 |
Brussels, 17 november 1999
EURO COOP'S COMMENTS ON COMMISSIONER DAVID BYRNE'S STRATEGY ON EU FOOD POLICY
Introduction
- GENERAL ISSUES
- Scope of EU legislation
- WTO/ Precautionary Principle
- Public information and risk communication
- Controls and management of crisis
- Quality of Community legislation
- Legislation versus voluntary agreements
- SPECIFIC FOODSTUFFS-RELATED ISSUES
- Green Paper on food law
- Labelling
- Genetically modified foodstuffs
- Animal feed legislation
- Antibiotics in feedingstuffs
- Hormone-treated meat/ BST
- Animal welfare
Annex : Available Euro Coop's Positions paper on EU Food Policy Issues
 Introduction
Euro Coop welcomes the confirmation of Mr. David Byrne as the new European Commissioner for health and consumer protection and wishes to address the following responses to his strategy on issues related to food policy.
Over the last years, Euro Coop has taken strong positions on food-related issues, including comments on the Commission Green Paper on EU food legislation, genetically modified foodstuffs, labelling, hygiene, additives, the use of antibiotics in feedingstuffs, the ban on hormone-treated beef, etc. Our most relevant food-related positions are listed in the attached annex, and we will be happy to provide copies if needed.
Euro Coop is the European Community of consumer co-operatives. 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.
It is on the basis of this long-standing experience that Euro Coop has prepared comments on the following food issues, which Commissioner Byrne raised in his answers to the European Parliament.
We offer these comments as a contribution to the debate within the Council, the European Parliament and the Commission on these very important issues for European consumers.
I. GENERAL ISSUES
a) Scope of EU legislation
Euro Coop welcomes Commissioner Byrne's position, that EU public health and consumer protection laws are neither excessive nor unnecessary.
Euro Coop considers that so far, legislation has been too much concerned with the single market, and too little with public health, animal welfare, ethical and environmental issues.
Euro Coop supports measures giving priority to consumer protection, and answering the "global approach" principle, which covers all foodstuffs from stable to table However, we wish to point out that before drafting any new law or amending existing ones, the Commission must carefully consider "where" and "how" in the food chain the problem has arisen, and "where" and "how" in the food chain the problem can be addressed.
Euro Coop looks forward to commenting on proposals about a European Food Agency.
b) WTO/ Precautionary Principle
At the international level too, Euro Coop calls on Commissioner Byrne to put forward EU policies which promote a high level of consumer health protection and which ensure that an objective, transparent and reliable procedure is followed.
Euro Coop also wishes to reaffirm the right of individual countries to maintain safety standards higher than internationally accepted standards in order to protect its consumers.
Furthermore, consumer co-operatives are concerned that international decisions are increasingly driven by economic and political interests, which rely mainly on scientific references and which often prevail over consumers' concerns.
Euro Coop believes that factors such as the precautionary principle, animal welfare and environment are as legitimate and important as scientific evaluation and should be taken into account along with science within the decision making process. We consider that science is not an absolute and that the interpretation of scientific results is not entirely value-free. In each case, it should be for the participants in that discussion to argue that any one of the non-scientific factors is irrelevant, not for the participants to have to argue that they are relevant.
Euro Coop has made this clear to the Codex Alimentarius through its international body, the International Co-operative Alliance, which has observer status at Codex.
c) Public information and risk communication
Euro Coop agrees that efforts are needed to improve risk communication as well as transparency. Indeed, communication with the public is crucial to ensure that up to the minute information is available, and to reduce the impact of false or alarmist messages.
We share Mr. Byrne's views that to restore consumer confidence, the EU should place more emphasis on effective risk communication so that consumers may make an informed choice.
Consumer co-operatives throughout Europe take a pride in giving speedy and accurate information to consumers, for example by providing informative labelling of all own-brand products, in providing a "free phone" consumer advisory services, etc.
