The EU's food industry association yesterday set out its wish list for the coming year, calling
for a raft of changes to current and proposed laws.
These include those on quality schemes, novel foods and ingredients, additives and enzymes, additives and flavourings, enzymes, nutrition and health claims, vitamins and minerals additives, and labelling and obesity.
The proposals are made in the latest memorandum issued by the Confederation of Food and Drink Industries of the EU (CIAA).
The document serves as an outline of the group's agenda for lobbying the European Commission and politicians for the next six months. The CIAA issues such memorandums as proposals to the country that takes over the leadership of the EU presidency every six months, in this case Germany, which takes over from Finland on 1 January.
The EU has been in the process of placing the food industry under increasing regulatory control, mainly due to public concerns about safety, quality and the amount of information it receives about the products they eat. In general, the CIAA's general stance has been toward attempting to hold back the tide of legislation in favour of self-regulation.
In the broad area of food safety, the CIAA has called on politicians not to confuse the issues with those relating to quality schemes. Food safety is a fundamental concept that is subject to law, quality is not, the CIAA argues.
"Once products comply with food safety standards, consumers will decide which foodstuffs they
want, depending on their income, lifestyle, tradition, etc.," the CIAA stated. "Food quality is up to the market and must not be subject to
mandatory, regulatory prescriptions. It is a private sector responsibility."
The food and drink industry has developed voluntary quality assurance schemes and is responsible for
these systems in relation to consumers, the organisation noted. There is an enormous diversity of
The European Commission is currently running a pilot project aimed at identifying such quality management
schemes in use throughout the bloc and is assessing the costs and benefits for companies operating in the
food chain. The Commission plans to hold a conference on food quality schemes in February 2007.
"In the discussions on the increasing number of quality assurance schemes, it must be recalled that it is
ultimately up to the consumer to judge the 'quality' of a product," the CIAA stated. "The
Commission should not prepare additional legislation in this area."
In relation to proposed changes to regulation governing novel foods, the CIAA says administrative burdens, timing and legal uncertainty
are making it more onerous and costly for processors to submit applications for the approval of new
In August 2006, the European Commission conducted an impact assessment of a revision of the
bloc's regulation on novel foods and ingredients.Â
"Discussions revealed that administrative burdens, timing and legal uncertainty add costs to the overall procedure,
which in the end counteract any likely benefit from the widely promoted European-wide innovation policy, and do
not contribute to the competitiveness of the European food and drink industry," the CIAA
stated. "This could act as a barrier to the creation of new jobs and also undermine consumer choice."
Uncertainty about the interpretation of the term â€œnovel,â€ which could lead to costly legal assessments before
considering an application in the segment, is currently preventing food and drink industry from innovating
more, the CIAA stated.
Discussions with CIAA member companies have revealed that the current EU novel foods legislation poses significant
obstacles to the development of new products, as companies frequently encounter significant administrative
difficulties when trying to obtain EU approval, the CIAA stated.
"The burden and lengthy duration of current extensive administrative procedures can be a deterrent for
EU food and drink companies wishing to invest in research and development (R&D) and in innovative
products," the CIAA stated.
The CIAA calls for decisions to be taken on the basis of science. It also calls for changes
requiring only one application for all new foods for different uses with one single assessment, undertaken by the European Food Safety Authority (EFSA).
In relation to proposed new regulations governing additives and enzymes, the CIAA calls on the
bloc to allow for the granting of temporary national authorisations until the proposals are adopted.Â
Otherwise, a lengthy 'stand-by situation' will arise, thereby hindering both product development and continuous market
adaptation," the CIAA warned.
The organisation generally welcomes the package of proposals, which will review andÂ update
the current additives and flavourings legislation and harmonise the safety assessment and authorisation of
The CIAA said it also "strongly supports" the introduction of the comitology procedure for all
technical provisions and a centralised risk assessment
process, to be undertaken by the European Food Safety Authority (EFSA).
