|Dockets Management Bransch (HFA-305)
Food and Drug Administration
5630 Fishers Lane, rm. 1061
Rockville MD 20852
Docket No 98N-1038,
”Irradiation in the Production,
Processing and Handling of Food”
Dear Commissioner Henney,
We are deeply concerned about US temptations and
proposals to change the legislation regarding labeling of irradiated food.
Not only because it will have consequences contrary to Codex current regulation,
but also because consumers’ democratic right to choose will be jeopardized.
It is obvious that these US proposals are put
forward by the industry to protect their own interests. At the same time,
so open and clear, it shows how industry has no intention to care for or
listen to the consumers, but have intention to protect their possibilities
to increase the use of irradiation and to ignore the fear from consumers
and consumers right to be informed.
Normally when a producer is proud of his product
he boast of it and blows up his arguments in big letters in the publicity
and in labeling of the product, normally on the front of the packing. But
trying to minimize labeling and weaken the words, as ”cold pasteurization”
only give us the impression that he want to hide something.
Even if the FDA legislation only will be applicable
in the US we see this effort as a first step to weaken the future regulations
of Codex. We can also see what will happen in the future when US industry
want to force the European countries to import irradiated foods from the
US. It will soon be called a threat to free trade and therefore we can
not keep our own rules in Europe for our own safety and consumer
We are also concerned that a negative attitude
to all kinds of US products is growing. The actual trade war around
hormone beef is one example that upsets European consumers, particularly
because no respect is shown from the US side to our own concerns for the
safety of food. We want to use the precautionary principle and avoid hormone
beef as we have indications of risks, but this is not allowed because the
US absolutely wants to force their products on European consumers. The
same discussion concern the rBGH hormone for milk producing cows. We also
can´t belive that the enormous opinion against GM foods is not known
in the US. The opposition is also continuosly increasing, something that
confirms what we said before, about the negative image the US-products
are more and more getting in Europe.
This way of eliminating the democracy is not appropriate
for a country saying that they fight for democracy and peoples rights.
The UN charter for Consumers Rights have also been signed by USA.
Behind the facade of democracy we can imagine
a transnational company dictatorship. We are afraid of these tendence.
We are anyhow happy that in Europe the consumers rights are very
strong and the consumers’ democratic right to a choice and to make their
own decisions to choose are widely accepted. Therefore labeling is a key
issue and not negotiable from the consumers’ point of view.
We write this to you to give you our opinion and
concerns and to urge you to consider the opinion in all the European countries
and amongst a great majority of the consumer organisations worldwide.
We also hope that you take our concerns seriously
and that you take in consideration how the US image is changing both among
countries and consumers in Europe. It is quite clear that the method
to weaken Codex regulations, proposals such as this are not popular in
Europe and will not make it easier for US to gain the European consumers’
Behind this concern, when writing to you in this
matter, we also have the newly formed European organisation ”Association
for European Consumers, socially and environmentally aware, AEC” at the
moment counting more than 20 organisations.
To sum up, the opinion from consumers outside
the US urge you to not adopt the proposed changes, especially for the reason
not to start more trade wars that also in the long run will damage the
US trade with markets outside the US.
Swedish Consumer Coalition
Mr Eric Benjaminson, Ambassy of
the United States of America, Stockholm, Sweden
and EU Commission
and Swedish Ministry for Foreign