcheries cutting and packing meat for direct sale. We cannot see how butchery shops will be able to implement the law at all.
- the effect of this proposal will be to the detriment of consumers.
Costs will rise adding to the upward pressure on prices, thus disadvantaging consumers.
Larger labels will be required in order to carry the information. This will prevent consumers from inspecting the product. The aim in labelling meat is to keep the label small so that consumers can see the product.
Finally, it has always been Euro Coop's clear view that information on the label should be useful to consumers, and should be directed at them. It has also always been Euro Coop's view that labelling rules should be derived only from the General Food Labelling Directive (79/112).
If the case is made for more consumer information on the beef label then this information should be presented under Directive 79/112. It should not appear in an Agriculture Directive and it should not appear in a law on traceability.
We thank you for your time and attention.
Please, do not hesitate to contact us for any further information.
Yours sincerely,
Caroline Naett
Secretary General
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