Opinion of the European Economic and Social Committee on the 'White Paper on Food Safety'
Date: 2000-05-24
Institutions: European Economic and Social Committee
Subjects: consumer protection, food inspection, foodstuff, foodstuffs legislation, health risk

18.7.2000

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Official Journal of the European Communities

C 204/21

Opinion of the European Economic and Social Committee on the ‘White Paper on Food Safety’

(2000/C 204/06)

On 28 January 2000 the Commission decided to consult the Economic and Social Committee, under
Article 262 of the Treaty establishing the European Community, on the above-mentioned White Paper.

The Section for Agriculture, Rural Development and the Environment, which was responsible for
preparing the Committee’s work on the subject, adopted its opinion on 10 May 2000. The rapporteur
was Mr Ataı´de Ferreira and the co-rapporteur was Mr Verhaeghe.

At its 373rd plenary session of 24 and 25 May 2000 (meeting of 24 May), the Economic and Social
Committee adopted the following opinion by 105 votes to one, with four abstentions.

1.

Introduction

1.1.
The Committee has closely followed the reorganisation
of the Commission’s services — in the wake of the BSE crisis
— with regard to food safety, risk assessment, consumer
information and monitoring. It welcomed the ‘farm to table’
approach advocated by the Green Paper on Food Law (1), and
suggested a number of avenues for developing legislation and
checks on food safety, while concluding that a general
foodstuffs agency such as the United States’ FDA was not
suited to the European situation. It also called for strengthening
of the Food and Veterinary Office in Dublin (FVO) in order to
ensure more effective harmonisation of control systems in the
Member States (2).

1.2.
However, when consumer confidence was shaken yet
again by the dioxin crisis (before the BSE crisis had completely
died down), the Committee considered that further action was
needed at EU level in order to fill the continuing gaps in
legislation, implementing procedures and checks on the food
chain.

The Committee is pleased to see that the new Com-
1.3.
mission has given great priority to this subject and has taken
decisive steps to reorganise its departments still further by
making a single Commissioner responsible for health, con-
sumer protection and food safety. Right at the start of its new

term, the Commission announced a major initiative in this
field and its intention to issue a White Paper on Food Safety.
Mr Prodi confirmed this positive step when he addressed the
ESC’s October 1999 plenary session.

1.4.
In launching the White Paper, the Commission now
proposes to establish an independent European Food Authority
(EFA), with responsibilities for: risk assessment (preparation of
scientific advice), the collection and analysis of information
(food safety monitoring and surveillance programmes), and
risk communication (information on food safety issues).

The guiding principle of future EU food safety policy
integrated

1.5.
is that it must be based on a comprehensive,
approach.

1.5.1.

Other key principles are set out in the White Paper:

1. a clear definition of the responsibilities of the various
stakeholders, i.e. primary responsibility should be borne
by: feed manufacturers, farmers, fishfarmers, fishermen
and food operators; national authorities should monitor
and enforce this responsibility; and the Commission,
through the FVO, should control the national inspection
systems;

2.

full traceability of feed and food and their ingredients;

3.

involvement of all stakeholders in policy development;

(1) Opinion on General principles of food law in the European Union
(Commission Green Paper) and Consumer health and food safety
(Communication from the Commission), OJ C 19, 21.1.1998.
(2) Opinion on the Commission communication to the European
Parliament, the Council and the Economic and Social Committee
on food, veterinary and plant health control and inspection, OJ
C 235, 27.7.1998.

4. application of

the three components of risk analysis
(comprising risk assessment, risk management and risk
communication) and

5.

the use of the precautionary principle when carrying out
risk management, where appropriate.

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2. General comments

2.1.
The Committee has long argued for a comprehensive
and integrated approach to food safety in the EU. The past
decade was marked by certain food scandals leading to a lack
of confidence in food and its safety. The European food chain
must be legislated in its entirety — from ‘farm to table’. Each
link in the food chain must be as strong as the next and the
Commission should assure reliable enforcement of Com-
munity legislation.

