G/TBT/GEN/339  
 
13 January  2023 
(23-0352) Page: 1/5 
Committee on Technical Barriers to Trade    
 
THEMATIC  SESSION ON STANDARDS  
(STANDARDS DEVELOPMENT IN CODEX ) 
15 NOVEMBER  2022, 1 5:00-18:00 
Moderator's Report1  
 
At the Ninth Triennial Review, Members agreed to continue to hold thematic sessions in conjunction 
with the TBT Committee's  regular meetings from 2022 to 2024 to further deepen the exchange of 
experiences on specific topics.  On this basis, the Committee ag reed to hold a thematic session on 
standards .2 The first part of the session focused on an overview of the Codex Alimentarius' present 
work on standards . The second part focused on recent  work in the Codex Committee on Food 
Labelling (CCFL) , including on Front-of-Pack Nutrition Labelling and Allergen Labelling . The third part 
of the session consisted of an exchange of experiences by Members highlighting challenges and 
opportunities for participation in the standards setting -activities of the Codex Alime ntarius . 
Information about the speakers, presentations, and related material s is available  on the WTO 
website.3 
 
1  GUIDING QUESTIONS  
• What are the main standard -setting activities undertaken at the Codex Alimentarius 
Commission that have relevance in the are a of technical barriers to trade?  
 
• What are the main challenges and opportunities for the participation of members in the 
standard -setting activities of the Codex?  
 
• How can developing countries be supported further in order to increase their 
participation in Codex's standard -setting activities?  
 
• What recent developments in the Codex Committee on Food Import and Export 
Inspection and Certification Systems (CCFICS) are relevant from a TBT perspective, 
including in the area of conformity assessme nt procedures?  
 
• What recent developments in the Codex Committee on Food Labelling (CCFL) are 
relevant from a TBT perspective?  
 
2  INTERVENTIONS  
2.1.  Ms Gracia Brisco  (Codex Secretariat ) presented the Codex Alimentarius Commission's 
structure and main standard -setting activities with relevance in the area of technical barriers to 
trade (TBT). She highlighted that Codex and the TBT Committee support each other's work on, 
among others, protecting consumer s against misleading practices but also in terms of health 
through , for example, nutrition labelling measures and other considerations on nutrition issues . 
Regarding structure, she shared that the Codex Commission has an Executive Committee 
responsible for  providing advice on the adoption of standards developed under the technical 
subsidiary bodies  namely:  (i) Horizontal Committees and Task Forces with a focus on all foods or 
food groups and both SPS and TBT issues; (ii) Vertical Committees with a focus on specific foods or 
 
1 Ms Lorena Rivera  (Colombia ). This Report is provided on the Moderator's own responsibility.  
2 G/TBT/46 . 
3 WTO | Thematic Session on Standards .  G/TBT/GEN/339  
 
