Comments and Correspondence
ICGMA COMMENTS SUBMITTED TO HEALTH CANADA ON COUNTRY OF ORIGIN LABELING
March 7, 2002
Mr. Ron B. Burke
Director, Bureau of Food Regulatory International
and Interagency Affairs
Health Promotion Branch
Health Canada
HPB Bldg., Room 200
Tunney’s Pasture
Ottawa K1A OL2
Canada
Dear Mr. Burke:
The International Council of Grocery Manufacturers Associations
(ICGMA) is pleased to provide input on the “Discussion Paper
on Country of Origin Labeling.” (ALINORM 01/21).
ICGMA, a recognized INGO before the Codex Alimentarius Commission,
represents the interests of national and regional associations who
collaborate with all sectors of the consumer packaged goods industry.
ICGMA promotes the harmonization of scientific standards and policies
concerned with health, safety, packaging, and labeling of foods,
beverages, and other consumer packaged goods. ICGMA also works to
facilitate international trade in these sectors by eliminating or
preventing artificial barriers to trade.
General Comments:
We believe that the Codex Committee on Food Labeling (CCFL) should
not begin new work in the area of country of origin labeling, and
should instead stay focused on labeling issues that promote science-based
health and food safety objectives. ICGMA continues to oppose efforts
to impose extraneous food labeling requirements that afford no health
or safety benefits to consumers. Country of origin labeling for
ingredients serves only to increase the costs of production for
food producers and regulatory costs of governments—particularly
those in developing countries. 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
regarding the health or safety of the product.
Comments to the “Discussion Paper on Country of Origin
Labeling.” (ALINORM 01/21):
As stated previously, ICGMA supports providing “factual,
verifiable, understandable and non-misleading information”
relevant to the protection of consumers’ health and to ensure
fair practices in food trade. For this reason, we support the existing
Codex general standard that requires country of origin labeling
only in cases where its omission would mislead or deceive the consumer.
This requirement is appropriately focused on the objective of preventing
consumer deception.
Furthermore, ICGMA believes that the “Discussion Paper on
Country of Origin Labeling” is potentially violative of the
World Trade Organization’s (WTO) trade agreements. Specifically,
Article 2.2 of the Agreement on Technical Barriers to Trade (TBT
Agreement) provides that technical regulations shall not be “prepared,
adopted, or applied with a view to or with the effect of creating
unnecessary obstacles to international trade.” To ensure that
no unnecessary obstacles are erected, the Agreement requires that
any regulations enacted “shall not be more trade-restrictive
than necessary to fulfill a legitimate objective.”
Country of origin labeling is an obstacle to trade because the
enormous compliance and regulatory costs will force many producers,
especially those in developing nations, out of the market. It is
also unnecessary because it is something that could be achieved
in a less trade-restrictive manner, for instance through the establishment
of a voluntary system for labeling. Additionally, country of origin
labeling does not fulfill a legitimate objective because it does
nothing to advance the health and safety of consumer products. Country
of origin labeling requirements do not fulfill Codex’s mandate
of “protecting the health of the consumer and ensuring fair
practices in the food trade.”
Moreover, work on international harmonization of rules of origin
has been underway for several years in the WTO, with technical assistance
from the World Customs Organization (WCO) (formerly the Customs
Cooperation Council). This work was mandated by the WTO Agreement
on Rules of Origin that was concluded in 1994 as part of the Uruguay
Round of Multilateral Trade Negotiations. ICGMA continues to raise
concerns that setting Codex standards based on political pressures
will duplicate, and even contradict, the work of the WTO and WCO.
Finally, ICGMA remains concerned about the impact of country of
origin labeling requirements on developing nations. Developing countries
are oftentimes left out of the decision-making process even though
they are the hardest hit by the costs imposed by new regulations.
Many developing nations will not be able to absorb the costs of
these new labeling requirements which fail to offer any safety or
health benefits to consumers. As a result, they will be forced out
of the international market and suffer significant economic losses.
The costs of this labeling scheme will be most onerous for small
processors. With the significant additional costs of country of
origin labeling, these companies will no longer be able to compete
in the global marketplace and will be forced out of business, seriously
impairing free trade and consumer choice.
In conclusion, for the reasons discussed above, ICGMA strongly
urges CCFL to refrain from beginning new work in the area of country
of origin labeling. Instead, CCFL should remain focused on labeling
issues that promote science-based health and food safety objectives.
* * *
ICGMA appreciates the opportunity to comment on this very important
issue. Should you have any questions or need additional information
on our comments, please do not hesitate to contact me.
Sincerely,
Mari Stull
Executive Secretariat
International Council of Grocery Manufacturers Associations
cc. FAO Secretariat
C. Taylor-Lewis
FCPMC
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