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Brussels, 26/02/2002
The Commission's proposals on GM feed and food, and traceability and labelling must be improved, rather than undermined
In light of the current international and European debate on the Commission's proposals on GM feed and food, and on traceability and labelling , Euro Coop calls on the European Parliament and the Council to take appropriate measures to ensure consumers safety and consumers right to make informed choices. We stress that the Commission's proposals need to be improved, rather than undermined.
The recent discussions held at the EP's Environment and Agriculture Committees have shown that the Commission's proposals are considered by some actors of the food chain as "unworkable" and costly. Euro Coop has always claimed that all GM foods should be subject to a rigorous mandatory approval process and that all GM derived foods and ingredients should be labelled so that consumers have a choice over whether or not to eat them. We consider that the Commission's proposals are a significant step forward in this respect, but that they should be strengthened. We ask the EU institutions to consider the following points:
- Euro Coop welcomes the establishment of a centralised authorisation system
Euro Coop welcomes the introduction of an authorisation system addressing both GM feed and food. Under the existing EU legislation, feeds which contain live GMOs must be authorised under Directive 2001/18/EC on the deliberate release of GMOs in the environment. However, there is a legal gap concerning processed GM feed, such as maize gluten, as it does not fall within the scope of Directive 2001/18/EC, neither within the scope of the EU legislation on Novel Foods. The proposed EU legislation will therefore address this legal gap.
Euro Coop also supports the dual-use clause which requires a GM product to be approved as food and feed where it is likely to be used for this purpose . Furthermore, we welcome that the authorisation procedure applies also for GM feed and food "substantially equivalent" to conventional products. We are pleased to see that the Commission recognises that substantial equivalence is not a safety assessment in itself. The abandon of the fast-track notification procedure should ensure that no new "Starlink scandals" would occur in the future.
We believe that it would be a useful precaution to institute a formal review process in the early years of development of GM technology. There is so much concern about the long-term impact of its use, particularly on human health and the environment. Setting a date for review would ensure such concerns were assessed. The Commission's proposal on GM feed and food states that approvals should be limited to 10 years. We question whether 5 years would be more appropriate.
Finally, the Commission's proposal gives the European Food Safety Authority all the responsibility for the risk assessment. We insist that the risk assessment process should be publicly available. Notifications and assessments should be published on the Internet.
- Euro Coop believes that the labelling of GM-foodstuffs must be based on full traceability and Identity Preserved Supplies
Euro Coop has always strongly called for a labelling of GM food based on full traceability and segregation. The existing European legislation on Novel Food and Novel Ingredients does not allow consumer to make informed choices. Therefore, we welcome the Commission's proposal to label all products "produced from GMOs" , and to closely link the traceability and labelling proposals. We agree that all products produced with GM ingredients must be labelled as containing GMOs, even if the final product is similar to a product produced without GMOs, or if no trace of GM material can be detected in the final product.
Finally, 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 not be meaningful for consumers.
- Euro Coop is concerned that there should be no tolerance for non-approved GM material
Euro Coop accepts that it is necessary to set thresholds for adventitious contamination. We agree with the 1% recommended by the Commission, but we recommend that tolerance levels for GM seeds contamination, which are currently developed by the Commission Services of DG SanCo, should be strictly set in order to meet this requirement. The expression "adventitious contamination" should also be defined.
Our approach differs regarding the 1% thresholds for adventitious contamination of non-authorised GM material. The Commission's proposal states that the 1% tolerance level applies to GMOs that have been positively assessed by Scientific Committees, even if those GMOs have not been approved by the Commission yet. We consider that this proposal potentially compromises consumer safety and confidence in the Regulations. The 1% tolerance level should not apply until the Commission has approved GMOs.
- Euro Coop welcomes the establishment of a traceability scheme, but considers that it should be strengthened
Euro Coop strongly supports the development of systems of traceability for GMOs, GM foods and feed and the proposed development of unique means of identifying particular GMOs. We agree that GM food and feed should be accompanied by detailed records so that an audit trail can be established throughout the supply chain.
We believe the proposed Regulation on GMOs traceability is a good step towards the implementation of the traceability requirements of the General Food Law Regulation. However, Euro Coop is concerned that the development of many and diverse European traceability systems (e.g. for beef products, GM foodstuffs, etc…) would hamper the consistency and coherency of the EU legislation. We therefore ask for the development of a single traceability system for all food products, which could be based on the functioning of the ISO system. This would simplify the current situation and lead to a better monitoring.
Euro Coop believes that traceability is essential for ensuring that there can be effective product recalls if a safety or quality problem emerges. We want to underline that a risk assessment can never be a complete assurance of their safety as science is continuously evolving. Traceability would help to ensure that there could be monitoring of the longer-term implications of products post-marketing and also enable them to be removed from the market if necessary. Traceability also has the added benefit of enabling claims about products and their potential benefits to be monitored where necessary to ensure that consumers are not being misled.
However, we consider that the proposal on traceability should be strengthened. We ask the EU institutions to consider the following specific points:
- We are concerned that different requirements would apply to live GMOs and products produced from GMOs. According to Article 5 of the proposed Regulation on traceability, the relevant unique code(s) should not be indicated on products produced from GMOs. We feel that it would undermine the potential effective of the EU legislation, which main objectives is to facilitate withdrawals of harmful products.
- We agree that guidance on sampling and detection should be developed in order to facilitate a co-ordinated approach for control and inspection, and provide legal certainty for operators. We ask the Commission to develop them urgently.
- Where labelling is not possible, for instance in the case of products that are not packaged, this information should still be provided. Guidance should be provided to clarify the form in which the supporting documentation should be made available.
- We ask the Commission to promptly establish the system for development and assignment of unique codes as the proposal states that they must be in place before the traceability requirements apply. We also wish to stress that it is important to establish a comparable traceability system for imported products from outside Europe.
- As indicated in our position paper on the general principles of food law and on hygiene, Euro Coop believes that all stakeholders involved in the food chain should be responsible for traceability at his own level only, rather than a requirement to trace back through the entire chain.
- Euro Coop considers that the new traceability requirements must apply to GM products that have already been authorised - under the existing EU legislation.
- Appropriate measures should be taken to achieve segregation and transmission of information in the context and sources of bulk supplies in order to avoid cross-contamination and the presence of a number of different GM sources.
Aude L'hirondel, Food Officer
Tel: +32.2.285.00.70 - Fax: +32.2.231.07.57 E-mail: alh@eurocoop.org
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