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INTERNATIONAL DEVELOPMENT IN LABELLING OF GM FOODS

Approaches on GM Food Labelling

International Practices on GM Food Labelling

Pros and Cons of Major Labelling Approaches

Issues to be Considered in Setting Up a Labelling System

Approaches on GM Food Labelling

The regulatory approaches on GM food labelling vary in different countries and areas, and can be broadly classified as voluntary or mandatory.

For the voluntary labelling approach, only GM food that is significantly different from its conventional counterpart, in terms of composition, nutritional value and allergenicity, needs to be labelled.

For the mandatory labelling approach, it can be further classified as two categories, i.e. "pan-labelling" or "labelling for designated products only". The "pan-labelling" category requires that any food products, which contain GM materials exceeding a threshold level or have any significantly different characteristics as a result of genetic modification, must be labelled. The "labelling for designated products only" category requires that only the designated products, which are genetically modified, need to be labelled.

International Practices on GM Food Labelling

The international community is working towards a consensual policy on GM food labelling. However, the Codex Alimentarius Commission of the United Nations is unlikely to be able to set internationally agreed standards in near future. At present, policies on GM food labelling vary in different countries and areas:

1) Canada and the United States

Labelling of GM foods is only required when the food is significantly different from its conventional counterpart in terms of composition, nutrition and allergenicity. However, the trade may label other GM foods on a voluntary basis. In Canada, a set of guidelines for voluntary labelling of GM foods has been issued in April 2004. While, in the United States, public consultation on draft guidelines for voluntary labelling has been finished but finalisation of the guidelines is still pending.

2) Member countries from the European Union

All GM foods have had to be labelled in countries of the European Union since 1998. This policy was amended by the European Commission in November 2003. The new requirement stipulates that all foods produced from Genetically Modified Organisms (GMOs) should be labelled, irrespective of whether DNA or protein of GM origin is detectable in the final product. Moreover, conventional foods with adventitious presence of GM materials of higher than 0.9% should also be labelled.

3) Australia and New Zealand

The Australia and New Zealand authorities decided that all food products produced or imported had to be labelled starting from 7 December 2001 when any of their ingredients contains more than 1% GM material. Additional labelling was also required for GM food ingredients with significantly altered characteristics. Highly refined foods, processing aids or food additives with the absence of GM materials, flavours in a concentration no more than 1g/kg in the final food, as well as foods prepared at point of sale are exempted from the GM food labelling requirement.

4) Japan

The Japanese authorities have required designated agricultural products and processed food items containing GM materials to be labelled. For the processed food items, those ingredients containing GM materials that are ranked within the top three constituents in terms of weight and the weight ratio of which account for five percent or more of the total weight have to be labelled. Labelling is not required for oil and sauce, where the original GM materials can no longer be detected.

5) Republic of Korea

The Korean authority requires that all approved genetically modified agricultural products (including bean sprout originated from approved beans and other sprouts), which contain more than 3% GM materials have to be labelled. In addition, processed foods which contained these approved GM products as one of the top five ingredients were required to be labelled.

6) Taiwan

In Taiwan, mandatory labelling of designated foods has been implemented by three phases according to degree of processing of the food products, and the last phase has come into effect from January 2005. Under the labelling requirement, foods containing ingredient of GM soya bean or corn which is more than 5% total weight of the finished product have to be labelled. Moreover, soya bean or corn, which is adventitiously or accidentally mixed with not more than 5% of GM varieties during harvest, storage, transportation or other reasonable causes, is regarded as "non-GM". Food products made of non-GM soya bean or corn may be labelled as "non-GM" or "not-GM".

7) Mainland China

The Ministry of Agriculture enacted a regulation "Implementation Regulations on Labelling of Agricultural Genetically Modified Organisms"《農業轉基因生物標識管理辦法》which was effective on 20 March 2002. Under the regulation, five categories of GM crops including soya bean, corn, cotton, rapeseed and tomato, as well as some of their products are required to be labelled. On the other hand, the Ministry of Health enacted a regulation, "Measures for the Administration of Novel Foods" 《新資源食品管理辦法》, on GM food on December 2007. This regulation stipulated that all GM foods should be properly labelled.

8) Other places in Asia

Some other Asian countries such as Thailand and the Philippines have also set up regulations on GM food labelling.

 

Pros and Cons of Major Labelling Approaches

Voluntary Labelling Approach

  1. Pros
  • Appropriate labels on GM foods which are significantly different from their conventional counterparts help to alert consumers of their differences in terms of allergenicity, nutrition and toxicity. Therefore, this labelling approach addresses the basic concerns of most consumers and hence safeguards public health against any potential risks.

