Comments and Correspondence
ICGMA COMMENTS 2003 CODEX ALIMENTARIUS COMMISSION AGENDA ITEMS
May 28, 2003
Dr. Alan Randall
Secretary of the Codex Alimentarius Commission
FAO
Viale delle Terme di Caracalla
0100 Rome, ITALY
Re: ICGMA Comments 2003 Codex Alimentarius Commission Agenda Items
Dear Dr. Randall:
The International Council of Grocery Manufacturers Associations
(ICGMA), a recognized NGO 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 the sector by eliminating or preventing
artificial barriers to trade.
As requested by your office, we are pleased to present our comments
on specific agenda items of the 26th Ordinary Session of the Codex
Alimentarius Commission.
ICGMA offers our comments on agenda items that are relevant to
the ICGMA Membership. Accordingly, not all agenda items will be
specifically addressed in these comments.
CODEX COMMITTEE ON GENERAL PRINCIPLES
- Draft Working Principles for Risk Analysis in the Framework
of Codex at Step 8
ICGMA Supports the adoption of these Principles.
- Proposed Amendments to the Procedural Manual: Membership
of Regional Economic Integration Organizations
ICGMA Strongly Opposes the EC proposal to seek
membership in the Codex Alimentarius Commission. Contrary to the
title of this proposal, the issue of Regional Economic Integration
Organizations is applicable solely to the constructs of the European
Community and would not afford the same rights and privileges
to any other economic or regional bloc within Codex - such as
the Caricom or Andean Pact groups. Under the FAO Constitution,
a regional economic integration organization is defined as "an
organization constituted by sovereign States of a given region,
to which its member States have transferred competence in respect
of matters governed by this Convention and which has been duly
authorized, in accordance with its internal procedures, to sign,
ratify, accept, approve or accede to it." Under this very
finite and limiting definition, special rights are afforded to
one group of Codex members at the expense of the rest of the membership.
Additionally, the collective voices of 25 Codex Members would
be effectively be muted.
The proposal fails to adequately address even the most basic
and practical considerations. Practical issues on the declaration
of competency alone are substantial enough to oppose the proposal
- among those practical issues are:
- What is the given timeframe under which the EC must declare
itself "competent" on a particular agenda item?
- Are declarations of competency made only upon request?
- Is competency extended to issues addressed in proposed Commission
Directives?
- Is competency declared by the EC or by its member states to
the EC?
- Can an EC member challenge competency- especially on issues
of dual competency?
- The Codex process naturally allows for and encourages floor
debate- how would the debate process be affected if only those
interventions by voting parties can be taken into account?
- For each declaration of competency when is the quorum count
called?
- Can competency be declared for procedural issues such as amendments
to the rules of procedures?
There are far too many uncertainties and unknowns that the mere
eight paragraphs of proposed rules governing this important issue
provide. Until such time the European Commission can offer a more
substantial and detailed proposal to the Codex Commission members,
we oppose such their vague request for Codex membership.
CODEX COMMITTEE ON FOOD ADDITIVES AND CONTAMINANTS
ICGMA Supports the following documents forwarded
by CCFAC at Steps 5/8 and 8:
-
Proposed Draft (Step 5/8) and Draft (Step 8) Revisions to the
Codex General Standard for Food Additives
-
Draft Revisions to the Annex to Table 3 of the Codex General
Standard for Food Additives
-
Proposed Draft Revised Recommended International Code of Practice
for Radiation Processing of Foods
-
Draft Revised Codex General Standard for Irradiated Foods
-
Proposed Draft Codex Advisory Specifications for the Identity
and Purity of Food Additives
-
Draft Maximum Level for Patulin in Apple Juice and Apple Juice
Ingredients in Other Beverages
New Work in CCFAC
- Proposed Draft Revised Preamble to the Codex General
Standard for Food Additives
ICGMA looks to the USA to assure that the decisions
in the revised document will be made to protect the health of
the consumers and ensure fair practices in the food trade.
- Proposed Draft Code of Practice for the Safe Use of
Active Chlorine
ICGMA Supports the view of the USA that, if a Code of
Practice is elaborated, it should be done so in cooperation with
CCFH and other appropriate Codex Committees.
CODEX COMMITTEE ON PESTICIDE RESIDUES
New Work: (Other matters for consideration by
the Commission):
- Advice on the proposed procedure of the elaboration
of Interim MRLs
ICGMA Supports this proposed procedure of the
elaboration of Interim MRLs.
- Reduction of an extraneous burden from the workload
of JMPR
ICGMA supports this issue.
CODEX COMMITTEE ON FOOD LABELLING
- Draft Guidelines for Use of Nutrition and Health Claims
at Step 8
ICGMA Strongly Opposes the adoption of these Guidelines.
References to "advertising" and the requirement to include
"other dietary sources" on the label when making a health
claim were added during the last session (31st Session) of the
CCFL. These requirements introduce a substantial extension to
the scope and purpose of the Guidelines, whereas the Committee
was to resolve only certain identified text and not to substantively
change the document or introduce language outside the identified
text.
No new work was approved to amend the Guidelines for
Use of Nutrition Claims. The inclusion of "and advertising"
in 1.1 of the Scope of the document introduces a substantial amendment
to the scope of the Guidelines for the Use of Nutrition Claims.
