APPENDIX 8
Memorandum submitted by the Food and Drink
Federation (R 10)
This is in response to the invitation to comment
on the segregation of GM foods as announced in Agricultural Committee
Press Notice No 23 of 30 July.
FDF as such has no direct expertise in the practicalities
of the segregation of GM crops on farm, in storage, or in transit.
Such expertise will reside, inter alia, with the companies
identified in the MAFF website list of suppliers offering non-GM
material.
FDF wishes to draw attention to the importance
of ensuring the sourcing of identity preserved (I-P) non-GM (ie
conventional) ingredients as a basis both for satisfying consumer
demand for non-GM products and of ensuring sufficient legal certainty
for companies in not GM-labelling such products.
The background of difficulty in controlling
the co-mingling of GM soya, and to a lesser extent GM maize, due
to unsegregated supplies, principally from the USA, is well known.
In view of the scale and complexity, particularly of the production
and transportation of GM soya, and the relatively small amount
required for production of derivatives for the UK food and drink
manufacturing industry, it was held by suppliers that segregation
would not be possible other than at very substantially increased
prices. For many manufacturers, the response has been to remove,
where possible, derivatives of soya and maize from products. This
is not, however, a satisfactory, long-term answer overall.
EC Regulation 1139/98, on GM soya and maize
labelling, requires labelling where GM material (protein or DNA)
is present in the final food; the absence of GM material from
products of GM origin thereby removing the need to label. There
is substantial customer demand, however, that GM labelling be
applied to all products of GM origin, whether or not GM
material is present. Accordingly, the only route to the supply
of non-GM products to these requirements is the secure sourcing
of identity-preserved, conventional material.
It is, therefore, a current priority amongst
both manufacturers and retailers to agree a best practice standard
for the supply of I-P soya and maize, demonstrable compliance
with which could be the basis of not GM labelling products. The
objective of such a scheme is to minimise any adventitious presence
of GM materials by the monitoring of all key points from which
such presence might arise. The approach might best be described
as a "target-zero, due diligence" approach where zero
presence of GM material is the target but demonstrable compliance
with the system would provide a due diligence defence if a low
level of GM material was found to be present in non GM-labelled
products, the relevant ingredients of which have been so sourced.
With the passage of time, and an increasing
demand for conventional materials, there is an evident increase
in ability or preparedness of growers to supply conventional materials.
It is hoped that increasing demand will result in an economically
viable supply of conventional materials identity-preserved to
an agreed standard.
8 October 1999
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