Agenda Item 5(b)
MCX/FL 00/6

Twenty-Eighth Session
Ottawa, Canada, 9-12 May 2000
Recommendations For The Labeling of Foods Obtained Through Biotechnology (Proposed Draft Amendment to The General Standard For The Labeling of Prepackaged Foods)

Draft Discussion Document - Section 5
(At Step 3 of the Procedure)










国連消費者保護ガイドラインにあるように、消費者は「個人の願望や必要に応じた選択をするための情報」を得る権利がある。(1985年4月16日、国連消費者保護ガイドライン、一般原則, section II(3)(c))この権利は、食べ物を選択する際に特に重要である。消費者はその食べ物がどのように生産されたか、例えば、有機、冷凍、フリーズドライ、ナチュラル、缶詰、殺菌、食品照射などを考慮に入れて選択している。消費者は、遺伝子操作されているかどうかに関しても同様に知る権利がある。表示部会は消費者の知る権利を尊重した規格をつくらなければならない。


Specific Comments on Section 5 - Additional Mandatory Requirements

Option 1: (3)

「従来の食品と[同様でない場合] [著しく異なる場合]のみに表示を義務づける」オプション1に反対する。表示は販売後調査と消費者の知る権利のためのものであり、表示の分野で実質的同等の概念を使用することには反対である。

Option 2: (13)1





(20) 4



(24) 8 ["[モダン] プラントバイオテクノロジーによる種から育てられた], (f) [プラント/動物バイオテクノロジーによる生産物], (I) [遺伝子技術による生産物] は消費者にとってわかりにくいので、削除する。

(24) 8 (h), ["食品および原材料名 (分別されていない遺伝子操作食品および遺伝子操作技術)"] 例 「大豆(遺伝子操作大豆と分別されていない)」は削除する。「分別されていない」という言葉は消費者にとって有用ではなく、このような表示によって販売後調査を行うことも難しくなる。




IACFO favors comprehensive labeling for foods and food ingredients derived from biotechnology. Labeling should not be a substitute for safety; every genetically engineered food and food ingredient must be demonstrated to be safe before it is offered to consumers. Yet, even assuming that genetically engineered foods are as safe as conventional foods, comprehensive labeling is essential for the following reasons.

Post market surveillance and traceability

At the intergovernmental task force for food derived from biotechnology from March 14 to 17, 2000 in Japan, many delegates stated that a system of post market surveillance must be instituted to maintain consumer confidence and ensure the safety of genetically engineered foods. Such surveillance is necessary to build and maintain consumer confidence. For example, while the safety of pharmaceuticals is determined prior to marketing, long term monitoring is conducted to ensure that such products are safe. Similar monitoring should be conducted on genetically modified food and ingredients.

One aspect of post market surveillance involves conducting epidemiological studies to compare sub-populations who have eaten and not eaten genetically modified foods. Such studies, however, cannot be conducted unless consumers can identify whether or not they have eaten such foods. Thus, the provision of adequate labeling is an integral part of performing post-market surveillance studies. Another aspect of post-market surveillance involves traceability. While this matter is being discussed by the intergovernmental task force for food derived from biotechnology, CCFL must consider the issue at this time because traceability and labeling are so closely related. Without adequate labeling, it is often difficult to trace the source of a substance in food. Specific requirements for post market surveillance will be discussed at the intergovernmental task force for food derived from biotechnology. However, because such surveillance cannot efficiently be conducted without adequate labeling, CCFL must take this matter into account at this time as it develops labeling standards for generically modified foods.

Consumer Choice

As recognized by the United Nations Guidelines for Consumer Protection, consumers have a right to know adequate information to enable them to make informed choices according to individual wishes and needs. United Nations Guidelines for Consumer Protection, General Principles, section II (3)(c),16 April 1985. This right is perhaps no more important than in choosing what foods to eat. Consumers often choose food products on the basis of how they are produced, e.g. whether they are organic, frozen, freeze-dried, natural, canned, pasteurized, or irradiated. Certainly consumers have right to know whether a food has been genetically modified. CCFL should develop standards for genetically modified foods that respect consumers' right to know information.

Moreover, many consumers may take environmental issues (such as harm to wildlife or promotion of pesticide resistant weeds) into consideration when choosing whether to consume genetically modified foods. Other consumers may wish to take religious or ethical consideration into account when deciding whether to consume such foods. CCFL has developed standards for the labeling of foods meeting Halal dietary requirements and should consider religious and ethical factors in this area as well.

Specific Comments on Section 5 - Additional Mandatory Requirements

Option 1: (3)

We do not agree with option 1 which specifies that labeling is applied only for food and food ingredients which [is no longer equivalent to]/ [differs significantly from] the corresponding existing food or food ingredients.? We do not support use of the concept of substantial equivalence in this area because we believe that labeling is necessary to conduct appropriate post market surveillance and to address the consumers' right to know information.

Option 2: (13)1

We support Option 2. However, we note that methods for detecting genetically engineered substances will be discussed by a working group of the intergovernmental task force for food derived from biotechnology. Detection methods are continually improving and it is important to update labeling requirements based on such changes. We thus recommend that the following sentence be added after the second bullet dot in Option 2: These requirements should be periodically updated based on improvements in detection methods.

In addition, we urge CCFL to retain the following two items in the text of the proposed standard, because such requirements are important to protect the health of consumers.

(19) 3. [The presence of substances that are absent in corresponding existing foods that may have implications for the health of certain sections of the population shall be labeled]

(20) 4. [When it is not possible to provide adequate information on the presence of an allergen through labeling, the food containing the allergen should not be marketed]

With regard to (24) 8, we urge that the following statement be added after the statement "[The following label declaration(s) [should]/[may] be used to identify the presence of food or food ingredients obtained through modern biotechnology,"

"The identification number of the inserted gene should be disclosed in cases where it is necessary to facilitate trace back of the specific source of the genetically engineered material."

We further urge that (24) 8 ["Grown from seeds from [modern] plant biotechnology"], and (f) [product of plant/animal biotechnology"], (I) ["product of gene technology"] be deleted because they may be confusing to consumers.

We lastly urge that (24) 8 (h), ["Naming the food/food ingredient (genetically modified food/food ingredient not segregated)"] e.g. "soybean (genetically modified soybean not segregated)" be deleted. The term "Not segregated" is not useful for many consumers. Furthermore, the use of these statements would interfere with the ability to conduct appropriate post-market surveillance studies.