The Guidelines for Use of Nutrition Claims (CAC/GL 23-1997) were
adopted in 1997 and amended in 2001. No new work has been approved
to amend the guidelines since that time. At a previous session,
CCFL had agreed to incorporate the Guidelines for Use of Health
Claims into the Guidelines for Use of Nutrition Claims and change
the title of the Guidelines; however, at no time was there a request
for new work to change the scope of the Nutrition Claims guidelines.
Accordingly, from a procedural standpoint, this new wording cannot
be included in the scope. Further, we do not believe that the
CAC should discuss placing a reference for advertising in another
section of the document; if this discussion takes place, it should
be at the Committee level, and not utilize the CAC's valuable
meeting time.
The requirement to include information on other dietary
sources on the label with a health claim is not appropriate.
ICGMA supports labelling that provides consumers with clear, useful,
and relevant information to make an informed choice when purchasing
a product; therefore, we support including appropriate information
on the label with a health claim. However, the purpose of the
label is to inform consumers about the product in that particular
package, and any required information for the label should be
limited to the specific labeled product. In addition, label space
is very valuable to manufacturers, is often very limited, and
in many countries, the information must be presented in several
languages. Thus, ICGMA believes that the requirement in Section
7.5.3 to include information on other dietary sources when making
a health claim is inappropriate.
"Advertising" and "other dietary sources"
were new concepts added during the CCFL meeting; therefore
Member Countries and organizations that were not present did not
have the opportunity to comment on these issues before they were
included in the Step 8 document. The document should be returned
for circulation and comments on these issues.
- Draft Amendment to the General Standard for the Labeling
of Prepackaged Foods (Class Names) at Step 8
ICGMA Supports the adoption of the amendment to this
Standard
- *Draft Amendment to the Guidelines on Nutrition Labelling
at Step 8
ICGMA Supports the adoption of the amendment to these
Guidelines.
CODEX COMMITTEE ON NUTRITION AND FOODS FOR SPECIAL DIETARY
USES
New Work
- Proposed Draft Recommendations on the Scientific Basis of Health
Claims
ICGMA Supports this new work.
ad hoc INTERGOVERNMENTAL TASK FORCE ON FOODS DERIVED FROM
BIOTECHNOLOGY
ICGMA Supports adoption of the following Principles
and Guidelines at Steps 5/8 and 8:
-
Draft Principles for the Risk Analysis of Foods Derived from
Modern Biotechnology
-
Draft Guidelines for the Conduct of Food Safety Assessment
of Foods Derived from Recombinant-DNA
-
Draft Guideline for the Conduct of Food Safety Assessment of
Foods Produced Using Recombinant-DNA Microorganisms
-
Proposed Draft Annex on the Assessment of Possible Allergenicity
to the Draft Guideline for the Conduct of Food Safety Assessment
of Foods Derived from Recombinant-DNA Plants at Step 5/8
ICGMA Supports the continuity of this Task Force
under the leadership of the Japanese Government.
ICGMA Would Support a proposal for work on Guidelines
for Adventitious Presence of Ingredients Derived through Modern
Biotechnology in Food and Feed should the Task Force work be extended.
ICGMA Opposes any work on cloning of animals at
this time.
CODEX COMMITTEE ON FOOD HYGIENE
ICGMA Supports the following documents forwarded
by CCFH:
-
Draft Code of Hygienic Practice for the Primary Production
and Packing of Fresh Fruits and Vegetables at Step 8
-
Draft Revised Guidelines for the Application of HACCP System
at Step 8
-
Proposed Draft Code of Hygienic Practice for Milk and Milk
Products at Step 5
CODEX COMMITTEE ON MILK AND MILK PRODUCTS
ICGMA Supports the Revision to the Standard for Fermented Milk
Products at Step 8
CODEX COMMITTEE ON FOOD IMPORT AND EXPORT INSPECTION AND
CERTIFICATION SYSTEMS
- Guidelines for Food Import and Control Systems at Step
8
ICGMA supports adoption of these Guidelines
- Guidelines on the Judgement of Equivalence of Sanitary
Measures Associated with Food Inspection and Certification Systems
at Step 8
ICGMA supports adoption of these Guidelines
Discontinue Work
- Proposed Draft Guidelines for the Utilization and Promotion
of Quality Assurance Systems to Meet Requirements in Relation
to Food
ICGMA Supports the decision to discontinue work
on these draft guidelines.
Ad Hoc TASK FORCE ON ANIMAL FEEDING
- Proposed Draft Code of Practice on Good Animal Feeding
ICGMA Strongly Opposes the adoption of this Draft
Code
This document was inappropriately advanced in the accelerated step
process over the objections of several delegations and without the
requisite consensus and developing country input. We strongly object
the procedural deficiencies of this document, as well as the scientific
deficiencies inherent mandatory labeling and traceability.
CODEX COMMITTEE ON FATS AND OILS
- Recommended Code of Practice for the Storage and Transport
of Edible Oils in Bulk
ICGMA Strongly Opposes the adoption of the Code
of Practice.
If adopted by the Codex Commission, this amendment has the potential
to disrupt global trade in edible oil, particularly, in lesser developed
countries. The amendment was not given the appropriate consideration
by CCFO and deserves more careful review and scientific grounding.
The Commission should send the amendment back to CCFO for further
review, evaluation of substances against established criteria and
elaboration of a clear process for future revision of the lists,
particularly with respect to meeting the Codex principle of sound,
scientific decision-making.
Sincerely,
Mari Stull
Executive Secretariat
ICGMA
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