The CIAA also supports the revision of the additives law, which it says rationalises the mechanism
for the authorisation and review of such products and their uses.
The CIAA also supports the proposal to enter all existing authorisations currently in the specific additives
directives into a single annex. In relation to enzymes, the CIAA believes that any conditions on use
of such products should not be set unless there is a recognised technological or food safety limitation.
The CIAA also supports the clarifications made to the scope of the proposed flavourings regulation
and the changes that have been made to the control of
biologically active principles (BAPs).Â
"However, care should be taken that these controls do not remove from the market food and drink products containing herbs and spices
that contribute to high levels of BAPs, but contribute very little to overall dietary intake,"
the CIAA stated.
The CIAA said it has "some concerns" over the removal of the distinction between â€œnature identical" (NI) and
â€œartificialâ€ used on labels.Â
"These categories have been in use for some time and are enshrined in some national and vertical
legislation," the CIAA stated, noting that the proposals would introduce new labelling
requirements. "The decision to treat them in the same way will have considerable impact on the food industry, particularly
where national legislation will have to be changed."
The CIAA called on legislators to clarify the status of smoke flavourings within the scope of the proposal.Â
The organisation said the requirements as drafted
are wholly unworkable.
The Commission proposal to introduce "comitology" as the common authorisation procedure for
food additives, enzymes and flavourings would allow flor the faster authorisation of new substances,
the CIAA said. Comitology refers to an EU proceedure under which a technical committee is
established to make decisions on behalf of the Commission.
In relation to the regulation of nutrition and health claims, the CIAA said it supports the general objective of the
EU law as adopted by the Council on 18 October 2006. It would to establish a harmonised regulatory framework
covering all types of claims, including disease risk reduction ones.
"All claims that are scientifically substantiated and well understood by consumers should be
permitted," the CIAA stated. "The communication of the claim as such, that is the
wording of the claim, should remain the responsibility of the food operator. "
The CIAA called on further work to focus on the development of a nutrient profiling scheme by EFSA.
The association also called for the setting of nutrient profiles at the Community level and not at regional or national
level. A list of nutrient profiles should be established by EFSA on the basis of scientific contributions gathered but not evaluated by
In relation to a regulation on the addition of vitamins, minerals and other substances to foods,
the CIAA supports the Commission decision to base a harmonised regulatory framework forÂ fortified foods on safety
grounds. The European Council adopted a regulation on 18 October 2006 governing fortified
"Consumer safety must be the only criterion for the setting of maximum levels for the addition of vitamins
and minerals to foods," the CIAA stated, noting that it is preparing a policy position on
In relation to a proposed revision of the European legislation on labelling, the simplification of existing legislative measures
should not be too prescriptive and not too detailed, so as to leave room for operators to adapt to changing
consumer needs and interests, the CIAA stated.
Future measures should also reduce administrative burdens by allowing for different means to provide information to consumers.
In terms of the European Commission's current focus on bringing down obesity, the CIAA is calling
on regulators not to focus exclusively on industry.Â
"Any intervention must be evidence-based and will require the involvement of several sectors due to the multifactorial nature of the
problem," the CIAA stated. "Commission policy initiatives that focus solely on food and
food manufacturing will not be effective in addressing all the different causes and factors related to overweight,
obesity and chronic diseases."
The CIAA believes that a Commission green paper on the issue does not assign sufficient importance
to physical activity and its role with regard to the
prevention of chronic diseases and health issues.Â
"CIAA strongly believes that improved public health education on nutrition and healthy lifestyles is urgently
needed in order to solve current health problems," the organisation stated.
Membership of CIAA is made up of 24 national federations, including two observers. There are 32 EU sector associations, 21 major food and drink companies grouped together in a liaison committee.
The second part of this two-part series covers the CIAA's strategy in lobbying EU legislators during the upcoming year on environmental policies and international trade issues.Â