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Brussels, 26 April 2000
Euro Coop comments on the establishment of a European Food Authority
Euro Coop, the European Community of Consumer Co-operatives welcomes the package of food safety-related measures presented by the European Commission, and in particular:
- the proposal for a European Food Authority and the review of the European scientific committees;
- the reorganisation of food policy into one Directorate-General, the DG responsible for Health and Consumers;
- the legislative programme set out in the White Paper on Food Safety.
Euro Coop believes that this package of measures should deliver a more coherent and more effective food policy. Consumer safety should therefore be improved. If that happens then consumer confidence will follow. That should be the order of events. The Commission should be driven by the imperatives of consumer safety not of consumer confidence.
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 expertise that Euro Coop has prepared the following comments on the recent European move related to food safety.
EuroCoop believes that there is a need for a European Food Authority but considers that the Authority must have a specific role and a clear remit.
The Authority's role should be to evaluate scientific evidence and to offer independent scientific advice. It should be focussed on risk assessment. It should operate with independence and transparency.
Euro Coop agrees that risk management should be retained within the main body of the Commission for the reasons set out in paragraph 33 of the Commission White Paper on food safety: democratic accountability; control; Treaty obligations. It is for the Commission to propose to the Council and the Parliament the measures necessary to manage risk, not for the Food Authority.
Euro Coop stresses that there should be a very active involvement of all stakeholders, and particularly consumers, in the decision-making, which forms part of risk management. The stakeholders should have a clearly defined, and valued, role in assessing relative risks, reviewing the balance of probabilities, and applying the precautionary principle.
Euro Coop agrees that risk communication should not consist of the passive mediation of information, but should be based upon interaction and involvement of all affected parties in a dialogue. However, this presupposes that all parties are identified and affected, and that all communication is based on a customer/consumer perspective. The role of consumer co-operatives is also important in this communication, not least because we are close to the consumers.
The remit of the Authority must be set out clearly and unequivocally.
Euro Coop welcomes the proposal in paragraph 45 of the White Paper that the Authority should cover the whole of the food chain from farm to fork, safety and nutrition. It should also cover other areas such as animal health and welfare, or risk assessments in the environmental and chemical sectors. However we underlines that the role and duties of the Authority in relation to these areas must be defined.
Careful consideration must be given to the working methods of the Authority.
The Authority should be small in size so as to maintain its focus, and so as to minimise the lines of internal communication and the burdens of internal administration.
Euro Coop agrees (paragraph 36 of the White Paper) that the Authority should be able to make flexible and rapid responses. We are not therefore convinced of the suitability of the structure proposed by Professors James, Kemper and Pascal in Figure 7.1 (p.46) of their report on The future of scientific advice in the EU (December 1999).
We consider that the scientific committees should be the core of the Authority.
The work of the Authority should include :
- providing advice in international disputes such as the hormones in meat issue,
- responding to emergencies such as dioxins in meat and dairy products,
- identifying emerging issues in Europe and world-wide such as viruses in food,
- co-ordinating reviews of scientific evidence for legislative or surveillance reasons (as happens through the SCOOP programme),
- evaluating individual substances.
Euro Coop stresses that the opportunities and procedures for suggesting work to the Authority must be set out. Indeed, it is clear that stakeholders will often be in a very good position to, for instance, flag up emerging issues and will then want to suggest work to the Authority.
Two major developments will be essential: strategic planning for the scientific committees' work; and adequate staffing and resources.
Euro Coop considers that the Authority must ensure that each committee allocates appropriate amounts of time to the different areas of the Authority's work. It is not at all satisfactory to read (paragraph 25) that many of the committees' 256 opinions since reorganisation have been evaluations of individual substances. An established five year rolling programme would go far to avoiding the criticisms of the current operation of the committees which are that they are not proactive enough, that they are not able to react quickly enough to crises, that their reports take too long to produce.
Such a programme would require very effective back-up particularly in support staff. Scientists appointed for their eminence and with full-time posts elsewhere cannot be expected to give extensive amounts of time to attending Authority meetings. The support staff will not necessarily be scientists. There would clearly be a need for statisticians for example.
Finally, while the work of the scientific committees should be wholly separate from the regulatory process, day to day scientific advice must be available to Commission officials when they need it, ie when they are in the process of drafting proposals. The fact that scientific advice should be independent does not also mean that it must be inaccessible.
The Authority should have a duty of transparency. Euro Coop agrees (paragraph 43) that the Authority's findings and recommendations should be available, as should the processes followed in order to reach them. We agree that the work programme should be widely available. We feel strongly however that the Authority should be required to write all of this information in a way that is readily understandable by lay people. True transparency has more to do with intelligibility than availability.
The reorganisation of food policy into Directorate General SanCo
Euro Coop very much welcome the reorganisation of food policy into one Directorate General, that responsible for Health and Consumers Protection. Indeed we have been calling for the co-ordination of EU food policy for a number of years.
However, Euro Coop is very disappointed that some dossiers, in particular those with labelling components, remain with other DGs notably DG Agriculture. There have been long-standing problems where consumer labelling issues have been determined with the needs of the industry in mind rather than the needs of consumers. We feel strongly that DG SanCo should have the responsibility for all labelling provisions so as to ensure a coherent labelling policy clearly focussed on the needs of consumers rather than those of industry.
The Commission's legislative action plan
Euro Coop welcomes the Commission legislative action plan as an agenda for food policy work over the next few years.
However it is extremely ambitious in its scope and in its time-scale. We have doubts about whether the Parliament, the Council and the Commission will be able to handle this quantity of work, and whether they have enough resources to guarantee adherence to the timetable.
The major omission from the White Paper is a review of food labelling. This was promised in the Green Paper on EU food policy but there is now only a reference in paragraph 100 of the White paper to the "on-going codification of the Labelling Directive". There can be no excuse for omitting this matter from the White Paper. Indeed, Euro Coop considers that clear and understandable labelling is one of the key planks in securing consumer safety.
In conclusion, Euro Coop considers this reorganisation as a very good start in principle, but stresses that this should lead to appropriate weight given to consumer views in practice and to a food legislation effectively examined from a consumer point of view.
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