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Consideration of Labelling Provisions in Codex Standards[2] (Agenda Item 4)

Draft Standards for Milk and Milk Products

14. Some Delegations and the Observer from Consumers International stressed that it was premature to endorse the labelling provisions in these standards in view of the recommendation to redraft the Code of Principles for Milk and Milk Products as a standard and in view of the close link between the Code and the standards. They also highlighted a number of inconsistencies across all standards, especially differences in the expression of fat content and deviations from the General Standard for the Labelling of Prepackaged Foods in the declaration of ingredients; as a number of issues remained to be resolved, the standards needed further consideration as a whole and their adoption might be delayed.

15. Other delegations noted that there had been consensus in the CCMMP on the technical content of the standards, and on the need to finalize them in view of their importance for international trade; while additional clarification could be sought from the CCMMP on the rationale for specific deviations from the General Standard, consideration of labelling provisions should not delay the adoption of the standards.

16. The Committee agreed to the proposal of the Delegation of New Zealand to harmonize the wording of the Sections on Labelling of Non-Retail Containers in all standards as follows:

"Information specified in sections 4.1 to 4.8 of the General Standard for the Labelling of Prepackaged Foods, and, if necessary, storage instructions, shall be given either on the container or in accompanying documents, except that the name of the product, lot identification, and the name and address of the manufacturer or packer shall appear on the container [A-6 and A-7; and in the absence of such a container, on the cheese/whey cheese itself]. However, lot identification, and the name and address of the manufacturer or packer may be replaced by an identification mark, provided that such a mark is clearly identifiable with the accompanying documents."

17. The Delegation of Slovakia expressed the view that the Declaration of Milkfat Content should generally refer to "mass fraction in percentage" instead of "percentage by weight" in all relevant standards.

Draft Revised Standard for Cheese - Draft Revised Standard for Whey Cheese

Draft Standard for Cheeses in Brine

18. The following issues were identified as requiring further consideration:

- designation of cheese: potential conflict between the first and second sentences in section 7.1;

- inconsistency in the wording of Section 7.1.2 as compared with similar sections of other standards (reference to "all animals");

- declaration of the country of origin (7.2) in relation with the General Standard for Labelling;

- discrepancy between the expression of milkfat content (7.3) for cheese and for other dairy products, including butter;

- exception in date-marking requirements for ripening cheese (7.5) (indication of date after ripening).

19. The Delegation of Norway expressed its opposition to the use of three alternatives for the declaration of milkfat content and suggested that only the declaration as a percentage by mass should be allowed; this should apply to all cheese standards.

20. Several delegations pointed out that the definition of "low fat" for cheese (Section 7.3) differed from the conditions set out in the Draft Guidelines for Use of Nutrition Claims, although the Committee had reasserted the general applicability of the Guidelines.The Committee noted that the general comments made for the cheese standards also applied to the other standards under consideration.

Draft Revised Standard for Butter - Draft Revised Standard for Milkfat Products

21. The Committee had no specific comments on the Draft Standards for Butter and for Milkfat Products.

Draft Revised Standard for Evaporated Milks

Draft Revised Standard for Sweetened Condensed Milks

Draft Revised Standard for Milk and Cream Powders

22. The Delegation of the United Kingdom expressed the view that no exemption from ingredient declaration should be allowed for protein adjustment (7.3) as this was a major deviation from general labelling principles and did not allow for adequate consumer information. The Delegation of France and the Observer from IDF pointed out that the CCMMP had provided specific technical justification for this exception and that detailed labelling would not necessarily provide accurate information to the consumer in the case of protein adjustment.

Status of the Labelling Provisions in the Draft Standards for Milk and Milk Products

23. The Committee agreed that as important issues remained to be addressed, the labelling provisions in the draft standards for milk and milk products referred to in paras. 15 to 22 could not be endorsed at this stage. The CCMMP should provide further clarification on the issues identified above and review the standards accordingly.

