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Position Papers
EURO COOP Letter... PDF Brussels, 15 March 2006


Vote on Nutrition & Health Claims Proposal
- 21 March 2006

Dear Member of the European Parliament,

  I am writing with reference to the proposed Regulation on Nutrition & Health Claims (COM (2003) 424). As you know, many of your colleagues on the ENVI Committee have tabled amendments to this proposal in advance of the voting session scheduled for 21 March 2006.

  As a Member of the ENVI Committee you are certainly aware of the political importance that a large number of European stakeholders attach to this legislative dossier.

  Since the publication of the proposal in July 2003 EURO COOP - the European Community of Consumer Co-operatives - has been actively contributing to the related EU legislative debate. As a recognized European stakeholder, EURO COOP has been consulted by the competent Commission services in the preparatory stage of the proposal as well as in its subsequent developments.

  I should like to take this opportunity to draw your attention to those elements of the proposal that are priorities for EURO COOP member organisations across Europe.

  Firstly, Article 4: EURO COOP has always called for the inclusion of nutrient profiles as a pre-requisite to making a claim on foods. We firmly believe that in order to provide consumers with truthful and unambiguous information only foods with desirable nutrient profiles should be allowed to bear nutrition and health claims.

  In this respect, EURO COOP congratulates the Commission and the Council for agreeing on this point a text which looks satisfactory from a consumer protection perspective. Unlikely, EURO COOP does not support the solution put forward by some of your colleagues whereby a claim on a food not meeting a desirable nutrient profile can be allowed provided that the nutrient exceeding the profiling is indicated on the front-of-pack or nutrition information is given on the back. In EURO COOP's view, this solution would risk conveying contradictory and unclear messages to buyers and, in so doing, it would undermine the rationale behind the proposal.

  Secondly, Article 15: EURO COOP has always been in favour of an authorisation system as far as the approval procedure for health claims is concerned. Also on this point, EURO COOP congratulates on the Member States and the Commission for firmly supporting this solution. Indeed, an authorisation system would entail that any health claim should be subject to a thorough scientific evaluation before the product to which is related is marketed. In other terms, an authorisation system would prevent buyers from being exposed to non-evidence based health claims. EURO COOP, therefore, does not support other proposed solutions that are not able to ensure the same level of consumer protection, namely the notification procedure and the pre-marketing notification.

  In the light of the views expressed above, EURO COOP would ask you to vote against all the amendments tabled to Articles 4, 13, 14 and 15.

  We hope that you will take on board our concerns.

  Thank you for your time and attention in this important matter.

  Yours sincerely,

CONTACT PERSON
Francesco Montanari, Food Policy Officer
Tel: + 32 2 285.00.74 - Fax: +32 2 231.07.57
E-mail: Fmontanari@eurocoop.coop or info@eurocoop.coop