Opinion of the Economic and Social Committee on the "Communication from the Commission to the European Parliament and the Council on foods and food ingredients authorised for treatment with ionising radiation in the Community"

(2002/C 48/21)

On 8 August 2001 the Commission decided to consult the Economic and Social Committee, under Article 262 of the Treaty establishing the European Community, on the above-mentioned communication.

The Section for the Single Market, Production and Consumption, which was responsible for preparing the Committee's work on the subject, adopted its opinion on 21November 2001. The rapporteur was Mr Jaschick.

At its 386th plenary session of (meeting of 28 November 2001) the Economic and Social Committee adopted the following opinion by 104 votes to four with five abstentions.

1. Introduction

1.1. Food is only rarely consumed immediately at the place it was produced. During the transport and storage which is usually necessary foodstuffs are subject to influences which can cause them to deteriorate or even perish.

1.2. The traditional methods used to prevent this are, inter alia, drying, heating, cooling and smoking, as well as deep freezing or storage in a controlled atmosphere (CA). The treatment of foodstuffs with ionising radiation also aims to reduce the number of micro-organisms or parasites present or to inhibit sprouting. Irradiation can also make it possible to comply with quarantine regulations applicable to fruit (USA) or honey (South Africa) aimed at preventing the introduction of insects or pathogenic organisms into areas which are free of them.

1.3. Since March 2001 all irradiated food has had to comply with Directives 1999/2/EC and 1999/3/EC. Directive 1992/2/EC requires the Commission to forward a proposal by the end of 2000 completing the positive list of foodstuffs authorised for irradiation. Article 4(4) of Directive 1999/2/EC continues to apply, however; it provides that under certain conditions existing authorisations for irradiated foodstuffs may continue in force until the positive list has been completed.

1.4. Under this Directive, the irradiation of foodstuffs and food ingredients may be authorised only if there is a technological need, if the process can be shown to pose no health hazard, if there is a benefit to the consumer and as long as irradiation is not used as a substitute for good hygiene practices or health measures.

1.5. Many experts and representatives from consumer organisations, the industry, the scientific and research community and international bodies have already been canvassed for their views. The results of these hearings are both complex and controversial.

1.5.1. Consumer organisations consider irradiation to be unnecessary as long as good hygiene practices are followed. They feel that this technology should be used only very restrictively, if at all.

1.5.2. Many food producers are against the inclusion of their products in a positive list, fearing damage to the product image.

1.5.3. The FAO/IAEA/WHO International Consultative Group on Food Irradiation, research establishments and the irradiation industry itself advocate the authorisation of at least those products in respect of which the Scientific Committee on Food has issued a favourable opinion. They feel that irradiation is the best substitute for the fumigation of fruit and vegetables and that generally it can replace the use of dangerous chemicals. The opinion of the US government, given in the context of the EU consultation process, particularly stresses that there are no scientifically proven or valid reasons for restricting the irradiation of food. This assertion is, however, strongly disputed in the opinion of the Food Commission (UK) Ltd.

1.6. Now the Commission intends to conduct a broader debate on the basis of its Communication(1).

2. General comments

2.1. The European Economic and Social Committee (ESC) welcomes the Commission's very informative communication. It provides an excellent summary of the reactions to the Commission's consultation paper, setting out the views of the groups consulted.

2.2. The ESC refers to its original Opinion of 31 May 1989(2) and reiterates the view expressed in it:

"In the above circumstances, the Committee deems it inadvisable to endorse a Community framework for food ionisation, apart from ionisation of spices, until such time as the EC Commission has submitted conclusive evidence as to the technical need for and acceptability on health grounds of this preservation method."

2.2.1. With regard to technical need: The prevailing scientific view is that the irradiation of food is technically necessary and worthwhile, particularly where chemical treatment has hitherto been used for the same purpose. Informed consumers are critical of the use of chemicals because of possible residues.

