APPENDIX 5
Memorandum submitted by Consumers in Europe
Group (CEG) (R 5)
THE CONSUMERS IN EUROPE GROUP (CEG) IS AN
INDEPENDENT UK UMBRELLA BODY FOR 34 UK ORGANISATIONS WITH AN INTEREST
IN THE EFFECTS OF EUROPEAN UNION POLICIES AND PROPOSALS ON UK
CONSUMERS
INTRODUCTION
1. As a general comment, CEG is not against
genetic modification in itself, provided it is tightly controlled.
We recognise that this new technology could potentially offer
benefits to consumers. However, consumer confidence in genetic
modification is facing a crucial time as the first GM commodity
crops are used as sources for a wide range of food ingredients.
CEG appreciates that many consumers are concerned about genetic
modification of crops and the foods produced from them, for this
reason we consider segregation of GM crops as a necessary step
to ensure consumer choice.
APPROVAL PROCESS
2. The approval process for GM crops and
GM foods is split between many different scientific committees,
both at UK and EU level. Each committee has a strict remit and
considers each approval on a case-by-case basis. As stated in
the recent Royal Society report, "there is no means for looking
at GM technology as a whole". In particular, there is, as
yet, no committee to look at the wide-ranging impact and ethical
issues surrounding the use of genetically modified crops to produce
food and the effects that they have on the food chain from farm
to consumer. This gap affects issues such as segregation of GM
and non-GM foods and also how labelling schemes could be introduced
and validated through the supply chain.
3. CEG has recommended that the European
Commission and the UK set up overarching committees to consider
the wide-ranging impact of genetic modification on consumers and
the environment. The Government announced in May that it would
set up a new Agriculture and Environment Biotechnology Commission
to cover the use of biotechnology in agriculture and its environmental
effects. This appeared to be a step in the right direction, however
CEG is not aware that this Commission has been established yet.
Also it is not clear how it will bridge the gap between GM crops
and GM foods, which will be the responsibility of the Food Standards
Agency.
SEGREGATION
4. Segregation of GM crops and GM foods
throughout the supply chain is essential to meet consumers' calls
for the clear labelling of GM-produced food and conventionally-produced
food. Even if segregation is not legally required (because of
world trade rules), it should be possible for the food and farming
industry to provide voluntary segregation. CEG is concerned that
the crop from GM maize grown in other Member States may not be
segregated. This will make it far harder to establish a non-GM
line of maize products within the EU, and all EU maize could end
up labelled as GM because of potential cross-contamination during
bulk processing.
5. At present, GM crops are in the minority
but are expected to grow to about two-thirds of the US crop. If
this trend continues then segregation may focus on separating
out the non-GM crop/food and creating an "Identity-Preserved"
source. Conversely, foods that have been genetically modified
to provide a selling-point (such as healthier oil) to the consumer
may also be segregated since they may well be sold at a price
premium.
6. Segregation would need to be accompanied
by detailed records and an audit trail through the supply chain,
in a similar process to that used for organic foods.
7. CEG strongly supports the segregation
of GM and conventional foods throughout the food chain. GM crops
grown in the EU must be segregated from the farm onwards.
LABELLING OF
GM FOODS
8. EU legislation does not require segregation
of GM crops and food, nor does it require the labelling of all
food produced from GM sources. EU law is likely to remain based
on scientific detectability of genetic modification. However,
several food retailers have followed consumer demand to label
GM food more fully than the strict legal requirements and some
manufacturers have re-formulated products to avoid using soya.
9. A consequence of the EU legislation is
that foods produced from GM crops, but which are refined or processed
so that any modified DNA or protein is not detectable, will not
have to be labelled. CEG has serious concerns about the concept
of a "negative list" of such food products. The establishment
of a negative list of products could potentially mislead consumers
because it may give the impression that foods on the list, eg
soya oil, have not been genetically modified. The list must be
based on tests that are accurate, reliable, validated and readily
available to retailers and the food industry at a reasonable cost.
However the tests are under constant development and it is not
clear how the "negative list" will be amended to take
into account new tests or new limits of detection in existing
tests.
10. CEG strongly supports the labelling
of all foods produced from GM sources, based on traceability,
in addition to those foods that are legally required to be labelled.
11. A negative list of GM products which
do not need to be labelled is misleading to consumers.
MAINTENANCE OF
CHOICE
12. Labelling of GM foods is important to
inform consumers when foods have been produced using genetic modification.
As GM crops become more widely grown, and mixed with conventional
produce, then the proportion of food needing a GM label may increase.
Potentially, the majority of products from some crop species may
be labelled as GM.
13. Choice is a basic consumer principle.
A choice between GM and conventionally-grown food must be maintained
for those consumers who do not want to eat GM food. CEG recognises
that this is impractical for every food product on the market.
However, it should be possible for a non-GM alternative to be
made available for each type of product, for example via supermarkets'
own brand labels. There may be practical difficulties in providing
this, but it is not impossible, and customer pressure may demand
it.
14. As the proportion of GM-produced foods
increases, it may become more important to identify non-GM foods
by labelling. As the law stands, if a food is not specifically
labelled as genetically modified then it is still possible that
it has been produced using GM sources but that no changes due
to the modification can be detected. Consumers may prefer to buy
foods labelled "GM-free" or "non-GM". EU law
allows for this type of labelling. Retailers may be reluctant
to make claims for "GM-free" if they think that such
claims may be hard to substantiate, especially if analytical tests
detect small amounts of GM material.
15. In Germany, a national law has been
passed that specifies criteria for food claiming produced "without
genetic engineering". It states that a small amount of accidental
contamination with GM material may be unavoidable, and is acceptable
provided that appropriate proof can be given that the foodstuff
has been produced without the use of GM. For those consumers who
have concerns about the use of GM as a technology, this sort of
labelling based on the production method could be the most suitable.
16. Organic foods could provide an alternative
to some GM foods, although many consumers may not be able to afford
the price premia on organic foods, and organic alternatives are
not available for the wide range of processed food.
17. Consumers must be given a meaningful
choice between food produced using GM sources and food produced
using conventional methods. Labelling must clearly distinguish
GM food from non-GM food; it must be possible to verify labelling
claims. Organic food should not be the only alternative to GM
foods.
4 October 1999
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