Comments and Correspondence
ICGMA COMMENTS ON A QUANTITATIVE DECLARATION OF INGREDIENTS
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.
Proposed Draft Amendment to the General Standard for
the Labeling of Prepackaged Foods: Quantitative Declaration of Ingredients
(QUID)
1. ICGMA opposes the Proposed Draft Amendment and all efforts
to impose extraneous food labeling requirements that afford no consumer
health or safety benefit.
Product composition is sufficiently declared through full ingredient
labeling in order of predominance by weight. Mandatory percentage
ingredient labeling as proposed requires the disclosure of proprietary
information, e.g. recipes protected by trademark; distracts from
material information related to product safety and nutritional content;
and has the potential to confuse and mislead consumers who have
no numerical concept of the appropriate ingredient percentage in
packaged food products.
ICGMA CCFL Comments
May 3, 2004
Page 2 of 2
2. The Proposed Draft Amendment could have the effect of reducing
consumer choice and marketplace competition without increasing safety
quality or consumer confidence.
Rather than divulge proprietary information or confront the technical
burdens of complying with the Proposed Draft Amendment to access
the market, food companies would withdraw select product lines.
Governments that adopted such measures then would be saddled with
the burden of implementing and enforcing the requirements that effectively
hinders consumer choice and marketplace competition.
3. ICGMA is particularly concerned about the impact of such
labeling requirements on small and developing businesses as well
as small and developing economies.
The significant expenses associated with the proposed amendment
coupled with the slim profit margins inherent in the food processing
industry will burden small and developing business. Additionally,
the regulatory structures in many small economies have neither the
personnel nor the budgets necessary to enforce such a burdensome
labeling scheme, as scare regulatory resources are focused on other
important food safety issues.
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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