Voluntary GM-Free Labelling
April 2003
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2.Why Develop a GM-Free Labelling System?
Summary
This section sets out the key background issues around the
development of a labelling system. These are:
- The Royal Commission on Genetic Modification identified
an "information gap" between the coverage of
Standard 1.5.2 of the Australia New Zealand Joint Food
Code and the information needs of consumers who wish to
avoid food produced using genetic modification.
- The government responded to the Royal Commission's
report by directing an interdepartmental working group to
facilitate the development of a "GM-free"
labelling system (noting that there were technical and
cost barriers to developing a labelling system).
- A key stakeholder meeting was then convened in February
2002, which identified general support for government
facilitation in developing a labelling system.
2.1 Overview: the Role of the Royal Commission on Genetic
Modification
The Royal Commission on Genetic Modification was set up in
May 2000 to investigate, and report on, the issues and options
surrounding genetic modification for New Zealand. A particular
area of public interest focused on by the Royal Commission was
food safety and consumer choice. Within this context, a key
issue the Commission identified for consideration was "can
people choose whether or not to eat genetically modified food?"
The Royal Commission considered the operation of Standard
1.5.2 of the Australia New Zealand Joint Food Code, and
supported the standard's pre-market safety assessment of GM
food. It also supported the Code's mandatory labelling
requirements, although it noted that some people are concerned
that food not labelled may contain some GM material, or may
have been manufactured using a process involving genetic
modification.
An "information gap" exists under Standard 1.5.2
because there are several exemptions from the mandatory
labelling of GM material or genetic modification processes.
Two of these exemptions are for flavourings and the
unintentional presence of GM material, as long as the amounts
involved do not exceed certain percentage thresholds. If they
exceed these thresholds, then the flavouring or ingredient
would have to be declared on the label. The other exemption is
for food intended for immediate consumption, such as that
available at restaurants, cafes, and take-away, self-vending
and self-catering outlets.
While acknowledging this "information gap", the
Royal Commission accepted that there are cost, testing and
product-tracing barriers that "... mitigate against the
imposition of a mandatory labelling requirement covering not
only the product but the production process".[1]
The Royal Commission did "... consider that a standard
label should be used, on a voluntary basis, to indicate that a
food contains no genetically modified material and has not
been manufactured in a genetically modified production
process".[2] It
recommended:
that government facilitate the development of a voluntary
label indicating a food has not been genetically modified,
contains no genetically modified ingredients and has not been
manufactured using a process involving genetic modification.[3]
In making this recommendation the Royal Commission
contemplated that the "GM-free" label would be
simple and easily recognized - similar to the Heart
Foundation's "Pick the Tick" and would indicate that
a product was "100% free" of genetic modification.
2.2 Government's Response
Government accepted the Commission's recommendation and
directed:
...the Ministry of Consumer Affairs to scope what would be
required for an interdepartmental working group to facilitate
the development of a voluntary "GM-free" labelling
system, and to proceed with the facilitation if it can be
resourced from within baselines.
The government noted that a voluntary "GM-free"
labelling system would complement the mandatory labelling
requirements of Standard 1.5.2. The purpose of the label would
be to help fill the "information gap" for those
consumers who wish to avoid food produced using genetic
modification but which was not covered under the mandatory
Standard. Important technical and cost barriers to the use and
development of a "GM-free" labelling system were
also noted:
- the cost and difficulty of detecting GM material in
processed foods
- the ability of identity-preservation systems to verify a
food's origin
- the willingness and ability of suppliers to standardise
"GM-free" claims.
Cabinet papers relating to the government's response are
available on the Ministry for the Environment's website.[4]
2.3 Scoping Exercise
The Ministry of Consumer Affairs hosted a meeting with key
consumer and industry stakeholders in February 2002 to scope
the issues involved - such as who and what may be involved in
developing a voluntary labelling system. For the purposes of
the meeting, key stakeholders were identified as those that
either represented industry/consumer associations or who might
be in a position to take ownership of a voluntary labelling
system. Appendix
One lists participants at the meeting.
The meeting was not a substitute for consultation with
wider stakeholders. Its role was to allow the
interdepartmental working group to get an overall
"feel" for the issue. Objectives of the meeting
- processes for further work and consultation on the
development of a GM-free labelling system
- issues that will need to be addressed when developing a
voluntary GM-free labelling system and feasible options
for such a system.
Key stakeholder groups expressed their support for the
development of a voluntary labelling system, and for
government's role in facilitating the development of such a
system. But it is indicative of the complexity of the issue
that the meeting did not identify a process for developing the
labelling system. Stakeholders did identify, however, a range
of issuessurrounding the development of a system and these are
discussed in Section 5.
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