Comments and Correspondence
ICGMA COMMENTS ON AUSTRALIAN COUNTRY-OF-ORIGIN LABELING PROPOSAL
July 10, 2001
The Project Manager
ANZFA
PO Box 7816
Canberra MC
ACT 2610
Australia
Dear Project Manager:
The International Council of Grocery Manufacturers Associations
(ICGMA) is an international non-governmental organization officially
recognized by the Codex Alimentarius Commission, the International
Chamber of Commerce, and the Organization of Economic and Cooperative
Development (OECD). ICGMA represents the interests of national and
regional associations who collaborate with 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 consumer packaged goods.
In this context, ICGMA welcomes the opportunity to present our
submission to the Australia New Zealand Food Authority in response
to the request for comment on Proposal P237 – Country
of Origin Labelling.
The ICGMA strongly supports Option 2 – No specific
requirement in the new joint Australia New Zealand Food Standards
Code to make a country of origin declaration.
An internationally accepted Codex general standard already requires
country of origin labeling in cases where its omission would mislead
or deceive the consumer. This requirement is appropriately focused
on the objective of preventing consumer deception. Mandating country
of origin labeling across the board or expanding it to include ingredients
would be burdensome, impractical, and provide no additional benefit
to the consumer. Country of origin labeling has no relation to public
health or food safety, and conveys no useful information to the
consumer on health or safety.
Expanding country of origin labeling requirements beyond the origin
of the food, to reach the origin of the food’s ingredients,
is particularly troublesome. Ingredients may be sourced from suppliers
in different countries during different times of the year, or from
multiple countries and then commingled or blended. Variations in
ingredient availability as well as quality affect usage and manufacturing
decisions by food companies.
Ingredient manufacturers, traders, and food processors and manufacturers
would be constantly required to segregate ingredients from different
countries in order to ensure proper compliance with ingredient origin
labeling requirements, and to maintain a myriad of labels to correspond
to every possible mix or combination of sources of ingredients.
Even if this could be done as a practical matter, the compliance
costs would be astronomical for foods with multiple ingredients
– ICGMA understands that the cost of label changes, resulting
from any more detailed country of origin labeling requirements than
currently exist, would be at least $10 - $100 million for food products
sold through Australian supermarkets. The range of different labels
for a food product that is compositionally the same would be very
confusing to the consumer.
Existing international trade rules under the WTO Agreement on Technical
Barriers to Trade (TBT) prohibit technical regulations (including
labeling requirements) from creating unnecessary obstacles to international
trade. Such regulations may not be more restrictive than necessary
to fulfill certain identified legitimate objectives, which include
national security, prevention of deceptive practices or protection
of human health and safety. Mandatory country of origin labeling
would most likely create an unnecessary obstacle to trade with no
legitimate or internationally recognized justification.
The International Council of Grocery Manufacturers Associations
appreciates ANZFA’s consideration of our comments.
Sincerely,
Mari Stull
Executive Secretary
CC: AFGC
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