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
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. REGULATION OF
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