Furthermore, Euro Coop supports Mr. Byrne's call for a more systematic and early use of the Rapid Alert System for food. We agree with the need for more exchange of experience between the Member States' competent bodies.
d) Controls and management of crisis
Euro Coop agrees with Mr. Byrne that the role of the EU in auditing controls should be reinforced. We consider that the focus should be on the outcomes rather than on processes, on whether the national inspections achieve the required results for consumers not on how they do it.
Many national control systems are excellent and work well and to change them could have more negative than positive effects. However, there is a need for action in three areas :
- auditing of the results of the controls
- setting of minimum standards for the outcome
- setting of priorities for national control authorities to make sure that the national controls throughout the EU achieve the required level of performance necessary.
These will clearly be key issues in the discussions for a proposed European Food Agency.
Furthermore, Euro Coop stresses that the Commission's control of the national control systems, and the inspection reports must be transparent and that the Food and Veterinary Office's evaluations should be published.
e) Quality of Community legislation
Euro Coop welcomes Commissioner Byrne's argument in favour of legislation for consumer protection, which is readily comprehensible to ordinary people.
Euro Coop agrees with Commissioner Byrne that existing food legislation must be simplified, that gaps in the law must be made good, and shortcomings remedied.
Euro Coop considers that legislation should be horizontal and that vertical laws should be reserved for crucial consumer safety issues only.
Euro Coop calls on Commissioner Byrne to ensure that consumers are considered as major stakeholder in the decision making process, and that they take full part in the discussion of implementing issues.
f) Legislation versus voluntary agreements
Euro Coop supports the view that legislation and voluntary agreements are complementary. We consider that, when properly administered, self-regulation, including HACCP is the best way of securing safe food.
However, Euro Coop notes that self-regulation is not a replacement for effective enforcement. It must be used in partnership with enforcement authorities.
II. SPECIFIC FOODSTUFFS-RELATED ISSUES
a) Green Paper on food law
Euro Coop welcomed the April 1997 Commission Green Paper on the general principles of EU food law. It gave the long-awaited opportunity to debate the aims and objectives of such an important issue. Euro Coop was one of the first organisations to publish its comments on the Green paper, and we are eagerly awaiting the follow-up.
In that respect, Euro Coop strongly supports Commissioner Byrne's intention to issue a White Paper on Food Safety, with a target of the year 2002 by which all the necessary measures would be implemented. We will be happy to share our views on the forthcoming White Paper and to collaborate with the Commission and the Parliament to achieve that timetable.
b) Labelling
Information on labelling is a key element for Consumer co-operatives, who believe strongly in the right of the consumer to make choices on the basis of full and accurate information. In that respect, Euro Coop considers that current labelling requirements should be reviewed. In particular, we stress the need for a EU law on health claims and for a thorough review of the Nutrition Labelling Directive.
c) Genetically modified foodstuffs
Euro Coop notes Commissioner Byrne's intention to support a science-based and prudent approach towards genetically modified organisms (GMOs). We agree that the authorisation of GMOs' must be time limited and carefully monitored, but we have reservations about the fact that those authorisations are so largely based on science. Euro Coop considers that the precautionary principle must also be a key element in such judgements.
Euro Coop welcomes Mr. Byrne's position in favour of an informative labelling of GM products to make it possible for the consumers to make a choice. We urge the Commission to press ahead with the work on the labelling of both genetically modified foodstuffs and GM animal feed, and to submit the announced proposal as soon as possible.
Consumer co-operatives across the EU do not oppose the use of biotechnology but plead for a responsible and controlled use of it in food. They took clear position and set out the basic principles on which GM food products should be placed on the market, including the principles of segregation and traceability.
Finally Euro Coop urges the Commission to finalise work on the threshold value for unintentional mixture of GM and non-GM crops and ingredients and on accreditation of analytical methods of control to make documented identity preservation systems work in practice.
d) Animal feed legislation
Euro Coop welcomes the confirmation by the new Commission of its intention to act rapidly and thoroughly to adopt animal nutrition legislation and to propose measures on animal waste.
