Food safety

White Paper On Food Safety

General Remarks
The Bund für Lebensmittelrecht und Lebensmittelkunde e.V. (BLL), the leading association of the German food industry, representing members from all sectors of food production, agriculture, grocery trade, industry and retail trade, welcomes the Commission's White Paper as an important contribution to the discussion about increasing consumer confidence in food; it must now be followed by detailed consultations.

There is a plethora of reasons for reduced consumer confidence in food safety and legislation: general crises, both BSE-related and otherwise, supposed and genuine food scandals, the discussion of the genetic modification of food and, not least, the bewildering nature of regulatory and monitoring mechanisms at community level. What makes this development all the more unsatisfactory is that both food quality and safety are on a higher standard than ever before, so that declining consumer confidence is inversely proportional to the actual state of affairs. Problematic individual cases, which should neither be glossed over nor generalised, foster doubts on the part of public opinion with regard to food safety and quality.
This situation must be countered with all possible means. Therefore the German food industry fundamentally supports the efforts of the Commission to contribute to this process with the White Paper.

Like the Commission, we wish to emphasise that the European food-production chain is among the safest in the world, and that the current system is generally working well. However, there are areas in which improvements are both possible and necessary in order to modernise existing Community food law, to make it more coherent, more intelligible, more flexible and hence safer.

The most important objectives of European food-law policy should include the following points:

  • protection of public health with regard to food safety
  • restoration of public trust in food safety and the relevant European protection mechanisms
  • efficiency of the internal market with regard to foodstuffs
  • fostering of innovation throughout the European food industry.

The compilation of a regular report on food safety in Europe could provide indicators as to the areas in which deficiencies still exist and where there is a need for improvement.

The action programme proposed by the White Paper contains a comprehensive package of measures in various fields; whilst some are in our view very well justified, others need examination and careful consideration. The Commission has set an extremely tight schedule for 84 regulatory measures, which - experience suggests - is unlikely to be met if the quality and legal certainty are to be ensured (see also Report of the Commission of the European Communities to the European Council: "Better legislation 1999" (KOM(99) 562 final; council document 13725.99). It is thus necessary to set priorities, clarifying fundamental questions first in order to create a coherent regulatory system on the basis of generally-agreed principles and legislative and administrative structures that are working.

Here again, high priority should be accorded to the so-called "basic or framework directive on European Food Law" on the one and to the creation of the European Food Authority on the other hand. This will provide a foundation for adapting the entire regulatory framework to the principles thus established.

It is also important for the revision of the existing regulatory framework to take account of the prerequisites of the internal market and of world trade alike, and also to substantially improve the competitiveness of the European food chain.
With regard to consumer information, unfortunately, there are no indications of a new approach. Any thought of tackling new, alternative information channels is conspicuous by its absence. It should however be recognised that with regard to information on foodstuffs, the label is only one and in addition a means of information with limited capacity. Therefore, alternative channels for providing consumer information should be sought and exploited, thereby preserving the label`s primary function of conveying first source information relevant to the buying decision.

We do just as well regret that there is no new approach to health claims, i.e. to claims conveying information on health-related properties of foodstuffs to be found in the white paper. Whilst specialist circles are generally aware of the fact that a healthy diet and a particular choice of food can contribute to maintaining good health and to reducing the risk of diseases, there is within the present legal framework hardly a way of conveying this information to consumers. It must be the objective of a future-orientated health policy to make sure that consumers are made aware of the aforementioned health properties of foodstuffs. Consequently, the regulatory framework needs to permit statements to the effect that particular dietary practices may contribute to reducing the risk of certain diseases.
Conversely there should be no attempt to draw up European dietary recommendations. Discrepancies in regional dietary habits make this more or less pointless.

Due consideration must be given to the fact that eating habits vary considerably in the respective member states, thus imposing limits on the effectiveness of uniform dietary standards. The special national aspects must continue to be respected in this area.

In view of the activities at European level aimed at drawing up dietary guidelines for the citizens of the European Union, the Scientific Advisory Council of the BLL has formulated propositions which should be taken into account when evolving dietary guidelines on the one hand and disseminating information on food to promote public health on the other hand:

  • dietary guidelines should be target-group-oriented
  • they must be based on findings with a sound scientific basis
  • they must be clear and comprehensible
  • they must take account of the cultural, geographic, historical and religion-based differences in dietary traditions and accord due consideration to taste preferences
  • there is no such thing as healthy or unhealthy food
  • processing measures contribute to the stabilisation of perishable foods
  • foods tailored to requirements help the consumer in choosing the right products
  • on-going dietary information and advice is necessary
  • consumers are responsible for their eating habits
  • the media play a key role in the transfer of dietary recommendations
  • dietary research requires to be intensified
  • European dietary guidelines can only be of a very general nature.

Overall it is clear that the White Paper lacks answers to many of the points for discussion highlighted by the 1997 Green Paper. Many interesting and useful matters raised in the Green Paper are absent from the White Paper. We should thus like to conduct the discussion on a broader basis.
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