FSA Consultation Letter, 14 March 2006
We seek your views and comments on the European Commission's consultation document on labelling.Responses are requested by: 5 May 2006
For a copy of the Commission's Consultation Document, see: Labelling: Competitiveness, Consumer Information and Better Regulation for the EU
The key points in this consultation are:
The attached paper ‘Labelling: Competitiveness, Consumer Information and Better Regulation for the EU' is a consultative document from the European Commission. It forms part of the EU review of labelling. This document explores the broad approach to labelling of both food and non-food products. It also addresses particular labelling issues such as country of origin labelling and the labelling of alcoholic drinks. The Commission will take into account the outcome of its consultation in drafting proposals for legislation, which are expected, along with an impact assessment, in 2007.
The European Commission's paper covers areas of policy outside the Food Standards Agency's remit. These include health warnings on alcoholic drinks, welfare labelling, labelling of non food products, some origin labelling provisions and labelling of some types of alcoholic drinks. The Department of Health, the Department of Trade and Industry, and the Department for Environment, Food and Rural Affairs have agreed that the Agency should co-ordinate the public consultation on this document and that they will consider any responses received that relate to their policy areas before agreeing the Government response. Responses on all these points should therefore be sent to the Agency.
Responses should be structured to match the questions listed in Annex A. [See Annex A]
The rationale for labelling legislation
In paragraphs 7–12 of the document the Commission sets out its thoughts on the overall approach to labelling.
The Commission identifies, in paragraphs 11 and 12, a need to re-examine how far its current approach to labelling meets the objectives set out in its overall approach and poses a number of questions. Stakeholders are requested to provide their views and the rationale for those views.
The future Scope and Structure of Food Labelling Legislation
Paragraphs 16–21and 25–26 of the Commission's paper focus on the future structure and scope of general food labelling legislation.
Paras 23–24 relate to the labelling of alcoholic drinks. The Commission concludes from consumer research that consumers have little interest in ingredient listing on alcoholic drinks except to identify where ingredients have been added to ‘natural' products. They further propose that the only substances that may need labelling are allergens, and possibly food improvement agents. They also raise questions about alcopops.
The Commission notes in its discussion document that there is a general consensus within the EU that the current system of nutrition labelling needs to be improved. There is, however, currently no agreement on the best way forward. The Commission is seeking views on a number of issues relating to the future of nutrition labelling.
The Agency previously responded to the 2003 Commission consultation on nutrition labelling issues. These responses reflected comments from a range of UK stakeholders.
The Agency would appreciate comments from UK stakeholders on the following questions, on which the Commission is now seeking views:
Paragraphs 29–31 of the paper details the apparent mismatch between the current legislative requirements for origin labelling and consumer demand as evidenced by Commission research.
The Commission suggests a number of ways forward (paragraph 32) including mandatory origin labelling on all foods at either Member state/EU/Third country level or at EU/Third country level, setting out a procedure for the approval of request for mandatory origin labelling for specific foodstuffs, or to focus ensuring that existing country of origin requirements are more transparent for consumers.
Health warnings on alcoholic drinks
The EU Commission seeks comments on the possibility of health warnings on alcoholic drinks. This is described as ‘evidence gathering' and does not constitute a proposal for action by the Commission.
The Alcohol Harm Reduction Strategy for England , published in March 2004, tasked the Department of Health with exploring with the EU Commission the possibility of regulatory action to secure health warnings on labels and packaging.
Within the UK , the Alcohol Industry's Social Responsibility Standards, published in November 2005, contain a commitment to a voluntary agreement with Government to include a ‘sensible drinking message' on labels, packaging, advertising, and at point of sale. Implementation of this agreement is currently under discussion.
In responding to the Commission's request, the Department of Health suggests that comments should aim to cover:
Labelling of non-food consumer products
The discussion on non-food labelling in paragraphs 43–45 provides a very basic outline of the issues and existing work in this area, and seems unlikely to be an adequate basis for new proposals. However, if consultees have any concerns about any initiative which might be implied by paragraph 45, we should be grateful to know about these concerns.
Discussions on the Commission's proposal on origin labelling should in any case continue through existing channels, and those stakeholders already engaged on the issue need not respond separately to this consultation. Anyone who is interested in the Commission proposal, but has not yet made their views known to appropriate representative bodies or to the Department of Trade and Industry, should contact John Lane at the DTI (firstname.lastname@example.org or 020 7215 5402).