2.2.
Although there may not be much that is truly new in
the White Paper, it does represent a noteworthy effort by the
Commission to rethink food legislation in general and food
safety in particular and it is consistent with the principles of
the 1997 Green Paper.

Control aspects

feedingstuffs in the scope of

The Committee welcomes the consistent introduction
2.3.
of
food safety policy. The
Commission’s Action Plan should ensure that controls in all
sectors at farm level are defined, harmonised and adequately
funded.

2.3.1.
Surely the point is that controls along the whole
chain have to be equally rigorous and enforced. The costs
should be properly funded,
in order to ensure that both
national and FVO inspectors are totally independent and
that economic operators co-operate fully and openly in the
performance of the tasks allocated to them.

2.4.
It is stated that the Rapid Alert System works well
for consumer foodstuffs. However, such a statement is of
questionable value as experience has shown thus far that this
system is not sufficiently rapid and efficient. Improvements
are urged in the way crises are managed, including strengthen-
ing the Rapid Alert System, which should become the most
reliable trigger point in EU risk management mechanisms. The
Commission should become fully accountable for the overall
performance of this system.

fact
is that economic operators prefer to manage crises
themselves if they do not trust the authorities to do it in
a reasonable, responsible, effective and non-discriminatory
manner. The structure of the Rapid Alert System needs to be
established in a way that responsibilities are properly assigned
to the Member States and other parties involved, and correctly
managed. It must be assured that any information forwarded
to the Commission will be subject to a rigorous scientific
analysis before horizontal control measures are introduced.
This should take place with due regard to confidentiality.
However, confidentiality should not be an obstacle to proper
crisis management.

An effective RAS is only one element in food crisis
2.7.
management. This management is not satisfactorily addressed
in the White Paper on food safety. The Committee believes
that
there is a need for an effective crisis management
procedure at EU level to co-ordinate both the assessment
of the risk and its subsequent management between the
Commission, the Member States and the third countries, as
appropriate. Such co-ordination should also provide a single
source for communication with the operators and the public
in general. A reformed RAS should be structured in such a
way as to be able to tackle: 1. assessment of the risk identified
in one Member State by the EFA; 2. discussion between
RAS/EFA and the Member State (and company(ies) involved)
on the assessed risk and its confinement within a specific area
in a confidential manner; 3.
if the risk is real then the
Commission should provide all Member States with the
necessary information about what action to take; 4. feedback
from all Member States about actions taken to contain the risk
in their countries — without jeopardising transparency.

2.8.
In the context of Food Control the Committee would
express its support for an appropriate implementation of the
subsidiarity principle. However, with regard to the inspections
on implementation of EU food legislation and the monitoring
of related parallel activities undertaken by the relevant national
bodies, it would point out that the Commission is responsible
for ensuring that the subsidiarity principle does not jeopardise
the goals of the White Paper, namely the scope and benefits of
the ‘integrated approach’ and equal enforcement.

2.5. Meanwhile, on 22 March the European Commission
tabled a new proposal to put in place safeguard measures to
deal with emergencies on the animal feed sector. This proposal
aims to tackle the deficiencies recognised in the existing
legislation following the recent dioxin crisis in Belgium.

Regulatory aspects

The Commission identifies lack of communication and
2.6.
absence of co-ordination as the reasons for slow and late
responses from the relevant Member State departments. The

2.9.
The success of the measures proposed in the White
Paper is intrinsically linked to the support of the European
Parliament and the Council. Their implementation will depend
on the commitment of the Member States. Legitimate doubts
may be cast on the EU’s commitment to health protection, at

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all levels of decision-making, given its past record and the
present inexplicably slow progress in getting the Proposal for
a European Parliament and Council Regulation laying down
rules for the prevention and control of certain transmissible
spongiform encephalopathies and the Proposal for a European
Parliament and Council Directive amending Council Directive
91/68/EEC as regards scrapie (COM(1998) 623 final — COD
98/0323-0324) (1) on the statute book. Checking that national
authorities are properly applying Community rules and pro-
visions is not, and has not been, easy.

