Select Committee on European Communities Second Report - Written Evidence

Further Supplementary Memorandum by United Biscuits (UK) Limited


  United Biscuits (UB) has already provided significant input to the Committee.

  In July 1998, the company presented a written submission detailing its views relating to the important issue of genetic modification (GM) in agriculture.

  Subsequently, on October 14, 1998, at the request of the Committee, the company attended a meeting of the Committee to answer a series of questions put by Members.

  During that presentation, Lord Jopling was particularly interested in the consultation undertaken with food manufacturers by bio-sciences companies prior to the introduction of advances such as the genetic modification of crops.

  UB indicated its support of bio-sciences companies in the development of this technology, however, it did object strongly when advances were imposed without due consultation and the opportunity for a reasonable period of scientific review.

  UB pointed out that it felt its views had been "trampled upon" by the fact that its opinions had not been sought in advance of introduction of co-mingled GM crop to the UK and Continental Europe. This phrase was not meant to convey an accusation of systematic cavalier treatment by bio-sciences companies, so much as a cry of frustration over the way in which these particular GM crops were introduced.

  Lord Jopling asked that UB consider providing additional details in respect of the lack of consultation and this supplementary submission is UB's considered response to that request.


  As was pointed out in our October 14 presentation, consumer anxiety arises when food manufacturers have insufficient time to consider new developments and to plan their introduction.

  This is always true, but it is especially important when there are aspects of advances which are potentially controversial or which, through lack of information, can tend to cause anxiety among our customers and consumers.

  Moreover, as was indicated by us, the "forge-ahead-at-all-costs" approach invariably results in increased costs for manufacturers.

  This has certainly proven to be the case for United Biscuits as the company has:

    —  despatched buyers to many parts of the world to source traditional/traceable crops;

    —  paid a premium for traceable/traditional crops;

    —  met the costs of extensive additional testing of crops and final products;

    —  incurred significant additional labelling costs;

    —  devoted much time of many senior executives to the issue.

  Additionally, this approach works against providing consumers with choice if manufacturers through no fault of their own, cannot meet customer expectation. Despite strenuous efforts to source traceable traditional crop—only to find that there is trace presence of GM material, the dilemma is clearly whether or not to label. If the approach is to label, this would result in blanket labelling and offer consumers no choice.

  Due consultation before the introduction of these new crops would have resulted, UB believes, in less consumer anxiety, less expense and consumer choice. The process of introduction could, and should, have been handled more slowly so as to generate greater confidence and more ready acceptance.


  While this has been a frustrating and unsatisfactory period UB believes that there can be a positive outcome if lessons are learnt.

  In future, United Biscuits would like to see:

    —  A period of consultation with all relevant parties—prior to commercialisation of GM in the case of crops or marketing of the product.

    —  An opportunity to review existing science and to influence new research to underpin the introduction of GM foods during the above consultation period.

    —  Communication of consumer benefits flowing from the new advance.

    —  Traceability, if needed, is confirmed.

    —  All regulatory issues in Europe, including labelling, must be clear, before commercialisation of GM materials.

    —  Greater clarity of principle and setting of threshold levels, where appropriate.

    —  Scientifically accurate and up to date information to be developed and a communication programme informing consumers, opinion formers and the media to be undertaken in advance of introduction of GM materials.

  It is United Biscuits' view that if a more orderly and patient approach were adopted, the likelihood of consumer acceptance would be maximised and food manufacturers would not be placed in the difficult position of having to go to considerable expense and effort in order to supply their customers and consumers in the way they wish.

  UB supports the Government's announcement to establish a new Ministerial Group which will oversee strict monitoring of first commercial plantings of GM crops. Managed development of GM crops prior to commercialisation, will we believe help allay concerns and ensure that advances in the technology can continue, but with adequate scientific assessment and evaluation.


  United Biscuits welcomes the Committee's enquiry into this important topic.

  The company believes that, in the long term, there are likely to be benefits to society as a whole and to individual consumers, from the introduction of genetically modified foods.

  However, because any changes in the supply chain, or the introduction of bio-tech advances impact strongly on the operations of food manufacturers, we believe their views are most relevant and prior consultation must take place.

  Companies like United Biscuits can do much to ease the introduction of new advances in food by working with the broader industry to devise and implement information programmes, by monitoring consumer attitudes, by working with Governments to effect workable regulations and, ultimately, to deliver a better product to customers and consumers alike.

  UB commends the Committee for its deliberations.

28 October 1998

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