Euro Coop agrees that coherent animal feed legislation is essential to ensure that the quality of animal feed is reliable, as this is the first prerequisite to guarantee food safety.
Euro Coop considers the issue of animal feed as one of its priorities and will be ready to comment on forthcoming proposals.
Euro Coop repeats its answers to the Commission's consultation paper on meat and bone meal, where we supported the exclusion of fallen animals and all condemned material from the feed chain, and called 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.
e) Antibiotics in feedingstuffs
As regards antibiotics used as additives in feedingstuffs, here again, Euro Coop takes a strong position on the potential risks to human and animal health, which may result from the excessive use of antibiotics as growth promoters.
In that respect, we support Commissioner Byrne but wish to recall our demand for a total ban of all antibiotics used as growth promoters in feedingstuffs within the European Union. On November 1998, Euro Coop, jointly with other NGOs issued a position urging the EU to ban the use of all antibiotics as additives in feedingstuffs.
f) Hormone-treated meat/ BST
Euro Coop calls on Commissioner Byrne to support the EU ban on the import of beef meat from animals which have been treated with hormone growth promoters. We wish to stress the need for additional researches and full risk assessment of the uses of hormones in meat production (as regards consumer health, animal welfare, environment and ethics). Furthermore, Euro Coop underlines that labelling should not be used to solve fundamental issue like this.
On the issue of bovine somatotrophin, Euro Coop strongly supports Mr. Byrne and reaffirms its strong opposition to the use of BST in milk production for reasons of consumer health and animal welfare.
g) Animal welfare
Euro Coop supports proposals which require animals to be treated well, protected from unnecessary suffering and illness, and housed and treated in such a way that their health is promoted and natural behaviour is possible.
Euro Coop also welcomes further legislation to ensure the well-being of animals during transport and slaughter.
Finally, Euro Coop considers that animal housing should be constructed in such way as to promote animal health and reduce the need for medication.
Annex : Available Euro Coop's Positions paper on EU Food Policy Issues
- Euro Coop's comments on the European Commission Green Paper on the general principles of food law in the European Union (5/09/97).
- Euro Coop's comments on the precautionary principle (21/01/99).
- International Co-operative Alliance's statement on the role of science and "other legitimate factors" in the elaboration of Codex standards (14/04/1999).
- Euro Coop objectives for EU food labelling policy (30/09/94).
- Euro Coop comments on the proposal for a Directive on the use of claims concerning foodstuffs (26/01/95).
- Euro coop position on: "Genetically modified maize : a threat to consumer confidence" (6/02/1997).
- Euro Coop's position on the Commission draft proposal on the labelling of food made from GM soya beans and maize(22/12/97).
- Euro Coop pleads for a responsible use of biotechnology (8/04/97).
- Euro Coop's concerns about the consumer's right to choose between GM and non-GM food products (12/05/98).
- Euro Coop's answer to the Commission on meat and bone meal (17/12/97).
- Euro Coop's position paper on BSE : call for priority to consumer interest and public health (10/0796) + Letter to Commissioner Emma Bonino on Measures to inform consumers about BSE (26/04/96).
- Euro Coop pleads for a ban of antibiotics as growth promoters in feedingstuffs (12/01/98)
- Euro Coop, jointly with other NGOs urge the EU to ban the use of antibiotics as additives in feedingstuffs for breeding animals (6/11/1998 and 15/12/1998).
- Euro Coop calls on the EU to maintain the ban on hormone-treated beef (16/04/1999).
- Euro Coop statement in support of the EU beef hormone ban (28/05/97).
- Euro Coop welcomes the Commission's proposal to ban the use of Bovine Somatotrophin in milk production, and calls on the Council and the European Parliament to adopt such position (27/10/1999).
- Euro Coop's opinion on animal welfare (15/07/96).
|
|