2.13.
A more complex case which is not analysed in the
White Paper are the recent differences of opinion between
leading scientists — some acting at national level, others at EU
level — regarding preventive measures against new variant
CJD. The White Paper could have usefully taken a stance or
offer some thoughts on this emerging topic, in order to help
clarify matters for the general public and for economic
operators.

Existing European legislation is not always enforced
2.10.
efficiently at national
level. Implementation is partly frag-
mented in Member States. The measures taken by the Com-
mission to address these national failures have proved to be
insufficient, with the result that consumers have lost faith in
EU surveillance mechanisms. Other foodchain stakeholders
such as food industry workers, producers, distributors and
farmers would also like to see their confidence boosted by the
introduction of a food policy based on an integrated approach,
with maximum harmonisation at EU level and genuine inter-
vention capability.

An important factor in the wayward implementation
2.11.
of European legislation is the delay in transposition into
national law. Community legislation should, as far as possible,
recognise the direct applicability of Community food safety
policy instruments, as the Committee has advocated in the
case of consumer protection legislation, whenever these instru-
ments contain precise, detailed rights and obligations (2). As
the Committee has proposed in the past, a Regulation is in
most cases the most appropriate legislative tool and it should
be used broadly in the framework of Common Market
legislation.

2.12.
The Committee also notes that the White Paper does
not make it clear whether food from the sea (i.e. fish, crab,
shell-fish etc.) and aquaculture products are to be included. A
coherent food policy should cover all or the vast majority of
foodstuffs involved in all links of the food chain, from fisheries
to agricultural products. The Committee also notes that no
reference is made to the inclusion of drinking water in the
scope of food safety legislation and urges the Commission to
trigger the necessary procedures to this end.

Social dimension

2.14. Within the process launched by the White Paper, the
production conditions for non-industrial foods made by small
businesses are a particularly sensitive matter. The Commission
will have to give subsequent thought to this as part of its
global approach, particularly when it comes to revise legis-
lation, bearing in mind the importance of preserving rural
food specialities and know-how, without prejudice to food
safety rules.

2.15.
The Committee points out that the White Paper does
not mention the importance of working conditions for
ensuring that procedures are carried out properly. When work
is badly paid, and when working hours are unsatisfactory and
workers are inadequately trained, there is no guarantee that
tasks will be performed correctly, as they should be if food
safety standards are to be observed as closely as possible. The
Committee calls for clear, understandable rules which workers
will find easy to apply. Workers must be involved in the
implementation of safety procedures, and their representatives
should be able to act as whistle-blowers. The Committee has
already discussed the perverse effects which crises in consumer
confidence have on employment (3).

Nutritional aspects

2.16.
The White Paper addresses the basic questions of
achieving high standards of food safety. As a result of market
globalisation and access to food, dietary patterns are starting
to converge now. It must be highlighted however that an
unbalanced diet and an unhealthy lifestyle, rather than unsafe
food, are implicated in some diseases which are expected to
increase in the years ahead. There is wide agreement that we
are facing the prospect of more rather than less diet-related
diseases.

(1) OJ C 45, 19.2.1999.
(2) Opinion on Consumer protection and completion of the internal
market — CES 1115/91 — OJ C 339, 31.12.1991, and Opinion
on The consumer and the internal market — CES 1320/92 — OJ
C 19, 25.1.1993.

(3) See the ESC opinion on the BSE crisis and its wide-ranging

consequences for the EU, in OJ C 295, 7.10.1996, p. 55.

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2.17.
EU food policy must focus not just on safety but on
nutrition and diet as well. Health promotion should play a
food safety, taking into
major role in any discussion of
consideration traditions in national diets. The Committee
therefore welcomes the introduction of the question of dietary
patterns in the White Paper.

Education and training

2.18.
In addition, the ESC believes that campaigns such as
the ‘Food safety campaign’ already introduced back in 1997
could be successfully adapted to the current situation and,
eventually, play an important role in public education. Such
initiatives should aim to inform and educate European con-
sumers about such complex issues. The Committee invites the
Commission when designing such a campaign to give particu-
lar emphasis to the education provided at primary and
secondary education levels and to incorporate food safety
aspects in all health promotion campaigns.

