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Brussels, 3 June 2002
Letter sent to MEPs on GM feed and food, traceability and labelling.
Vote in Environment Committee 04 June 2002
Dear Sir/Madam,
Tomorrow morning, you will vote on two important Draft Reports on GM feed and food, traceability and labelling. Euro Coop, the European Community of Consumer Cooperatives, wishes to reiterate its call for a full implementation of consumers' right to choose between genetically modified (GM) and non-GM foodstuffs.
Euro Coop represents undertakings, active in the retail sector, which are owned and controlled by their members, the consumers. We have always claimed that all GM foods should be subject to a rigorous mandatory approval process and that labelling should be based on full traceability and segregation to ensure that consumers have a choice over whether or not to eat them. Euro Coop considers that the Commission's proposals on GM feed and food, traceability and labelling are a significant step forward in this respect.
The existing European legislation on Novel Foods and Novel Ingredients, which says that only products in which protein or DNA from modified organisms can be detected must be labelled, undermines consumers' right to know what is in their plate and how it has been produced. Many products, which do contain GM ingredients, are presently not labelled.
We are deeply concerned that many amendments tabled to the Commission's proposals, if adopted, would deeply undermine consumers' right to make informed choices and contribute to further erode their confidence. We therefore invite you to base your vote on the following recommendations:
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Consumer choice requires a labelling system based on full traceability and segregation
Traceability is not a new system. Euro Coop members have been using this management tool for many years, and it has proved to work efficiently to ensure that the products they sell are not genetically modified. Traceability allows them to guarantee the safety of consumers and to ensure a correct labelling of their products (e.g. beef, fish, organic products, products of origin, etc.). It has not led to an increase of food prices, and surveys show that it contributes to increase consumers' confidence.
Limiting the traceability scheme to GM products which include DNA or protein would mean to reject the whole Commission's proposals. Therefore, we invite you to vote:
- Against amendments 4, 5, 10, 11, 14, 15, 31, 34, 35, 54, 55, 57 to 59, 122 tabled to the Commission's proposals on traceability and labelling (Trakatellis Draft Report);
- Against amendments 68, 83 to 86, 90, 94, 116, 191, 194, 196 to 199, 204, 238 to 240, 301, 302 to 306, 309 tabled to the Commission's proposals on GM feed and food (Scheele Draft Report).
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Traceability and labelling should apply to GM derivatives
Euro Coop is very concerned that many amendments aim at limiting the scope of the proposal for a Regulation on traceability and labelling by excluding GM feed and food produced from GMOs. If adopted, these amendments would significantly weaken the proposed Regulation on traceability of GMOs and feed and food produced from GMOs with the objective of facilitating accurate labelling, environmental monitoring and withdrawals of products1.
Therefore, we invite you to vote against BLOCK 1 of amendments tabled to the Commission's proposals on traceability and labelling (Trakatellis Draft Report).
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Consumers should not find unauthorised GMOs in their food
Euro Coop has always claimed that the new EU legislation on GM feed and food, traceability and labelling should only apply to authorised GMOs. As correctly mentioned by several MEPs (see justification of amendments 112 to 114, 118 and 119), the Commission proposes to legalise the presence of unauthorised GMOs in feed and food. This would not increase consumer confidence. We are concerned that some amendments propose to extend the thresholds foreseen to unauthorised GMOs which have been assessed by the European Food Safety Authority or third countries with similar food safety standards. However, we want to stress that there is currently no mutual recognition for authorisation procedures between the EU and third countries.
For these reasons, we invite you to vote:
- For amendments 9, 36, 97, 93, 128, 247, and 331 tabled to the Commission's proposal on GM feed and food (Scheele Draft Report);
- Against amendments 125 to 127, 130 to 132, 249, 250, 252, 253, 332, 333 and 335 tabled to the Commission's proposals on GM feed and food (Scheele Draft Report);
- Against amendments 16, 126, 127 and 128, tabled to the Commission's proposals on traceability and labelling (Trakatellis Draft Report).
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Labelling must be precise and clear
Euro Coop agrees with the Commission that the label should indicate "genetically modified" or "produced from genetically modified organisms", but considers that adding "but not containing a GMO" would mislead consumers. Moreover, Euro Coop is opposed to a GM-free labelling scheme. We strongly believe that it would be highly misleading for consumers to label a product as GM-free if this just means that there is no GM material in the final product, but not that ingredients or derivatives could have been used all along the production chain.
Therefore, we invite you to vote:
- For amendments 33, 34, 35, 60, 68, 216 to 220, 222 to 226, 228 to 230, 232, 235 and 313 to 315 tabled to the Commission's proposal on GM feed and food (Scheele Draft Report);
- Against amendments 89, 104, 105, and 241 tabled to the Commission's proposal on GM feed and food (Scheele Draft Report).
Setting a proper traceability and labelling scheme for GMOs, GM feed and food is key to regain consumer safety and confidence. It is also one of the pre-conditions to resume the approval procedure for new GMO marketing applications. Therefore, we strongly urge you to follow the above recommendations during the vote tomorrow morning, and not to undermine the Commission's proposals.
Please do not hesitate to contact me if you need any questions in respect of our recommendations.
Yours sincerely,
Mrs Aude L'hirondel
Food Policy Officer
e-mail: alhirondel@eurocoop.org
1. Article 1 of the proposed Regulation on concerning traceability and labelling of genetically modified organisms and traceability of food and feed products produced from genetically modified organisms and amending Directive 2001/18/EC 2001/0180 (COD)
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.
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