Response by the European Commission to comments by WTO Members on the traceability and labeling of GMO foods and feed

July 29, 2002

Geneva, 26 July 2002

Committee on Sanitary and Phytosanitary Measures
Committee on Technical Barriers to Trade
Response from the European Commission to comments submitted by WTO Members under either or both G/TBT/N/EEC/7 and G/SPS/N/EEC/150

Full text

(Proposal for a Regulation of the European Parliament and of the Council on traceability and labeling of genetically modified organisms and traceability of genetically modified food and feed - COM(2001) 182 final)

I. Introduction

II. Notification under SPS

III. Objective of the proposal

IV. Scientific basis for traceability

V. Traceability guarantees food safety

VI. Traceability and monitoring

vii. Traceability of feed

viii. Presentation of the proposal

ix. Implementation of traceability

  • Implementation is difficult
  • The proposal is not workable, enforceable and would be very costly to implement
  • The use of batch numbering systems
  • Costs of traceability
  • Discrimination of processing aids
  • Unique codes
  • Technical guidance on sampling
  • X. Other concerns
  • Labeling requirements
  • EU food producers have shifted away from GM sources
  • Legal uncertainty and non-compliance costs
  • Fraudulent claims in documentation
  • Specific concerns of the United States
  • Link to the bio-safety protocol
  • Separation of GM foods and Novel Foods
  • Linkages between the two proposals
  • Alternative measures
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