Precautionary principle

2.19.
The Commission published its Communication on
the precautionary principle on 2 February 2000. Given the
importance of this,
the Committee will submit an own-
initiative opinion on the subject in due course. This opinion’s
comments on the precautionary principle focus exclusively on
food safety related issues. Where appropriate, the precaution-
ary principle will be applied to risk management.

2.20.
The application of the precautionary principle solely
to risk management does not seem to resolve the matter
entirely, as already mentioned in the opinion on the Green
Paper (1). It is well known that scientists have to deal with the
question of doubt. Their understanding of causes and effects
may be called into question at any time, and analyses may be
amended accordingly. Therefore, while being free agents, the
authors of scientific opinions must bear in mind the relative
nature of knowledge when drawing up the conclusions on
which the Commission — as the political risk-taker — will
base its action.

legislation must retain an upbeat attitude and must not prevent
research or close the door to progress.

2.22.
The precautionary principle might in such cases be
applied under well-defined conditions within risk management
for consumer health protection in the case of unknown risk of
a potential hazard while awaiting further results of scientific
approach. To this end, the Commission should be able to
introduce appropriate safeguard measures.

Agenda

2.23.
The White Paper agenda is clear and quite compre-
hensive. The principles of a food safety policy from ‘farm to
table’ based on traceability and transparency are well defined,
and include health protection as a logical objective of all food
safety measures.

2.24. Whilst
the question
the timetable is ambitious,
remains whether it is realistic. It is not clear whether the action
plan has been laid out in the right order and with the right
priorities to achieve the overall goal, particularly as regards the
issues which cause most concern to EU citizens.

3. Specific comments — The European Food Authority

(EFA)

In the light of the above comments, and provided that
3.1.
the matters raised in the present opinion are resolved, the
Committee supports the establishment of an EFA, to be made
responsible for risk assessment and communication.

3.2.
The main intention of the White Paper on food safety
is to contribute to a high level of consumer health protection
in the area of food safety, through which consumer confidence
can be restored and maintained. It is intended that this be
achieved by application of the principles of independence,
excellence and transparency. The authority must demonstrate
a high level of accountability to the European institutions,
consumers and other foodchain stakeholders.

2.21.
A precautionary approach must be the guiding prin-
ciple throughout all food safety legislation. However, the
White Paper does not provide a proper model for applying
the precautionary principle. Unnecessary risks should be
minimised, but those drawing up and applying Community

Resources

(1) OJ C 19, 21.1.1998, p. 61.

3.3.
It seems that resources are quite often duplicated.
There has been concern that many substances are evaluated
simultaneously at international, European and national levels.
The Committee hopes that the EFA can help to ensure that
available resources are managed more effectively.

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3.4.
Resources will be the key issue in developing this
model, and particularly in maintaining it. Without the pro-
to
vision of adequate public funding it will be difficult
demonstrate independence.

while respecting the principles of confidentiality where appro-
priate. Consumer involvement could be established by the
organisation of regular hearings on the state of scientific
evaluations. The Committee believes that it is important to
demonstrate transparency by actions and believes that risk
communication has an important role to play in this context.

Scientific findings and public opinion

3.5.
As regards the scientific basis of risk assessment, the
situation would remain as at present, although autonomy will
raise the profile and authoritativeness of the intervention
process.

The Committee is pleased to note that the setting up
3.6.
of the new authority marks a break from the tendency for
Commission services to be compartmentalised. The Committee
has criticised this on a number of occasions. The public may
not yet have got over the BSE crisis, the bacterial contamination
of foodstuffs, the increasing worries about inappropriate use
of antibiotics or the detection of dioxins in foodstuffs; the
Committee however welcomes the fact
that, by directly
involving six commissioners, the Commission has opened the
debate on food safety issues.