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  food groups covering purely TBT topics, such as quality characteristics of the final products; and 
(iii) Regional Coordination Committees to manage regional work and develop regional commodity 
standards which focus on TBT issues. The proc edure for developing standards is  very similar in all 
Committees, relying on consensus for adoption . 
2.2.  Ms Brisco also shared information on certain new areas of work related to conformity 
assessment procedures undertaken by  the Codex Committee on Food Import  and Export Inspection 
and Certification Systems (CCFICS). For example, CCFICS has finalized work on a number of texts 
to facilitate the use of ITC tools such as : (i) Principles and guidelines for the assessment and use of 
voluntary third -party assurance p rogramme (CXG 93 -2021); and (ii) revised Guidelines for the 
design, production, issuance and use of generic official certifications (CXG 38 -2001) to support the 
issuance of electronic certificates between trading countries . She also  mentioned some of the 
ongoing work in CCFICS related to: (i) guidance on  use of remote audit and verification in regulatory 
frameworks; (ii) consolidation of equivalence texts for more consistent application; and (iii) guidance 
on food fraud and broadening the scope of traceabil ity to englobe food control systems.  
2.3.  Ms Verna Carolissen  (Codex Secretariat) presented certain recent  developments in the work 
of the Codex Committee on Food Labelling (CCFL). For example, CCFL  has recently worked on 
elaborating standards for non -retail container labelling  and ways to provide information 
electronically. Other ongoing work focuses on develop ing guidance on e -commerce food labelling  
(e.g. what information should be made available on a product's webpage ) and on the use of 
technologies to provide food labelling information . 
2.4.  Ms Carolissen updated participants on Codex's exploratory work to provide guidance on food 
labelling in emergency situations, such as the COVID -19 pandemic, and o n sustainability claims, for 
example, sustainable production. She also shared information on the ongoing work to make the 
guidance on methods of analysis and sampling  more user -friendly , for example by develop ing 
broader criteria from where stakeholders ca n choose methods of analysis and sampling that suit 
them best . 
2.5.  Ms Kathy Twardek  (Canada)4 explained that CCFL's work on labelling aims to strike a  balance 
between conveying truthful information to consumers, while allowing business es to market their 
produ cts. CCFL 's work focuses on developing standards and guidelines for labelling , which  cuts 
across the work of other Committees  that focus on the definition of composition and nutrition 
labelling claims. Given that CCFL's standards and guidelines are open to  national authorities when 
enacting their legislation, increased participation by members in the standard -setting procedures is 
key to creating standards that are meaningful to all.  
2.6.  Ms Twardek  also informed participants that CCFL recently developed a new standard on front -
of-package nutrition labelling, which can be mandatory or voluntary, and provides valuable guidance 
on how to display nutrition information to help consumers make informed cho ices. She also shared 
that e -commerce and allergen labelling are areas of work on which CCFL made progress recently.  
2.7.  Dr Douglas Balentine  (United States)5 complemented the discussion on allergen labelling  by 
informing participants that CCFL is developing a declaration of allergens and precautionary labelling. 
This work, which is led by Australia with support from the United Kingdom, the United States and a 
group of experts assembled by  the Food and Agriculture Organization  (FAO) and the World Health 
Organi zation ( WHO), aims to develop: (i) a report with recommendations on a priority list of 
allergens; and (ii) guidance on precautionary allergen statements (e.g., the statement " may contain 
peanuts ") to best inform  consumers. This work is of particular intere st to countries that are in the 
process of updating their requirements on allergens . Dr Balentine also highlighted the value of the 
new Codex standard on front -of-package nutrition labelling for countries and regions that wish to 
better inform consumers. G iven the different approaches around the world in the use of labels to 
inform consumers that a product is "high in " sodium, sugar  and other ingredients , the work in Codex 
on the topic is key to preventing barriers to trade . 
 
4 Chairperson of Codex Committee on Food Labe lling (CCFL). 
5 Senior Science Advisor International Nutrition Policy at the United States Food and Drug 
Administration  (FDA). G/TBT/GEN/339  
 
