APPENDIX 4
Memorandum submitted by Consumers' Association
(R 4)
INTRODUCTION
1. Consumers' Association (CA), publishers
of Which?, Health Which? and other consumer books and magazines,
is an independent consumer organisation with over 700,000 members.
2. We have carefully monitored the introduction
of genetically modified (GM) foods on to the UK market over several
years and have conducted consumer research, including surveys
and focus groups, to assess consumer attitudes in line with developments.
While we do not therefore have practical experience of implementing
systems to segregate GM foods, our research assessing consumer
attitudes towards GM may assist the Committee with its Inquiry.
CONSUMER RESEARCH
3. Our research has repeatedly shown that
consumers feel very strongly about GM for a variety of reasons.
Some are concerned about the long-term consequences of GM. Others,
for example, are concerned from an ethical point of view. People
therefore feel strongly that they should be able to choose whether
or not to eat GM. Crucial to this is effective labelling of foods
and ingredients produced using GM. But for choice to be effective,
it also needs to be ensured that alternatives to GM are available.
This is one of the reasons why segregation is so important.
4. Consumers see GM in terms of the process
rather than the final product which is at odds with the approach
that has been taken by EU legislation. A CA survey in February
1999[1]
found that:
— 90 per cent of respondents had heard
of genetic modification;
— of these, 94 per cent felt that there
should be clear labelling on food packaging;
— 92 per cent agreed that food ingredients
that come from a GM plant, but which cannot be detected in the
final product because they have been processed should be labelled;
and
— 76 per cent wanted to know about
GM when eating out.
We are currently carrying out further qualitative
consumer research and will be able to provide the Committee with
the results at a later stage.
TRACEABILITY
5. To meet these requirements, labelling
must be based on traceability throughout the food chain, so that
manufacturers, retailers and caterers know what they are using
in their products and can give consumers clear information based
on this. More generally, traceability is also important for reasons
of safety. As we have repeatedly seen, for example with BSE, E
coli and more recently dioxin contamination, traceability
is essential for ensuring food safety and is an important aspect
of any Hazard Analysis Critical Control Point (HACCP) approach.
Many uncertainties still remain in relation to GM. We are not
satisfied that there are adequate safeguards in place at the moment,
that the approval process is rigorous enough or that there has
been enough research into the long-term implications of GM. If
a problem were to be identified in the future, it would be important
to ensure that all potentially affected products could be withdrawn
from the market and that consumers could be given clear information
about any potentially affected products. To do this, we need to
know where ingredients are going and therefore GM crops need to
be segregated. Similarly, if we are to monitor the long-term implications
of GM on our health—something that the government has acknowledged
as important and instructed the Advisory Committee on Novel Foods
and Processes (ACNFP) to consider—we need to know where
ingredients are going, and therefore need to ensure segregation
at source.
6. The current labelling regulations are
based on whether or not GM DNA or protein can be detected in the
final product and therefore the product is "no longer equivalent"
to an existing product. Using testing of the final product as
the basis for labelling is an inadequate basis for regulation
on several grounds. It excludes some ingredients which consumers
clearly want to know about, such as soya lecithin and soya oil.
Labelling requirements are also likely to change as test methods
become more sensitive.
IDENTITY PRESERVATION
7. CA has therefore supported an approach
based on identity preservation (IP) throughout the food chain,
beginning with the seed producers and following it right the way
through until purchase. We consider this to be the most effective
way to ensure that consumers can be given clear information about
the presence or absence of GM. It is also consistent with ensuring
a HACCP approach more generally. We do not however see identity
preservation as a way of allowing GM-free claims to be made on
products. There is always the danger that there could be accidental
contamination at some point in the chain, although this can be
minimised. "GM-free" also suggests that the technology
has not been used in any way, and so it would need to be ensured
that no GM animal feed or processing aids, for example had been
used. It is highly unlikely that a product could fulfil these
criteria. We therefore see IP relating to those products that
carry no label or claims.
8. We have called for this type of approach
based on clear segregation of GM and non-GM supplies since the
problem of commodity crops first emerged. Initially we were told
that this was impossible to achieve and therefore unrealistic.
It was suggested that consumers would have to pay a price premium
for segregated supplies of non-GM soya or maize. However, this
has not been the case in practice. This year it has become clear
that non-GM supplies are becoming available to meet the clear
demand in Europe, and that this can be achieved without increasing
the price of foods to consumers. As manufacturers, retailers and
caterers continue to work together to secure supplies, more are
likely to become available making controls easier and ensuring
that there are no additional costs.
9. The approach that is needed, and is being
implemented in many cases, involves ensuring segregation at all
stages of the chain and ensuring that there are mechanisms in
place to verify this. This involves the use of testing at critical
control points and also independent inspection to ensure that
the necessary measures are being complied with.
THRESHOLDS
10. One important issue in this respect
is that of thresholds: at what level should accidental contamination
be permitted? From a consumer point of view, if you are buying
something that does not say that it contains GM ingredients, it
is reasonable to assume that none are present. However the complexities
of the distribution chain make this more difficult in practice.
Any threshold would need to be set as low as can be practically
ensured. We understand that 0.1 per cent can, for example, be
achieved. There is however the danger that once a threshold is
set, there will be no incentive to strive to reduce levels beyond
this point—and therefore the industry may work within this
threshold. It may therefore be appropriate to phase out a threshold
as more non-GM supplies become available, and experience results
in more effective controls at all stages along the line. In addition,
we have welcomed efforts by some retailers to segregate animal
feed and ensure that their meat is not reared on GM feed, in line
with their general policy of removing GM ingredients. Ultimately,
we would hope that this could also be extended to include GM processing
aids.
INDUSTRY-WIDE
STANDARD
11. Although efforts in this direction have
been very welcome and have ensured that consumers can choose whether
or not to consume GM, we consider it necessary to establish an
industry-wide standard. This would ensure that where consumers
saw products that were not labelled as "GM", they could
expect them to mean the same thing ie that they had been produced
to a standard that ensured that GM contamination had been kept
to an absolute minimum. We hope that industry and the Government
will work together to develop such a scheme. It is also important
that this approach is reflected within European legislation which
at the moment is failing to keep pace with market developments
and practicalities.
12. Although the crops that are causing
most concern at the moment are soya and maize which are not grown
in the UK, it is likely that other crops may come onto the market,
some of which may actually be grown in this country. This will
present new problems of possible cross-contamination that need
to be addressed as soon as possible. While no crops are being
grown commercially at the moment, we are concerned that the farm
scale trials currently taking place could result in cross-contamination
if adequate controls are not ensured. This has raised particular
concerns for organic farmers who have to make sure that GM is
not used in their products. Clear guidance will be necessary on
appropriate separation distances—and how these can be enforced—before
crops are grown commercially in the UK. Similarly, it should also
be ensured that any crops grown in the rest of Europe are effectively
segregated.
8 October 1999
1 1,914 people aged over 15 who were representative
of the population were interviewed face to face in their homes
between 19 and 25 February 1999. Back
| 
