Background Paper
BIOTECHNOLOGY FOOD INGREDIENT TRACEABILITY
September, 2001
At the first session of the Codex Ad Hoc Intergovernmental Task
Force on Foods Derived from Biotechnology, France proposed that
guidelines be developed for traceability of foods derived from biotechnology.
Since the concept of traceability was new to Codex, it was agreed
that further clarification and explanation was required; therefore
France was assigned to develop a discussion paper on traceability.
France presented a draft copy of the discussion document at the
first meeting of the Working Group that had been established to
develop papers on general principles for risk analysis of foods
derived from biotechnology and guidelines for the safety assessment
of foods derived from biotechnology. France explained that traceability
is the process that verifies the nature and origin of a genetically
modified product through appropriate documentation of reliable information.
Traceability is possible if each segment of the food chain efficiently
tracks information from agricultural production to finished product.
France also stressed that traceability is an essential component
of the vigilance that should be exercised after these products are
marketed. France further emphasized the need to link traceability
to risk analysis for foods derived from biotechnology.
The International Council of Grocery Manufacturers Associations
(ICGMA) believes that the French approach is flawed and impractical
because no scientific reason has been provided to warrant traceability
for foods and ingredients from biotechnology. Implementation of
traceability as proposed by the French would be mainly through documentation
and not through analytical procedures. If a misinterpretation (in
either direction) is made early in the documentation chain, the
misinterpretation would follow the product to the end, resulting
in an inaccurate label. It would be imperative to have some system
of analytical monitoring to confirm that the documentation is correct.
The stress on the need for post-market monitoring of foods and ingredients
derived from biotechnology raises the question as to whether Codex
should be involved in such an exercise that is the responsibility
of national governments.
Also, such guidelines are unnecessary because: (1) the approved
foods and ingredients are safe, and have been confirmed to be safe
by governments; (2) implementation of traceability would be expensive,
without corresponding benefits; (3) post-market monitoring such
as traceability should not be a Codex concern; and (4) any costs
associated with a claims label for foods from biotechnology should
be borne by the organization making the claim.
Approved foods and ingredients derived from biotechnology
are safe.
Extensive studies and reviews by governments have shown that
foods and ingredients from biotechnology are safe. This is particularly
true for products that have been specifically approved by governments.
There are no requirements to “trace” other approved
products, and no reason that is based on science has been given
to require this for foods from biotechnology.
Implementation of the concept of traceability would
be an economic burden without comparable benefits.
Although the French draft guidelines would implement traceability
mainly through documentation, it would be imperative to have analytical
methods endorsed by Codex to confirm the documentation. Any enforcement
procedure must have objective methods for confirmation. These
analyses would be resource intensive and costly, and would be
a burden on governments, especially developing countries. The
corresponding benefits; i.e., a label statement, would not be
comparable to the economic costs of implementation because the
label state would be for information only, and not to advise on
health/safety issues.
We question whether Codex should be concerned with post-market
monitoring, such as traceability.
Implementation of traceability as proposed by France would not
be feasible on a global basis, considering the differences in
development and policies in different countries. Post-market monitoring
should remain the responsibility of national governments. It raises
a basic question as to whether Codex should be concerned with
post-market monitoring as proposed. Codex Committees are charged
with the responsibility of developing standards and leaves monitoring
for compliance to national governments.
We agree that consumers and manufacturers should be
given a choice.
We agree that some consumers prefer products that do not contain
foods derived from biotechnology, while others may want the benefits
that specific products from biotechnology provides. Manufacturers
want to provide for consumer preferences; therefore they may want
to make claims about their products. We believe that specific
guidelines should be developed to address these types of claims.
These manufactures would be bearing a greater part of the economic
burden, because they would be responsible for the accuracy of
their label. They would therefore perform the required tasks needed
to ensure accurate information. Regulatory agencies could then
develop enforcement plans to target voluntary labels, rather than
a plan to implement guidelines to trace all products through biotechnology.
The International Council of Grocery Manufacturers Associations
is an international non-governmental organization (NGO) officially
recognized by the Codex Alimentarius. ICGMA represents the interests
of national and regional associations representing all sectors of
the grocery industry and serves to facilitate harmonization of standards
and policies concerned with health, safety, packaging, labeling,
advertising and marketing of foods, beverages and other grocery
products.
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