The proposed system for informing about risks is
3.7.
perhaps the most positive feature of the new authority. It is
true that recently the Commission has made the opinions of
the scientific committees available, but since the EFA itself is
to publish its opinions, these will reach economic operators,
the general public, civil society, and consumer associations in
particular. This will do much to strengthen civil society and
the involvement of the general public, who will be able to
judge for themselves any cover-ups or mistakes in management
that flout scientific opinions assessing the risks, as well as the
handling of public health protection or the misuse of the
precautionary principle. This will do much to improve confi-
dence in the scientific opinion and the understanding of the
subsequent management measures.

3.8.
The proposed model for providing a structure for
delivering world class scientific advice supported by a Euro-
pean network seems appropriate. It will, however, not be easy
to accomplish, and the mechanism to achieve this end has not
yet been defined.

3.9.
Because consumers are not formally involved in the
preparation of scientific opinions, the process does not take
due account of their interests. But consumers would like to be
involved in a dialogue with scientists on food safety issues,

3.10.
If the scientific advice is to be of the highest quality
and independence, it is essential that the scope of the scientific
advisory committees is regularly kept under review and that
the relevant experts are appointed to these committees and are
adequately sourced. In some areas it may be necessary to
appoint experts from outside the EU in order to ensure the
highest quality and the right balance of expertise.

Objectives

3.11.
The EFA will not be given responsibility for legislation
and control (the two components of risk management). Whilst
the White Paper does suggest that the authority might extend
its competencies in the future, the starting point is a body with
little power which appears to be a restructuring of
the
existing scientific committee arrangements. The Committee is
concerned that the EFA does not have sufficiently well defined
scope to tackle many of the key issues facing the EU. If
improvements are to be ensured, the Committee considers that
the EFA should be given involvement in some decision making
procedures, always leaving the ultimate responsibility to the
Commission, the European Parliament and the Member States.
If the Treaty does not allow this, then the Commission should
develop an effective model within its own structure until the
Treaty is amended.

3.12.
The White Paper puts forward a model for a European
Food Authority and shows a clear commitment to a food
policy extending from ‘farm to table’ and including the animal
feed sector. Nevertheless it is not clear how the management
mechanisms of the new authority will guarantee excellence and
transparency. The Commission should give detailed indications
about the selection procedures and the management instru-
ments of the authority.

The White Paper seems to defend the status quo
3.13.
regarding the statute and dependence of the FVO, and this
would appear to be a weakness of the new system. An
independent EFA is still dependent on a Directorate-General
which in turn is dependent on the Commission, for the
collection of data which should be backed by inspections by
the FVO. The authority will not have powers to communicate

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directly with the inspection services, nor to seek clarification
or additional information when necessary. From a first analysis,
the system would appear more consistent if the FVO had
functional autonomy, so that the EFA can have its own means
of inspection. In this way harmonisation could be achieved,
and the Community framework of national control systems
would be able to work on the basis of operational criteria
set up at Community level, following Community control
guidelines and acting with the requisite administrative co-
operation.

3.14.
objectives of the EFA, which are:

The Commission White Paper highlights the principal

— best quality of scientific advice;

— independence from industrial and political interests;

b)

c)

d)

— openness to rigorous public scrutiny;

— scientific authority;

— close co-operation with national scientific bodies.

the EFA should play a key role in ensuring that consumers
can also be involved in stimulating further fields of action
if deemed appropriate. In this context, the EFA should be
funded so that it can be proactive rather than purely
reactive;

the EFA should be confined to questions of food safety and
should not extend to environmental issues, if food safety
is not involved; its functions should be concerned with
food safety aspects of animal welfare, zoonoses, and
biodiversity;

foods, novel

the EFA should give scientific advice for the approval of
novel
ingredients or novel production
methods to the Commission. This includes the provision
of risk assessment, utilising the expertise of recognised
bodies
the Community. Risk assessment
should be assigned in a harmonised manner throughout
the Community. If necessary, standards or specifications
must be established to make this happen;

throughout

e)

the EFA should have responsibility for assessing the risks
of new additives, and flavourings;

