G/TBT/W/613  
22 March  2019 
(19-1799) Page: 1/2 
Committee on Technical Barriers to Trade  Original:  Spanish  
 
  
URUGUAY - LABELLING OF PACKAGED FOODS  
STATEMENT BY COSTA RICA TO THE COMMITTEE ON TECHNICAL BARRIERS TO TRADE  
6 AND 7 MARCH 2019  
The following communication , dated  21 March  2019, is being circulated at the request of the 
delegation of Costa Rica . 
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1.  Costa Rica wishes to express its concern about the documents notified by Uruguay for public 
consultation with regard to the labelling of packaged food s, which are contained in the draft Law a nd 
Decree No. 272/2018.  
2.  While we support all training, education and information programmes aimed at improving  the 
dietary  habits of the population, we are concerned by the approach proposed by Uruguay to address 
the indicated o besity issues.  
3.  Obesity is a phenomenon shaped by  a great many variables ; therefore,  an approach  based on  
the characteristics of a specific product or its nutrients  would be  ineffective and would not provide a 
comprehensive solution to the  problem . We are a lso concerned by the trade implications of the 
measure and its consistency with the commitments undertaken by Uruguay in this Organization.  
4.  As indicated by Costa Rica on previous occasions, we consider that warning label systems lack a 
sound scientific bas is and d iverge from  applicable  international standards on the matter , 
in particular, the Codex  Alimentarius . 
5.  The warning labels proposed by Uruguay would apply to food products and their nutrients which 
are harml ess, which have never been classed as hazardous  substances, and which have even been 
duly approved by the  respective  health authorities . The application  of such labels  may therefore 
constitute an unnecessary barrier to trade and may be contrary to the principles of proportionality 
provided for  in Article 2.2 of the Agreement on Technical Barriers to Trade (TBT Agreement).  
6.  Furthermore, we consider that the proposed approach to labelling is misleading and may cause 
confusion among consumers.  
7.  The front-of-package labelling proposed by Uruguay only  covers certain food products that are 
packaged in the absence of the c ustomer . Such products include those to which sodium, sugar s or 
saturated fat s have been added during the processing or to any ingredients, and the amount of 
sodium, sugars, fats or saturated fats in the final composition exceeds the established values. The 
nutritional composition of all types of food and beverages in the context of an overall diet is what 
really matters when  it comes to  inform ing and educat ing consumers about nutrients of public health 
concern . The consideration of  an exemption from  front-of-package labelling for products with 
nutrients of public health concern (for example, cheese with a high fat content, full-fat dairy -based  
desserts and packaged fruit juice), may misinform consumers and lead them to believe  that such 
products are healthier than those to which the same nutrients have been added irrespective  of the 
total number of calories and calorie density of the food.  G/TBT/W/613  
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  8.  For these and other reasons, Costa Rica considers that  this discussion should take place in the 
context of  the Codex Alimentarius , so that the improvements can be implemented in an orderly , 
harmonized and multilateral manner, on the basis of a scientific discu ssion held in international 
forums created specifically for that purpose.  We also consider that  the potential for  short-term 
progress should be developed through  voluntary compliance programmes, which have enabled  the 
world food industry to make  significant  strides , and by carrying  out consumer education campaigns.  
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