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Bruxelles, le 21 janvier 1999
EURO COOP's comments on the Precautionary Principle
Euro Coop, the European Community of Consumer Co-operatives welcomes the guidelines prepared by DGXXIV on the application of the precautionary principle and looks forward to receiving a further document which sets out the mechanisms for operating the precautionary principle.
Comments on the principles in the guidelines' summary:
- Euro Coop agrees that implementation of an approach based on the precautionary principle should start with an objective risk assessment, identifying at each stage the degree of scientific uncertainty. In that respect, we applaud the new approach of the Commission on "consumer health and food safety (Commission Communication dated 30/04/1997), in particular with respect to the reorganisation of the Scientific Committees'' work, to the risk analysis, and the scientific advice.
- Euro Coop agrees that all stakeholders should be involved in the decision to study the various management options. We must stress that consumers must be considered as major stakeholders. However, we also stress that, for consumers to be able to act effectively as stakeholders, information and options must be clear and understandable to non-specialists and that consumers' non-scientific perceptions must be taken seriously into account.
- Euro Coop agrees that the principle for measures based on the precautionary principle must be proportionate to the risk, which is to be limited or eliminated. However, we do recognise the fact that certain risks never can be totally eliminated (for instance pathogens). In these cases the goal must be to control the risks as far as is possible and to ensure traceability.
- Euro Coop agrees that measures based on the precautionary principle must include a cost/benefit assessment. We consider that this should assess the costs and the benefits to all stakeholders and particularly consumers. However we are not convinced that it will be possible, on every occasion, to achieve a situation where all stakeholders accept the level to which risk is reduced. What would happen if one stakeholder disagrees? What would be the mechanism for dealing with this? We are not convinced that it will always be possible to use consensus in order to determine what action to take following the application of the principle. We consider that there will be occasions on which an executive/political decision will have to be taken.
- Euro Coop agrees that measures based on the precautionary principle must establish responsibility as to who must furnish the scientific proof needed for a full risk assessment. We take the view that the reversal of the burden of proof should apply, on a case-by-case basis, by shifting responsibility for furnishing the scientific evidence.
- Euro Coop accepts that measures based on the precautionary principle must always be of a provisional nature, pending the results of scientific research performed to furnish the missing data and performance of a more objective risk assessment.
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