Select Committee on European Communities Second Report - Written Evidence

Memorandum by the Provision Trade Federation


  1.1 PTF members are companies of all sizes involved in supplying bacon and ham; chilled and processed meats; dairy products of all kinds, including milk powders, cheese, butter, yogurt and other dairy desserts; and canned foods. Our members include importers and exporters of these products as well as companies who produce and trade in the UK. The combined turnover of our membership in relation to these products is in the region of £4 billion.

  1.2 Those of our members with a current interest in genetic modification are producers and importers of certain meat products and certain dairy desserts which may contain ingredients derived from soya or to a lesser extent, maize, and producers and importers of cheese manufactured using vegetarian chymosin. However, we are conscious that future developments in this field might open up new opportunities for our members. It is therefore important that current legislation should not set precedents which will create barriers to future progress.

  1.3 As we represent the trading interests of our members we are not qualified to comment on aspects to do with research and release into the environment of novel foods. Our comments are confined to issues to do with labelling and its regulation.


  2.1 We support the principle of "equivalence" laid down in EC Regulation 258/97 on novel foods and novel food ingredients under which novel foods which are equivalent to conventional products do not need to be labelled. However, the issue has been confused by the subsequent adoption of Council Regulation 1139/98 (compulsory indication of labelling of certain foodstuffs produced from genetically modified organisms) which introduces a stricter interpretation of the meaning of "substantial equivalence". This implies that the presence of protein or DNA from GM material in a product will require the product to be labelled.

  2.2 A possible consequence of this measure will be to deter industry from using certain processes or products which might introduce even very small traces of genetically modified material into a final food. This is exemplified by actions being taken by certain companies to replace ingredients originating from soya because the costs of monitoring for, and ensuring the absence of, genetically modified protein or DNA could outweigh the costs of changing to another ingredient which performs the same function and where there is currently no danger of contamination by GM material. If this were to take place on a large scale it could reduce the incentive for the development of new products using GM technology.

  2.3 In the case of imports, monitoring GM "contamination" of certain products or ingredients could be necessary in order to provide the importer with a due diligence defence in the event of a challenge by enforcement authorities.

  2.4 Another way of avoiding costs of monitoring could be to label all products containing soya derivatives, as it could be argued that it is not possible to guarantee that GM contamination at very low levels will not occur on occasions. It would be unreasonable to expect every batch to be monitored for GM material and labelled only when it is found.

  2.5 While some would argue that it might ease the situation by having a threshold within which GM material would not have to be labelled, this could represent a moving target if the occurrence of GM crops increased and made it more difficult to obtain raw material for which there would be confidence that the given threshold will not be exceeded on certain occasions.

11 June 1998

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