Current Status of Food Traceability in European Union

Willy De Greef

IBRS

Traceability in food production is not a new policy tool

• Traceability as such is a useful and proven tool in food safety management;– The management of bacterial contamination in perishable food– Management of the European Mad Cow disease crisis

• It is also legitimately used to ensure consumer choice regarding methods for food production and farming;– Religious demands related to food preparation– The food chain integrity for organic farming products

So why is it contentious in the GMO context?

Grounds for GM food traceability

• European traceability rules are intended for food safety management AND for consumer choice.

• This dual purpose has created an unwieldy regulation which has proven difficult to apply and unsatisfactory for some consumers

The relevant regulations

REGULATION (EC) No 1830/2003 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

of 22 September 2003 concerning the traceability and labelling of genetically modified organisms and the traceability of food and feed

products produced from genetically modified organisms and amending Directive 2001/18/E

REGULATION (EC) No 1829/2003 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

of 22 September 2003 on genetically modified food and feed

The objective of the regulations

Article 2: Scope1. This Regulation shall apply, at all stages of the placing onthe market, to:

(a) products consisting of, or containing, GMOs, placed on themarket in accordance with Community legislation;(b) food produced from GMOs, placed on the market in accordancewith Community legislation;(c) feed produced from GMOs, placed on the market in accordancewith Community legislation.

2. This Regulation shall not apply to medicinal products forhuman and veterinary use authorised under Regulation (EEC)No 2309/93 (2).

Practical problems

• Labelling of foods which do not contain any GM genes or expression products

• No labelling of animal products

• Tracing agricultural commodities through international trade

• Testing and identification

• The possibility of fraud

Tracing and labelling foods which do not contain GM genes or expression products

• Many processed foods do not contain traces of genes or proteins;

– Examples: • Refined oils and fats• Refined sugar and starch

• It is impossible to test whether they have been obtained from GM or conventional crops;

• Traceability for labelling requires a paper trail which in these cases cannot be policed by detection

No labelling of animal products

• There is no requirement for labelling animals which have been fed with GM feed

• This is inconsistent with the traceability and labelling requirement for plant products obtained from GM crops

• Justification: impossible to find traces of GM feed in animals• ! This labelling rule does not exempt animal feed from traceability

requirement!

Tracing agricultural commodities through international trade

• The EU traceability directive has created significant problems for agricultural exporters elsewhere

• Thresholds for exemption: – 0.9% for GMOs which have been approved by the EU GM food/feed

regulation

– 0% (!) for GMOs which have not been approved

This is why technology developers continue filing food/feed registration packages for new GM crops

Testing and identification

• The traceability and labelling regulations require a detailed and technically demanding system for testing and identification of GM crops

• The testing system has to be event-specific, to allow differentiation between approved and non-approved GMOs.

• The

The possibility of fraud

• The tracing and labelling requirements for products in which no GM can be detected is an invitation for fraud, if there is a price difference

• The absence of large differences between GM and non-GM commodities suggests that much food export to the EU does not comply with the regulations

Unofficial regulators

• In practice, traceability of food and feed has been policed by the purchasing policies of European supermarkets, more than by government policy

• Many supermarket chains put more stringent rules on traceability than EU policy requirements

Confusion among many food and commodity exporters

The problem of partial approvals

• The different treatment of EU-approved and other GM events leads to confusion among technology developers and the food chain:

– Approved events: 0.9% exemption from traceability and labelling

– Non-approved events: 0%

– What with events approved by scientific committee but not by policy makers? (this is the most common case today)

• EU regulatory system is only partially science based: the scientific review system leads to advice, not decisions.

• Many GM events have successfully passed the scientific review process but are blocked by EU political decision makers