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Brussels, 31 october 2000
Consultation paper on the proposal to complete the positive list of foodstuffs authorised for irradiation
European Commission
Mr Robert J. COLEMAN
Director-General
DG SANCO
200 rue de la Loi
B-1049 Brussels
Dear Mr Coleman,
In response to your letter dated 27.09.00, please find below Euro Coop comments on the Commission's proposal to complete and extend the Community list of foodstuffs authorised for irradiation.
Euro Coop does not agree with the list of products proposed by the Commission to be added on the positive list of foodstuffs authorised for irradiation, and is very critical of the Commission's strategy. This position is based on concerns about the way our food is produced.
Euro Coop is not opposed altogether to food irradiation. Since the publication of the first Commission proposals on the irradiation of foodstuffs in the early 1990s', it has supported the authorisation for irradiation to dried aromatic herbs, spices and vegetable seasonings. However, it must be noted that some Euro Coop members do not accept irradiation of these products for their own brands.
In case of further authorisations, Euro Coop considers that it should only be granted on a product-by-product basis and when the following conditions are met :
- irradiation shall only be authorised for foodstuffs representing a low contribution to food intake;
- irradiation is the ultimate need if other methods of preservation demonstrably fail to ensure the provision of safe products;
- irradiation should only be used if there is a significant benefit to consumers;
- irradiation shall in no way be used as a substitute for hygiene or health practices or good manufacturing or agricultural practices.
Euro Coop believes that the products proposed by the Commission to be included on the positive list do not respond to these criteria. Normal preservation techniques, such as cold storage, etc. are perfectly adequate to ensure the safety of the products such as chicken meat, frog legs, peeled shrimps, dried fruits, etc. Irradiation shall therefore not be authorised for these products.
The Commission's proposal discusses safety and hygiene at the wrong point of the chain, and is not in line with its new holistic approach of the hygiene rules, covering all stages of production, from the farm to the table.
A perfect example of this wrong approach, is the mechanically recovered chicken meat, which may be "unavoidably contaminated and needs to be decontaminated". It is perfectly possible to raise chicken in a salmonella-free environment, thus making sure that salmonella does not occur in the meat, in which case irradiation is not needed.
Euro Coop stresses that priority should focus on improving food production at primary level, storage, manufacturing processes, etc. rather than on killing off contamination at the last stage by irradiation. It may actually make the problem of food poisoning worse, if irradiation is being used to legitimate bad hygiene rather than to eradicate it.
Furthermore, Euro Coop wishes to make the following specific comments concerning the Commission's strategy to draw up the positive list:
- Extended shell life of food products is not in the interest of the consumer, but always in the producer's interest;
- We cannot accept that a reasonable technological need is only defined by the fact that a product is already irradiated in substantial amount in at least one Member State;
Finally, as already stated above, Euro Coop wants to underline that some of its members are totally opposed to the irradiation of foodstuffs and ban its use in their own-brand products. Even in those countries where, for example, irradiation of meat and poultry is authorised, Euro Coop members do not prove the need to have recourse to this process.
We hope that these comments and information will be useful to you and your services.
Yours sincerely,
Caroline Naett
Secretary General
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