2.2.2. With regard to the absence of any risk to human health: The irradiation of foodstuffs does not make the treated foodstuffs radioactive (i.e. the food does not itself emit radiation). Rather, sufficient irradiation of food destroys harmful organisms (mould, pathogens, parasites) and thus contributes to better protection of the consumer. The current scientific view is that irradiation is safe. The WHO has repeatedly stated that food irradiation poses no health hazard.

2.2.3. With regard to the ESC's call (of 31 May 1989) for a report on the various international organisations' attitudes to food irradiation.

2.2.3.1. The consumer associations (BEUC, CI) are very critical of food irradiation. They feel that, where proper hygiene practices are followed, irradiation is neither technologically worthwhile nor necessary. The technology should be used as restrictively as possible, if at all.

2.2.3.2. The WHO is in favour of irradiation as a way of reducing the microbial load in foodstuffs.

2.2.3.3. The JECFI and the Codex Alimentarius impose no restrictions on the irradiation of certain foodstuffs.

2.2.3.4. The FAO/IAEA/WHO argue that foodstuffs treated with a dose of radiation geared to a particular technical purpose not only can be consumed without risk but are also nutritionally adequate.

2.2.4. With regard to the ESC's call for a report on the further development of alternative methods of preservation: No such report has been drawn up, as no alternative preservation methods have so far been fully developed.

2.2.5. With regard to the ESC's call for a report on ways of identifying foodstuffs which have undergone irradiation: Analytical procedures now exist which are capable of identifying virtually every case of food irradiation. Five methods are already CEN standards and further methods are currently being tested(3).

2.2.6. With regard to the ESC's call for a report on international irradiation practices: No such report is available. The quantity of foodstuffs currently undergoing irradiation worldwide each year is estimated at 200000 t.

2.2.7. With regard to the ESC's call for a report on the import of products which are frequently subject to irradiation: No such report is available to the rapporteur. Irradiated frogs' legs are, for example, known to be imported into France from third countries. Under existing law official investigations by the Commission will be possible only in the future.

2.2.8. With regard to the ESC's call for a report on establishing the capacity of irradiation facilities installed in the Community: Under existing law the Member States have to register all authorised facilities. An initial list of such registered facilities is now available(4).

2.2.9. With regard to the ESC's call for a report on the progress of discussions in the Member States, the Commission and the Council: No such detailed report is available to the rapporteur. The fact that in its communication the Commission states that it is not yet in a position to draw up the positive list called for in Directive 1999/2/EC suggests, however, that the progress of the discussions has to some extent been unsatisfactory.

3. Recommendations

3.1. In its Opinion of 31 May 1989 (see point 2.2) the Committee deems it inadvisable to approve a Community framework for food ionisation, apart from ionisation of spices, until certain evidence and reports have become available.

3.2. Some of the evidence and reports called for by the Committee (points 2.2.1 to 2.2.9) is now available.

3.3. Food which has undergone irradiation or which contains irradiated ingredients is required to be labelled. Practicable analytical procedures exist for the identification of irradiated food. Informed consumers or those interested in sustainable consumption are therefore in a position to make buying decisions based on full knowledge of the facts or to decide not to buy.

3.4. The Committee feels that, in view of the concerns and reservations harboured by some sections of the population, generalised food irradiation should be handled cautiously. It should, however, be borne in mind that, according to prevailing scientific opinion, ionising irradiation of foodstuffs poses no danger to the consumer.

3.5. The Committee underlines the importance of the forthcoming EEA rules and expects the open and wide-ranging discussion taking place in the EU also to be conducted in all the EEA countries.

Brussels, 28 November 2001.

The President

of the Economic and Social Committee

Göke Frerichs

(1) COM(2001) 472.

(2) OJ C 89, 31.7.1989, p. 14, rapporteur: Mr Gardner.

(3) These tests are widely available, as they, together with other methods, have been adopted in Germany as DIN standards and are used by the inspecting authorities.

(4) According to expert opinion, the occupational radiation exposure of workers in irradiation plants is generally below normal background radiation levels because of the concrete shielding used.