3.15.
the EFA should also pursue:

In addition to the above, the Committee thinks that

f)

the EFA should evaluate the safety of pesticide residues,
animal medicine residues and contaminants in food;

a) openness to dialogue with all stakeholders;

b) highest level of accountability, to be enforced judicially in

the event of fraud or serious misconduct;

g)

the EFA should establish a Community-based system of
collection of nutritional and food consumption data,
including the establishment of a surveillance system of
diet-related illnesses;

c)

integrated approach at all levels;

d) clear definition of structure and management responsi-

bilities;

e)

transparency to achieve the EFA goals;

f)

the role of a centre of knowledge generation, taking
account of traditional national specificities.

Functions and methods

F u n c t i o n s

h)

the EFA should ensure that health related claims are
assessed effectively;

i)

j)

the EFA should provide impartial and objective scientific
assistance to the European institutions on food safety
issues that affect the obligations of the European Union
under international trade treaties,
including any issues
arising from the WTO Disputes Settlement Procedure;

the EFA will need to be able to carry out research,
monitoring and surveillance, give advice and propose
Community action across the entire food chain including
in relation to primary agriculture produce. At the other
end of the food supply chain, the EFA should ensure
the provision of clear and meaningful
information to
consumers on food and health issues.

3.16.
should be assigned to the EFA:

The Committee believes that the following functions

M e t h o d s

a)

the EFA should be the only body responsible for defining
and implementing suitable risk assessment models that
enable evaluation of food safety risks;

3.17.

Concerning the methods the Committee believes that:

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a)

the EFA should clearly communicate risks to the EU public
in a way that it is relevant, useful, easy to understand and
consistent. It will also be very important that the EFA
ensures that risk communication is a two-way dialogue
between citizens and the authority so that it can take into
consideration their attitudes and perceptions. If this system
seems not to be practical, it must be assured that the
is consistent
communication made at national
throughout the Community;

level

3.20.
The Committee calls on the Commission to present a
proposal for the establishment of the EFA within the deadlines
foreseen in the White Paper. In this context, the Committee
would like to see the above-mentioned remarks incorporated
in the Commission’s final text, to take into account the wishes
expressed by civil society.

b)

the EFA should also communicate benefits to health and
diet if research has shown evidence of such benefits;

4. Specific comments — Action plan

c)

the EFA’s relationship and interaction with legislation-
making bodies, the Dublin Office and other Community
institutions will be vital for its success and for ensuring
that food issues are effectively tackled within and across
Europe. It is important that the EFA is ultimately account-
able to the European Parliament and to the Member States.
It will also need to work closely with all the Commission
DGs.
Its relationship with the other EU agencies is
also important, including the EMEA when dealing with
borderline products where there may be difficulties
determining whether a product is a food or a medicine;

d)

it is important that the EFA develops appropriate working
relationships with other international organisations (1). The
food supply is increasingly globalised as are the issues that
face food policy decision-makers. In addition, the EFA will
need to be aware of its international obligations in relation
to international harmonisation of standards and ensure
that its advice is provided within this context.

3.18.
The White Paper refers to ‘other legitimate factors’
such as the environment, sustainability, animal welfare, food
quality, the role of agriculture and industry and the inter-
national dimension. However, it must be decided how these
interests are to be properly represented and balanced in a food
policy in which safety is a primary objective.

3.19.
All EFA opinions, once they have been published and
forwarded to the Commission, must be followed up with a
Communication, to be published within a reasonable timef-
rame.

(1) For example the Food and Agriculture Organisation (FAO), the
World Health Organisation (WHO), the World Trade Organisation
(WTO), the Joint FAO/WHO Codex Alimentarius Commission
and the International Office for Epizootics (IOE).

4.1.
The Committee welcomes the Commission’s proposed
action plan of over 80 legislative proposals set out in the
White Paper. There is the scope to review many of the
omissions within the current legislative proposals including
the need to establish a clear set of safety rules and guiding
principles for food legislation. The Committee particularly
welcomes the priority accorded to the establishment of a
General Food Law Directive to be proposed in September
2000.

