Hultsfred, Sweden 2000-06-30
Health & Consumer Protection Directorate-General
Rue de la Loi 200
Re: White Paper on Food Safety
Thank You for giving us this opportunity to respond to the White Paper
on Food Safety, and especially how consumers can participate in the risk
anlysis process, including risk management. Association of European
Consumers AEC has since its foundation 1999 worked for increased consumer
information. We have recognized consumers' right to sustainable development
in relation to food safety as a main focus for our work. We also work to
raise awareness about environmental and ethical issues, animal welfare,
and global issues. For food safety, we also consider the development and
conservation of agro-genetic resources as important for consumers.
While we support the proposals in the White Paper on Food Safety, we
would like to propose that consumer information gets a more prominent
role in the development of a European food safety policy. This needs to
be a horizontal concern. Experts from consumer organizations need to be
informed to be able to play a role in the risk analysis process, especially
in the management of risks. Consumers should never feel that producers,
retail or governments may hide data about food safety. To treat any food
related issue as a "trade secret" will give consumers the impression that
someone is hiding a "dirty secret".
We are insisting that consumers have a right to access to scientific
documents that are used in the risk assessment process, and cannot agree
that corporate interests should be protected rather than human
interests. Unpublished studies should generally not be used, especially
if they are reporting from studies conducted at corporate laboratories
or sponsored by the industry. One area we are very concerned about is intellectual
property rights, were patents on DNA, especially in microbes, grains, vegetables
and other foods including fish or meat may create monopolies that will
not at all benefit consumers.
Health is paramount for European consumers and after food scandals such
as BSE we insist that we have a right to be an equal party of the risk
analysis process. In order to participate fully, we must have access to
all available information. This is also true in the field of nutrition,
were new substances or foods may or may not turn out to be benificial to
In the risk analysis process, consumers can be successfully represented
by professional experts from consumer organizations at all three stages.
Participants from consumer organizations are skilled at raising awareness
of important matters that scientists, businessmen or politicians may overlook.
In the risk assessment process, professional experts from consumer organizations
can ensure that health protection and ethical concerns are
taken into proper consideration. Experts from consumer organizations can
assist policy makers in the risk management process by supporting or clarifying
decisions that need to be communicated to other parties of the process.
They will make sure that consumer concerns are heard by all parties, as
well as send strong and rapid messages to all involved when decisions are
not understood or appreciated by consumers. In the risk communication process,
experts from consumer organizations can be the "honest brokers" that are
percieved as being unbiased and fair if they have had access to information
at all stages of the decision making process.
We think the risk analysis process in the European Union will benefit
from increased scrutiny by professional experts from consumer organizations.
This will also aid and benefit the European Union in the international
arena. Specifically, we do not think the current system of FAO/WHOCodex
Alimentarius standards is sufficiently transparent. Codex alone cannot
guarantee that all food additives, pesticide residue, veterinary drug residue
and microbes are safe.
We insist that the European Commission must provide better information
to consumers about the risks and benefits associated with controversial
developments in the field of industrial food production technologies such
as irradiation and biotechnology. The European Commission must work towards
a situation where the JECFA and JMPR expert groups will be
opened up to normal scrutiny and ensure that meetings are open to observers
from consumer organizations. Otherwise, the World Trade Organization
agreements, especially the SPS Agreement, will not be acceptable
for European consumers.
Animal welfare concerns are intimately connected with food safety issues.
Association of European Consumers AEC thinks the White Paper of Food Safety
is rather weak in areas such as animal transportation and slaughter
methods. Consumers may be exposed to many contaminants such as E coli
bacteria or Campylobacter that are known to cross-contaminate animals in
the slaughter process. We welcome the proposals for safe animal feed as
this has often been neglected until now. Please do not ignore the need
for safe drinking water. Also unhealthy substances such as naturally-occuring
stress hormones may contaminate the meat as a direct result of long transports
of live animals.
Slaughter methods that cause unnecessary stress and/or pain for the
animals must be banned and the monitoring needs to be improved. It must
be recognized that zoonotic diseases cost society a lot of money.
We especially urge the European Commission to step up activities at the
International Office of Epizootics to develop international animal welfare
standards. Good standards should be based on a cradle-to-grave approach
that take into account the importance of sustainable animal breeding methods.
Consumer organizations can participate more actively in the risk management
process if certain demands are fulfilled. Mandatory animal welfare labels
are probably the quickest way of giving consumers a way to influence the
current situation, especially in a crisis of confidence, as more consumers
become aware of the ethical issues involved. We support the current push
towards country-of-origin labels for meat and we think this should
be extended to other meat product groups as well. The traceability
of food products through proper documentation is important from the animal
welfare perspective as this can be used to ensure that a mandatory animal
welfare label becomes reality as soon as possible. Egg labels is another
area that certainly need to be improved and were animal welfare concerns
must be considered. Improved standards and regulations for fish products
also need to be considered as many consumers are questioning the environmental
aspects of over-fishing while they may also want to avoid products from
unsustainable fish farms.
We strongly urge You to make sure that consumers get the proper information
they need in order to make informed choices about new developments in the
fields of food and agriculture. We want to be involved in the risk analysis
process, including risk management, on an equal basis with other experts.
In the democratic market place, consumers are as important as the producer.
We, as European consumers, generally enjoy good consumer protection but
will look forward to continue to work with You towards better food safety.
Assistant on Food Safety