Other Labelling Provisions: Milk Protein Products

24. The Committee agreed that the class names for "milk protein products" and "milk protein" as defined by the CCMMP, should be included in the list of class names in the General Labelling Standard (Section 4.2 List of Ingredients - sub-section 4.2.2.1).

Status of the Proposed Draft Amendment to the General Standard on the Labelling of Prepackaged Foods

25. As it was noted that the Accelerated Procedure was applicable in the case of revisions of standards, and in view of the non-controversial nature of the amendment, the Committee agreed to circulate the Proposed Draft Amendment, as included in Appendix V, at Step 3 of the Accelerated Procedure, subject to confirmation by the Commission.

Proposed Draft Code of Principles for Milk and Milk Products (Article 4 - Milk Products)

26. The Delegation of Canada, supported by the Delegation of the United States, proposed to delete the last sentence in order to allow the use of standardized cheese names when their composition had been modified. Many delegations, however, strongly supported the view that for cheese subject to individual standards, the product name should apply only to products conforming with the standard. The Committee could not come to a consensus on this question at this stage.

Draft Standard for Canned Bamboo Shoots

27. The Committee endorsed the labelling section as drafted by the CCASIA, while noting that this draft standard would be further developed by the Committee on Processed Fruits and Vegetables.

Draft Standard for Salted Dried Anchovies

Draft Standard for Crackers from Marine and Freshwater Fish, Crustacean and Molluscan Shellfish

28. The Delegation of Thailand, supported by the Delegation of the Philippines, proposed that no reference should be made to scientific names in the labelling and that only common names should be used for both standards. The Delegation of Japan, however, expressed the view that common names differed considerably from one country to another and that it was preferable to use scientific names for clarification purposes.

29. The Committee agreed that this question should be addressed by the Committee on Fish and Fishery Products in view of its responsibility for further development of both draft standards, initially prepared by the CCASIA.

Draft Revised Standard for Natural Mineral Waters

30. Some delegations recalled that the Committee had not been able to come to a consensus on the definition of the claim for "natural" and proposed that the use of this term should not be made mandatory in the name of the product. They pointed out that mineral waters labelled as "natural" might appear to be of a higher quality and could therefore mislead the consumer. Other delegations expressed the view that "natural" was not used as a claim or qualifier in the case of natural mineral waters, but was part of the product name itself and did not require to be defined. This was also reflected in the terms of reference of the Committee on Natural Mineral Waters. The Committee noted that general issues relating to the draft standard and the mandate of the CCNMW would be addressed by the Commission at its forthcoming session.

31. Under 6.3 Additional Labelling Requirements the Delegation of Canada noted that a minimum mineral content was not defined in the draft standard; accordingly it proposed that a declaration of mineral contents should be required, especially in view of consumers' concerns on sodium contents. Some delegations stressed the need for consistency in the approach to health claims and proposed to delete section 6.4.1 as no exception should be made for mineral waters; in accordance with the General Guidelines on Claims, such matters should be left for national authorities to regulate. The Committee could not come to a consensus on these points. It was brought to the attention of the Committee by the Delegation of Switzerland that, in the report of the CCNMW (ALINORM 97/20), agreement was recorded on all points of the labelling section, excepting section 6.4.1.

32. The Committee recognized that a number of issues in the labelling section of the Draft Standard for Natural Mineral Waters remained to be addressed and agreed to inform the Commission of the concerns raised at the present session. The Committee could not reach a consensus on the labelling provisions of the Draft Standard.

Proposed Draft Standard for Fat Spreads and Blended Spreads

33. The Delegation of the United Kingdom pointed out that the use of comparative nutrition claims such as "reduced fat" should be allowed in conformity with the Draft Guidelines for Use of Nutrition Claims, and not exclusively as an alternative to the terms "three quarter" or "half". While noting that this point should be brought to the attention of the Committee on Fats and Oils, the Committee agreed to endorse the labelling section as drafted.


[2] CX/FL 97/3, CRD 3 (Consumers International), CRD 4 (Comments of New Zealand), CRD 5 (comments of Canada) CRD 7 (comments of India)

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