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  2.8.  Mr Rodrigo Martins de Vargas  (Brazil)6 presented on ANVISA's experience in using Codex's 
guidelines to help Brazil develop their front -of-pack nutrition labelling (FOPNL) system. This included 
how the Brazilian authority built on CCFL work to provide simplified nutritional information t o 
consumers. ANVISA set up the Brazilian FOPNL system as mandatory to maximize the availability of 
information to consumers. For consistency purposes, t he FOPNL system also required adjustments 
to the nutrient declaration, which was available and mandatory  since 2006. One key lesson  from 
this experience  was the value of engaging with all interested stakeholders in public consultations at 
an early stage, including the public and private sectors, consumers and academia . 
2.9.  Ms Esther Ngari  (Kenya)7 presented Kenya's experience in conducting national coordination 
activities to participate in Codex Alimentarius Commission's activities. Kenya has a National Codex 
Committee in charge of coordinating Kenya's position in Codex activities. The membership o f the 
National Codex Committee is diverse, which ensures broad participation from the national food 
control system, including the Ministry of Health, Ministry of Agriculture, Pest Control and Products 
Board, Kenya National Accreditation Service, Kenya Plan t Health Inspectorate Service, Kenya Dairy 
Board, the government chemist, national public health labs, Kenya Fisheries Service, and various 
public universities. The National Codex Committee is currently chaired by the Ministry of Health. The 
Secretariat of  the National Codex Committee is the Kenyan Bureau of Standards (KEBS).  
2.10.  Ms Ngari also shared how Kenya has worked in a number of areas to enhance their 
participation in Codex's activities, including by: (i) ensuring that the national Codex contact point 
actively follows Codex's work and engages with domestic stakeholders; (ii) securing political support 
from the Kenyan government to deepen engagement with Codex; (iii) ensuring a specific budgetary 
allocation for Codex coordination activities; (iv) creating dedicated work plans that include Codex 
activities in all the government institutions involved in the food control system; (v) raising awareness 
among public and private stakeholders on the need to understand Codex work; and (vi) conducting 
capacity buildi ng activities for Codex contact points, policy -makers and other national stakeholders. 
She also highlighted the opportunities that have arisen for Kenya through its engagement with 
Codex, including enjoying global market access for exports, aligning nation al policies to 
internationally recognized standards, and safeguarding the health of its people. In terms of 
challenges faced by Kenya, Ms Ngari identified the inadequate engagement by members in the global 
system of food standards and trade; limited engage ment in the TBT committee due to funding 
constraints; and limited coordination between the national consultative committees on Codex, TBT 
and SPS.  
2.11.  Ms Cassandra Pacheco  (Chile)8 presented Chile's experience participating in Codex 
Alimentarius standard -setting activities. Given that Chile does not  yet have the technical and 
financial capability to develop science -based food standards, it relies on Codex standards and 
guidelines that are harmonized and well -recognized internationally. Consequentl y, Chilean food 
regulations are based on Codex standards. In addition, Ms  Pacheco shared good practices to improve 
participation in Codex activities. In particular, she noted that Chile established a National Codex 
Committee mirroring the Codex Alimentariu s Commission subsidiary bodies and also a Codex 
Contact Point and national coordination procedures  for engaging with various stakeholders . In 
addition, Chile actively participates in international Codex standard -setting procedures , which helps 
to ensure th at their national  position s are taken into account . 
2.12.  Mr Malose Daniel Matlala  (South Africa)9 presented South Africa's experience participating 
in Codex Alimentarius Commission's activities , where it has been a member  since 1994. 
South  Africa's participation has sought to contribute to Codex's work and contribute to the 
competitiveness of their industry.  South Africa participates in  Codex's activities , including in 15 
Codex subsidiary bodies,  through three  competent  authorities: the Depa rtment of Health , the 
Department of Agriculture , Land Reform and Rural Development and the National Regulator for 
Compulsory Specifications . In terms of good practices, Mr Matlala highlighted that South Africa has 
improved in their preparation ahead of Cod ex meetings by engaging in early consultations with 
stakeholders, including industry, consumers , research organizations  and academia. The challenges 
faced by South Africa include improving the consistency and continuity of staff attendance to Codex 
 
6 Specialist in Regulation and Sanitary Surveillance  at the Brazilian Health Regulatory Agency  (ANVISA ). 
7 Director , Standards Development and International Trade, Kenya Bureau of Standards . 
8 Agency for Food Safety and Quality , Chile.  
9 Deputy Director , Inter-Agency Liaison and Regulatory Nutrition  and South Africa's National Codex 
Contact Point . G/TBT/GEN/339  
 
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  meeting s due to a lack of resources and the absence of scientific , monitoring and consumption data 
to support national positions. He also noted that one of t he opportunities  arising from participation 
in Codex 's activities  is the possibility of harmoniz ing food l egislation  with international standards , 
which entails compliance with  SPS and TBT obligations.  
2.13.  Ms Blanca Cristina Olarte  (Colombia)10 shared Colombia's experience participating in the 
standard -setting activities of Codex . Some of the challenges faced by Colombia include : 
(i) maintaining a permanent and effective participation in Codex's activities by all relevant 
stakeholders, including in the early stages of standards development; (ii)  disseminating Codex's 
work, standards and guidanc e to a wider set of stakeholders;  and (iii) building technical knowledge 
within the national team responsible for Codex work. Ms Olarte also highlighted a number of 
opportunities that arise by engaging in Codex's standard -setting activities, such as: (i) b enefitting 
from support from relevant international organizations working in the area of food safety, nutrition  
and related areas (e.g. the FAO and the WHO) ; (ii) enhancing capacity building through the work 
and events led by Codex's regional Committees; a nd (iii) developing partnerships with domestic 
stakeholders, such as industry associations and academia, in order to strengthen national positions 
related to Codex's work programme . 
2.14.  Mr de Sousa dos Santos  (Brazil)11 shared Brazil's experience participating  in Codex's 
standard -setting activities. While the food safety control system does not have a single authority in 
Brazil (the national food system involves over ten Ministries at the federal level), the primary 
responsibility of regulation lies with the Br azilian Health Regulatory Agency  (Anvisa)  and the Ministry 
of Agriculture  (MAPA) . In order to overcome the complexity of the national food system, Brazil has 
worked to improve transparency and stakeholder engagement. When it established its National 
Codex Committee, Brazil sought to mirror the Codex Alimentarius Commission and its subsidiary 
bodies. Different subcommittees were created at the national level and the coordination of each of 
these groups was assigned to different governmental bodies considering their roles and regulatory 
scope within the national food system. Draft positions are first developed at the subcommittee level, 
with contributions from government experts, academics, industry  and consumer protection bodies . 
Following this, the  draft position is submitted for approval by the national committee , which then 
adopts by consensus the final national position for the Codex meetings . Stakeholders from 
government, academia, industry, consumer protection bodies and standard setting bodies  
participate in this part of the process.  
2.15.  Mr de Sousa dos Santos added that Brazil strives to ensure the adequate flow of information 
between subcommittees and the national committee. This is done, for example, by requiring 
delegations to present reports a fter attending Codex meetings. Moreover, to engage effectively with 
Codex's work  and overcome difficulties encountered, Brazil holds a workshop at the end of each year 
in which all Codex subcommittees conduct a review of their work and develop an annual wo rk plan. 
Mr de Sousa dos Santos concluded by noting that, to improve its management system, Brazil's 
national committee is revising its procedural manuals and enhancing capacity building activities.  
3  COMMENT BY THE MODERATOR  
3.1.  I would like to share with you a  number of key takeaway points from the thematic session:  
• We benefitted from a comprehensive presentation on the Codex Alimentarius 
Commission's structure and their main standard -setting activities with relevance in the 
area of technical barriers to trade (TBT). In particular, colleagues from the Codex 
Secretariat highlighted that Codex and the TBT Committee support each other's work 
on, among others, protecting consumers' health through labelling measures on nutrition 
and allergens.  
 
