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Position Paper
PRIOR CARGOES
February, 2001
At its February 2001 meeting, the Codex Committee on Fats and Oils
(CCFO) adopted an amendment to the Recommended Code of Practice
for the Storage and Transport of Edible Oils in Bulk regarding shipment
of cargoes prior to the shipment of edible oils. This amendment
established criteria for evaluating substances for prior cargo lists
and elaborated specific acceptable and banned prior cargo lists.
CCFO sent the amendment to the Codex Alimentarius Commission (“the
Commission”) at Step 5/8, recommending its immediate approval
by the Commission.
The International Council of Grocery Manufacturers Associations
(ICGMA) believes this action by CCFO was taken hastily, is not justifiable,
does not reflect the Codex principle of sound scientific decision-making,
and fails to address a process or procedure for future revision
of the list.
More specifically, the amendment:
Adopts criteria for evaluating substances to be placed
on Codex prior cargo lists and then “grandfathers”
a list of acceptable prior cargoes developed by the European Union
Scientific Committee for Food (EU SCF) without any discussion
or determination as to whether the substances on the EU SCF list
meet these criteria. Eliminates from the acceptable prior cargo list any
substances on the acceptable prior cargo lists of the National
Institute of Oilseed Products (NIOP) and/or the Federation of
Oil, Seeds, and Fats Associations (FOSFA) that do also appear
on the EU SCF list, without discussion or determination as to
whether the substances on either of these two organization lists
meet the criteria. NIOP and FOSFA have maintained such lists for
decades through transparent evaluation processes conducted by
qualified experts. Provides for no process to amend the list, nor does
it provide for any time period in which such a process should
be conducted and concluded. Identifies no expert body to review new candidate substances
for the prior cargo lists, nor any process to determine how such
a body should be selected.
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.
The International Council of Grocery Manufacturers Associations
is an international non-governmental organization (NGO) officially
recognized by the Codex Alimentarius. ICGMA represents the interests
of national and regional associations representing all sectors of
the grocery industry and serves to facilitate harmonization of standards
and policies concerned with health, safety, packaging, labeling,
advertising and marketing of foods, beverages and other grocery
products.
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