  • This approach imposes fewer barriers and constitutes less trade implications. It is adopted by some GM crops producers and also our important trading partners such as the United States and Canada. These countries may protest against labelling requirement (e.g. pan-labelling of all GM foods) that is more stringent than labelling of GM food with significantly different characteristics as unnecessary barrier to international trade.

  • This labelling approach would not significantly affect the cost of food production.
  1. Cons
  • Consumers would not know whether the food contains any GM materials. This labelling approach hence limits their rights to "informed choices". Some consumers would like to make their choices not only based on food safety grounds but also taking environmental, social or ethical issues into consideration.

Mandatory Labelling Approach

  (i) "Pan-labelling"    
     
  a. Pros    
       
  • Labelling of all GM foods enables consumers to know whether the food contains any GM materials at all and hence make informed choices.
  • Moreover, it helps to enhance surveillance and tracing on GM food.
  b. Cons      
 
  • additional costs to the trade would be incurred. However, these costs would either be absorbed by the trade or passed on to the consumers and hence the extent of any price changes due to labelling GM food is uncertain. Additional costs of labelling GM food may arise from:
   
1.
At present, GM crops/foods and non-GM crops/foods are often mixed together during harvesting, storage or processing. It would be necessary to establish a system to segregate these crops along the food supply chain, especially when the trade would like to source for non-GM food products. Hence additional cost would be incurred to establish and maintain segregation systems.
   
2.
The detection and identification of GM foods, which require sophisticated laboratory tests, might also incur additional cost.
 
  • The requirement to label all GM foods is not easy to enforce because:
1.
The Codex Committee on Methods of Analysis and Sampling under Codex Alimentarius Commission is still working towards the harmonisation of testing methods for GM food. Besides, not all GM food products are readily identifiable by end-product analysis.
   
2.
Adventitious mixing of GM and non-GM crops may occur during processing and storage, hence establishment of threshold level may be necessary to determine whether the batch of food product is GM or not. However, there is no international consensus on threshold level for GM food labelling.
       
  (ii) "Labelling for designated products only"    
       
  a. Pros    
       
  • Labelling for designated food products enables consumers to know whether the designated food items contain any GM materials and hence make informed choices.
  • Moreover, this labelling requirement is possible to be enforced.
       
  b. Cons    
       
  • It might not address the need of consumers who would like to know whether the non-designated food items contain any GM materials or not.
  • Additional costs might be added to the designated food items.

The pros and cons of the above labelling approaches are summarised below:

 
Mandatory Labelling
 
Voluntary Labelling
Pan-Labelling Labelling for designated products only
Pros
  • Alert consumers to special dietary advice on allergenicity, composition or nutrients.

  • Little international trade implications.

  • Do not impose significant additional costs to food production.
  • Inform consumers about whether the food contains any GM materials.

  • Enhance surveillance and tracing on GM food.

  • Inform consumers about whether the designated food items contain any GM materials.

  • Possible to enforce this labelling law.
Cons
  • Might not address the need of consumers who would like to know whether food contains any GM materials at all, so as to make informed choice.

  • Additional costs to the trade, which may be absorbed by the trade or passed on to the consumers.

  • Difficult to enforce because of the limitation of detection methods for GM foods.

  • Might not address the need of consumers who would like to know whether the non-designated food items contain any GM materials or not.

  • Additional costs might be added to the designated food items.
Countries adopting the approach e.g. Canada and the United States e.g. European Union, Korea, Australia and New Zealand e.g. Japan, Taiwan and Mainland China

Issues to be Considered in Setting Up a Labelling System

Different labelling approaches have their merits and shortcomings. Issues to be considered in setting up a practical and balanced labelling system include:

Limitation of Detection Methods

Difficulties in detection of GM materials include:-

  • At present, there is no international consensus on analytical method for detection of GM food.

  • Not all GM food products can be identified by end-product analysis.

  • Detection methods for highly processed foods e.g. soy lecithin are less sensitive and reliable when compared with raw or lightly processed foods, e.g. tofu (soy).

  • For highly refined food items such as oil and sugar, it is impossible to detect the presence of any GM materials.

  • There is no single test that can be used to detect all types of GM materials.

Present Practices of the Food Supply Chain

Since GM and non-GM crops are often mixed together during harvest, transportation, processing and storage, it is difficult to determine the GM status of the respective crops/foods. Therefore, a system to segregate GM and non-GM products at various stages of processing along the food supply chain needs to be set up and maintained.

Costs of Compliance

The costs of compliance with GM food labelling requirement will either be absorbed by the trade or passed on to the consumers and hence the extent of any price changes due to labelling of GM food is uncertain in the short run.

International Practices

At present the Codex Alimentarius Commission, the authority for setting food-related standards under the United Nations, is working on establishing an internationally agreed standard for GM food labelling.

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