Comments and Correspondence
ICGMA COMMENTS ON HEALTH CLAIMS
June 9, 2003
Secretary, Codex Alimentarius Commission
Joint FAO/WHO Food Standards Programme
FAO
Viale delle Terme di Caracalla, 00100
Rome, Italy
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.
The International Council of Grocery Manufacturers Associations
(ICGMA) appreciates the opportunity to provide input on the Draft
Guidelines for Use of Nutrition and Health Claims at Step 8
(Alinorm 03/22A, Appendix IV).
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 elimination or
preventing artificial barriers to trade.
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. IGCMA
opposes the adoption for the following reasons:
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 labeling 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.
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 therefore be
returned for circulation and comments on these issues.
Again, ICGMA appreciates the opportunity to provide comments on
these Guidelines.
Sincerely,
Mari Stull
Executive Director
International Council of Grocery Manufacturers Associations
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