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Brussels, 16 november 2001
Euro Coop asks for the full implementation of consumer right
to know and to choose
Euro Coop is the European Community of Consumer Co-operatives, whose members are the national organisations of consumer co-operatives in 11 of the 15 Member States of the EU and in 4 Central and Eastern European countries. Created in 1957, Euro Coop today represents over 3,200 local or regional co-operatives, membership of which amounts to over 19 million consumers in the EU and 2 million in the associated countries of Central and Eastern Europe. Euro Coop's major objectives are to promote, defend and represent consumer interests at European level.
It is on the basis of this expertise that Euro Coop has prepared the following comments on the recent Commission's proposal on the indication of the ingredients present in foodstuffs.
Euro Coop welcomes the Commission's proposal for an amendment to the food labelling Directive 2000/13/EC, which is intended to remove the possibility not to label the components of coumpound ingredients forming less than 25% of the final product and to lay down a list of allergens which will appear on the labelling of foodstuffs.
Euro Coop has always strongly argued for the abolition of the "25% rule" on coumpound ingredients , which does not allow consumers to be fully informed of the content of the food they purchase and eat. We have also always called for an appropriate labelling of allergens, which can cause severe health problems for consumers that suffer from allergies or intolerances to certain substances .
Euro Coop considers that the Commission's proposal consists of an important step towards better consumers' information and safety. However, we are very concerned that the Commission's proposal contains several exemptions that would impede the full implementation of consumers' right to make informed choices. The following comments explain more fully Euro Coop's position concerning the Commission's proposal for an amendment of the food labelling Directive as regards the indication of ingredients.
- Euro Coop supports the abolition of the "25% rule" but believes that the proposed exemptions could impede the scope of the reform
Euro Coop welcomes the Commission's initiative to change the current EU legislation on the labelling of components of coumpound ingredients and allergens. Considering the need for consumers to have a complete listing of food ingredients, most Euro Coop members have already gone beyond the "25% rule" and adopted a "0% rule" for some time.
However, Euro Coop is very concerned that the proposal contains exemptions that could impede the scope of the reform. We are in particular worried that the proposal states that the complete listing of compound ingredients should not be required where the composition of the compound ingredient is defined in current Community legislation (i.e. chocolate, fruit jams, chesnut purée) and constitutes less than 5% of the finished products.
This exemption will not allow consumers to make informed choices. Most European consumers do not know the exact composition of the coumpound ingredients that already defined in the current EU legislation. For example, even they usually know that cocoa butter is the main substance contained in the chocolate, they are not always informed of other substances used (i.e. vegetable fats). The other problem is that the current Community legislation does not always apply to all foodstuffs. For example, the future Directive on fruit jams, jellies, marmalades and chestnut purée states will not apply to products intended for the manufacture of fine bakery products, pastries, biscuits, nor to fruit preparations intended for use in dairy products .
We also do not agree that exemptions should be planned for preparation of sauces or mustards constituting less than 5% of the finished product.
In July 2000, the Commission Services in charge of Food Legislation and Biotechnology circulated a discussion note on the "25 % rule" and the labelling of allergens, which proposed the two following options: abolition of the 25% rule or reduction to 5%. The Commission services in charge of the dossier indicated at the time that the abolition of the "25% rule" was their preferred option, without specifying that exemptions should be planned. We are disappointed to see that the initial position of the Commission services has been weakened in order to reach a compromise between the two options.
Euro Coop asks the European Commission, the European Parliament and the European Council to fully implement the principle of abolishing the 25% rule, and not to allow exemptions that could impede scope of the reform. We believe that only the labelling of all ingredients will ensure consumers to make informed choices.
- Euro Coop calls for an exhaustive, but simplified, ingredient listing
Euro Coop believes that the way ingredients are listed should be changed with a view to naming everything, but only once. Euro-Coop position calls on the Commission to review ingredient listing to ensure all ingredients used are named, to avoid duplication, and to make lists more transparent.
- Euro Coop welcomes the Commission's initiative to lay down a list of allergens
Euro Coop has always strongly argued that labelling must enable consumers to avoid foodstuffs containing substances to which they are allergic or intolerant. Consumers are facing more and more public health problems due to substances they are allergic to, and that they cannot avoid because they are not correctly labelled.
- Euro Coop welcomes the Commission's initiative to lay down a list of allergens, which will appear on the labelling of foodstuffs. We agree with the proposed list. However, we believe that the list should be updated when there is a new and serious allergen.
Euro Coop particularly welcomes the requirement to label sulphites used in alcoholic drinks. Some Euro Coop members actually go further this labelling as they do additionally label all ingredients contained in the wine.
- Regarding the way allergens should be labelled, Euro Coop believes that allergens should be labelled in the ordinary list of ingredients.
- Regarding products sold loose (such as slices of cheese or meat that are not pre-packed, which consumers can purchase from a counter in a supermarket), labelling rules allow Member States to decide whether rules should be extended to products sold without packaging and in catering. Euro Coop believes that allergens should be listed on these too.
- Euro Coop calls on the Commission to tackle the issue of contamination
The important issue of accidental contamination/presence of trace levels of allergens is not tackled by the Commission's proposal. We stress that hygiene practices should be improved in order to avoid accidental contamination of allergens in foodstuffs.
Aude L'hirondel, Food Officer
Tel: +32.2.285.00.70 - Fax: +32.2.231.07.57 E-mail: info@eurocoop.org
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