• We discussed important  recent developments in the Codex Committee on Food Labelling 
(CCFL) regarding nutrition and allergens labelling. CCFL developed a new standard on 
front-of-package nutrition labelling, which can be mandatory or voluntary and provides 
valuable guidance on h ow to display nutrition information to help consumers make 
informed choices. One Member shared their experience on how they built on CCFL work 
to provide simplified nutritional information to consumers. One key lesson was the value 
 
10 Ministry of Health, Colombia.  
11 Brazilian National Institute of Metrology . G/TBT/GEN/339  
 
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  of engaging at an early stage with all interested stakeholders in public consultations, 
including the public and private sectors, consumers and academia.  
 
• In addition, a declaration of allergens and precautionary labelling is under development 
under CCFL with support from a group  of experts assembled by FAO and WHO. This 
work aims to develop: (i) a report with recommendations on a priority list of allergens; 
and (ii)  guidance on precautionary allergen statements (e.g., may contain peanuts) to 
best assist consumers. This work is of  particular interest to countries that are in the 
process of updating their requirements on allergens. Other CCFL work includes 
appropriate standards for the labelling of non -retail containers, e -commerce food 
labelling, and guidance on the use of technolo gy in food labelling.  
 
• We also learned about new areas of work of the Codex Committee on Food Import and 
Export Inspection and Certification Systems (CCFICS) related to conformity assessment 
procedures. For example, CCFICS has been working on: (i) guidance  on using data from 
voluntary third -party assurance programmes to support food control systems; (ii) 
guidance on establishing systems that support the issuance of electronic certificates 
between trading countries ; and (iii) guidance on remote audit and cer tification 
procedures for the use of national food control systems.  
 
• Some Members highlighted the main challenges faced for effective participation in 
Codex activities, such as the complexity to ensure participation of all national agencies, 
difficulties i n engaging private and public sector stakeholders, limited technical and 
financial resources to participate in the various areas of work , and limited access to 
scientific and data and specialized technical knowledge. However, these Members also 
highlighted  that taking part in Codex standard -setting procedures is extremely 
important, as this can help to ensure that their position is taken into account and they 
can also benefit from science -based and internationally harmonized standards and 
guidelines.  
 
• Membe rs also shared good practices to improve participation in Codex activities, such 
as establishing a Codex contact point and national coordination procedures with a wide -
ranging membership; the creation of a National Codex Committee mirroring the Codex 
Commi ssion subsidiary bodies; the set -up of annual work plans to address key priority 
areas; and the development of programmes of continuous training for national officials . 
Some Members also highlighted the need to develop further capacity for online systems 
and tools.  
 
3.2.  Finally, I want to thank all participants for their active and positive engagement. I believe this 
thematic session encouraged our TBT Committee to explore ways to strengthen the role of 
Observers, benefit  from their technical  knowledge, and also opened the possibility for a more 
dynamic and active participation  of these Organizations  in the Committee.  
__________