The action plan is ambitious in scope and timing.
4.2.
Priorities are set. There is overall agreement that the Rapid
Alert System must be amended and improved independently
of the establishment of the EFA.

4.3.
The Committee suggests that draft EU legislation on
the comprehensive Rapid Alert System and the proposal for a
regulation on official food and feed safety controls should be
submitted in the first half of 2000 and adopted by the Council
by the end of the year, rather than in December 2001 as
forecast (see 2.4). The future European Food Authority, which
will manage the Rapid Alert System, cannot realistically be set
up before 2002, which also underlines the need for a more
immediate crisis management system. The crucial importance
of strengthening the system of current feed and food controls
does not permit such a delay in taking a decision.

By June 2000 the Commission will adopt the proposal
4.4.
for a Regulation on hygiene for adoption by the Council/Euro-
pean Parliament in June 2002. The Committee believes that all
efforts should be made to adopt the draft Regulation in
June 2001. Consolidated hygiene legislation,
including the
appropriate veterinary rules, is a key measure for integrated
food safety legislation and cannot therefore be delayed. In the
same context,
is necessary to harmonise the existing
feedingstuffs legislation with the general hygiene rules to
include the principles of Hazard Analysis Critical Control Point
System (HACCP) rules and other equivalent methods which
are to be EU approved in future.

it

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4.5.
Concerning the listed Directive on ‘labelling’, which is
an important means of consumer information, the Committee
to consolidate Directive
believes
79/112/EEC in such a way as to modernise the system and to
make it consistent and comprehensible for the consumer, with
the aim of enabling informed consumer choice.

important

that

is

it

4.6.
Often health claims are made on packaging or in
advertising of products without proper scientific documenta-
tion, causing improper use and creating unjustified expec-
tations. For this reason, food supplements and fortified foods
(point 105 of the White Paper) and herbal products too, should
be regulated at EU level as soon as possible, harmonising their
definition,
labelling and advertising (particularly for claims
related to wellbeing and health). Since health claims are not
currently regulated at Community level and not mentioned in
the action plan, the Committee calls on the Commission to
launch consultation on health claims and common practices
in different Member States with a view to harmonising the
relevant Community legislation.

The annexed list of measures is, in general, a positive
4.7.
step (see the above-mentioned suggestions for additions).
However, the Commission should make a greater effort to
consolidate current EU food legislation. If this effort bears
fruit, it will contribute to legal clarity and to the efficiency of
the entire system, and will reinforce the confidence of the
general public. As well as consolidating legislation, it is equally
important
to update implementing procedures and make
adaptations in the light of technical progress and new scientific
knowledge. Although the EFA will not have legislative powers,
its role will be to support the legislator. The Committee hopes
that the Commission will also be sure to fulfil its commitment
(point 84 of the White Paper) to simplify and clarify the
relevant texts.

Brussels, 24 May 2000.

The Committee reserves the right to monitor the
intervene in the legislative

4.8.
legislative programme and will
process in accordance with the Treaty.

5. Conclusions

In conclusion the Committee welcomes the White
5.1.
Paper on food safety and supports the actions to be launched.

5.2.

The Committee particularly welcomes:

a)

b)

c)

the integrated approach of the food chain;

the strengthening of the EU’s operational capacity and the
new body (EFA) responsible for risk assessment and
communication;

the modernising and simplification of existing food legis-
lation,
to create more coherence and to launch new
measures where needed.

On the other hand, the Committee invites the Com-
5.3.
mission, in the framework of the on-going consultation, to
take the present opinion into account when refining the
following domains:

a) Rapid Alert System;

b)

social aspects;

c) nutritional aspects;

d)

e)

f)

g)

structure and role of the EFA;

risk management capacity of the Commission and the
inter-relationship of the EFA with the FVO;

legislation regarding drinking water;

incorporating with the principles governing future food
safety rules the domains of aquaculture, fisheries and sea
products.

The President

of the Economic and Social Committee

Beatrice RANGONI MACHIAVELLI