Swedish Consumer Coalition
Member of Association of European Consumers AEC

Sweden, Hultsfred 2000-10-23


European Commission

DG Sanco


Re: Consultation Paper on Irradiated food and food ingredients

Swedish Consumer Coalition appreciates the opportunity to express our opinions in the open discussion about the Consultation Paper. We feel points 1-10 basically reflect the view of consumers in Sweden, namely that food irradiation should be avoided. We are glad that the Consultation paper thinks the total amount of food which is treated by irradiation is small in member states. We want you to keep it that way by strict legislation and controls. We are following the international debate also, and are worried about recent proposal from the US with regards to labelling (See our letter to FDA, enclosed).

Having considered the proposals to you from several member countries to include a large number of foods in the so-called positive list, we are worried that there are interests that intend to irradiate many foods intended for consumer who may not be able to choose wether or not he or she wants to buy food that is treated in this way.

Specific comments about your "possible strategy", point 11.

While we have previously agreed in principle that certain spices ("dried aromatic herbs") may be irradiated if - and only if - necessary, we cannot see the need to include in the positive list "dried fruit "and "flakes or germs of cereals". Dried fruits and flakes of cereal are often considered as "health foods" such as muesli, and this image would be confused as the perception of the consumer would be challenged. Consumers would really be baffled by the fact that a "health food" needs to be irradiated! We think this may hurt sales of both irradiated and non-irradiated products in these product groups. Why? Because the image of normal dried fruits and flakes or germs of cereals may be tainted and misperceived as dangerously contaminated. In our opinion, "health foods" such as muesli should not need to be de-contaminated at all.

As for frog legs, they are not a very commom dish in Sweden, and we think it is a typical example on foods that we take from countries under development to feed the rich world and that needs special treatment to be edible at all. We do not need irradiation to take food away from countries that need it better than we.

Peeled shrimp, however, is commonly eaten in Sweden, and we cannot agree that this food should be on the positive list, for technical reasons and hygienic reasons. There is no good reason why a product from the oceans should be mishandled by a processing industry in such a way that it becomes contaminated. Legislation should not allow it to happen. If temperatures are kept at low and proper levels at all stages of transportation, storage, peeling and production, how can the shrimp be infected by any harmful micro-organisms? Another case when shrimp may become unfit as food is when it has been been unsucessfully offered for sale, and the same shrimp is processed and offered for sale again at a later time. Irradiation should not be used to substitute good hygienic practices especially to prolong the shelf-life of goods that are unsucessfully offered for sale at several different occasions. We are especially concerned that large-scale shrimp farming would be set up if irradiation is allowed, and that normal hygien will be compromised. In general we are not only worried but quite sure that if irradiation will be allowed many producers will decrease their efforts to keep a hight level of hygene, as they at the end can "clean up" the products. This will be contrary to all efforts to push Food Safety.

Your further suggest:

"Mechanically recovered chicken meat, offal of chicken, egg white and gum arabic (additive). These food ingredients may be unavoidably contaminated and need to be decontaminated to reduce health hazards and to extend the shelf life."

We are shocked that "offal" may be considered a food as this word in our dictionary means "refuse, rubbish, waste" (The Cassell Concise Dictionary, 1997) and we hope you mean something else, such as "other chicken parts", which we think you should specify.

We understand that industrial chicken production is a messy business, and cannot agree to support this type of irradiation for animal welfare reasons. For example, we know that large-scale chicken production requires antibiotics and in many countries growth hormones. For animal welfare reasons, as there can hardly be an incentive for improvement of the situation if chicken meat is irradiated, we disagree that mechanically recovered chicken meat or other chicken parts should be irradiated. We want to remind the Commission that in the WTO SPS Agreement, it is clearly stated that WTO members desire to "improve...animal health" in all countries. We think animals deserve better treatment and respect.

We are satisfied that you do not wish to include the following foods on the positive list, in spite of the opinion of the SCF: "Fresh fruits and vegetables, cereals, starchy tubers (potatoes), fish, camembert from raw milk, casein, rice flour and blood products, fresh red meats and poultry meat."

A very important point of view that we want to mention as an end of our answere is that irradiation plants are quite expensive and will be a weapon only for the big transnationals to eliminate smaller and local productions. That is not a development we want and as irradiation of foods is really not a necessity for survival or for good hygene, there is no reason for opening up a disastrous development on the world market.

We also enclose a letter we wrote to FDA in the US, as they were proposing to change the labelling legislation, in spite of Codex obligations.



Swedish Consumer Coalition

Bengt Ingerstam


Enclosed letter to FDA