Comments and Correspondence
ICGMA COMMENTS ON COUNTRY-OF-ORIGIN LABELING
May 5, 2004
Mr. Ron Burke, Director
Bureau of Food Regulatory, International and Interagency Affairs
Health Products & Food Branch
Health Canada, Building #7, Room 2395
Tunney’s Pasture, Ottawa K1A 0L2
Canada
Mr. Burke:
The International Council of Grocery Manufacturers Associations
(ICGMA) is pleased to provide the following comments regarding items
to be discussed at the upcoming Codex Committee on Food Labeling
meeting in Montreal, Canada on 10-14 May, 2004.
ICGMA, a recognized international non-governmental organization
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.
Country-of-Origin Labeling (CX/FL 04/8)
1. ICGMA does not support undertaking new work on country-of-origin
labeling standards.
This is consistent with ICGMA’s previously stated opposition
to extraneous food labeling requirements that afford no consumer
health or safety benefit. ICGMA members believe this position helps
to focus Codex’s priorities and limited resources on the development
of standards that protect the health of consumers and ensure fair
practices in food trade.
ICGMA CCFL Comments
May 3, 2004
Page 2 of 3
2. ICGMA believes the existing Codex General Standard for the Labeling
of Prepackaged Foods is appropriately focused on preventing consumer
deception.
ICGMA is not aware of any consumer protection, health or safety
issue that would merit a change.
3. Expanding country- of- origin labeling beyond the origin of
the food itself to include the origin of individual food ingredients
is particularly troublesome.
Ingredients may be sourced from different suppliers in different
countries during different times of the year or from multiple countries
and then commingled and/or blended. Extending country-or-origin
labeling requirements on ingredients would force ingredient manufacturers,
commodity refiners and food manufacturers to constantly segregate
products from different countries in order to ensure compliance
with ingredient origin labeling. Even if this could be done as a
practical matter, the compliance costs would be astronomical for
foods with multiple ingredients.
4. ICGMA believes that the costs associated country-of-origin labeling,
like other process or origin-based labeling regimes, will most disadvantage
small food processors as well as small developing countries.
Country-of-origin labeling will impede the ability of such companies
and countries to compete in the global marketplace, seriously impairing
their growth as well as consumer choice worldwide.
5. ICGMA believes that additional Codex action on country-of-origin
labeling could violate existing obligations of national governments
under the WTO TBT Agreement.
Specifically, Article 2.2 of the 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 measures taken “shall
not be more trade-restrictive than necessary to fulfill a legitimate
objective.”
ICGMA CCFL Comments
May 3, 2004
Page 3 of 3
Country-of-origin labeling is an obstacle to trade because of the
enormous compliance and regulatory costs imposed on producers, especially
those outside of the domestic market and in developing nations.
It also is unnecessary because it is something that could be achieved
in a less trade-restrictive manner, for instance through the establishment
of a voluntary, market-drive labeling system.
Sincerely,
Karil L. Kochenderfer, Secretary
cc: Secretary, Codex Alimentarius Commission
Joint WHO/FAO Food Standards Programme
FAO
Viale delle Terme di Caracalla, 00100
Rome, Italy
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