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Position Paper
UK COUNTRY OF ORIGIN LABELING IN CODEX
May, 2001
At the 28th session of the Codex Committee on Food Labeling (CCFL),
in May 2000, a recommendation was presented by the United Kingdom
(UK) Government to start new work to amend the General Standard
for Prepackaged Foods, to require detailed labeling of the country
of origin of prepackaged foods as well as their ingredients. A discussion
paper was prepared by the UK, Switzerland and Malaysia and presented
at the 29th session, April 30-May 4, 2001, which outlined options
for new provisions to origin declarations for foods and ingredients.
Diverse views were presented by delegations. Some supported undertaking
a revision; others, including the delegation of the U.S. and observers,
expressed concerns about practical implications, and the justification.
The Committee agreed to seek the approval of the Commission for
new work to amend Section 4.5 of the General Standard.
The existing Codex General Standard for Prepackaged Foods (GSFPF)
includes the following labeling requirements with regard to country
of origin:
Sec. 4.5.1 The country of origin of the food shall be declared
if its omission would mislead or deceive the consumer.
Sec. 4.5.2 When a food undergoes processing in a second country
which changes its nature, the country in which the processing
is performed shall be considered to be the country of origin for
the purposes of labeling.
The International Council of Grocery Manufacturers Associations
(ICGMA) believes CCFL should not begin new work in this area, and
instead stay focused on labeling issues that promote science-based
health and food safety objectives.
Identified Concerns:
Work on international harmonization of rules of origin has
been underway for several years in the World Trade Organization
(WTO), with technical assistance from the World Customs Organization
(WCO) (formerly the Customs Cooperation Council). This work was
mandated by the WTO Agreement on Rules of Origin that was concluded
in 1994 as part of the Uruguay Round of Multilateral Trade Negotiations.
Although the harmonization work has not yet been completed, significant
progress has been made. The existing Codex general standard already requires country
of origin labeling in cases where its omission would mislead or
deceive the consumer. This requirement is appropriately focused
on the objective of preventing consumer deception. Most countries,
including the United States, already have in place regulatory
requirements for country of origin labeling of food products.
Mandating country of origin labeling across the board or expanding
it to include ingredients would be burdensome, impractical, and
provide no additional benefit to the consumer. Country of origin
labeling has no relation to public health or food safety, and
conveys no useful information to the consumer on health or safety. -
Expanding country of origin labeling requirements beyond the
origin of the food, to reach the origin of the food’s
ingredients, is particularly troublesome. Ingredients
may be sourced from suppliers in different countries during
different times of the year, or from multiple countries and
then commingled or blended. Variations in ingredient availability
as well as quality affect usage and manufacturing decisions
by food companies. Ingredient manufacturers, traders, and food
processors and manufacturers would be constantly required to
segregate ingredients from different countries in order to ensure
proper compliance with ingredient origin labeling requirements,
and to maintain a myriad of labels to correspond to every possible
mix or combination of sources of ingredients. Even if this could
be done as a practical matter, the compliance costs would be
astronomical for foods with multiple ingredients. Moreover,
the range of different labels for a food product that is compositionally
the same would be very confusing to the consumer.
Existing international trade rules under the WTO Agreement
on Technical Barriers to Trade (TBT) prohibit technical regulations
(including labeling requirements) from creating unnecessary obstacles
to international trade. Such regulations may not be more restrictive
than necessary to fulfill certain identified legitimate objectives,
which include national security, prevention of deceptive practices
or protection of human health and safety. Expanded mandatory country
of origin labeling would most likely create an unnecessary obstacle
to trade with no legitimate or internationally recognized justification. Finally, new work in Codex on country of origin labeling should
not be undertaken while the WTO is completing its work on harmonization
of rules of origin. We must be careful to avoid any duplication
of work or inconsistency of approaches and criteria used in Codex
standards and WTO rules as they relate to determining and identifying
origin of foods.
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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