The Department of Trade and Industry BACKGRO GROUND D The - - PowerPoint PPT Presentation
GMO Labelling Regulations Conference 25 July 2014 Presenter: Mr. Andisa Potwana Director: Consumer Law and Policy The Department of Trade and Industry BACKGRO GROUND D The Consumer Protection Act, 68 of 2008 (the CPA) became fully
Stakeholder Comments / Inputs Proposal(s) put forward
We note that the Consumer Protection Act is clear that it is the ingredients of products that must be labelled in terms of Genetically Modified Organisms (GMO) If an ingredient contains 5 % or more GM content, it must be labelled as containing “genetically modified ingredients.” We advise that the regulations already provide a legally sound description of “prescribed goods” in regulation (3) and that no further action needs to be taken by the Minister in this regard. Unless there is monitoring and enforcement of the law, producers will unlawfully label products “may contain GM components or ingredients, taking into account that almost 80% of all maize grown and 98% of all soya grown in South Africa is GM. We strongly recommend that the wording “or not feasible” in the draft regulation (8) be deleted as it is unclear what the definition of feasible is.
Stakeholder Comments / Inputs Proposal(s) put forward We assert that a 5% threshold triggering positive GM labelling is misleading and confusing to consumers and therefore does not implement the stated objectives
We recommend that the threshold should be set at 0.9% as this is the intentionally accepted level and what our food exporters comply with, when exporting processed maize products especially to the EU. We note that the Codex Alimentarius has highlighted the need for further research to be carried out on the potential allergernicity
threshold 5% is not good enough; even a threshold of 0.9% is problematic in terms
We recommend that a “content-based” labelling system
labelling should be considered instead of a “content-based” system. We note that food companies are already required to label their products to provide consumer information and choice. GM labelling is no different and its implementation will not significantly impact on the cost of food.
Stakeholder Comments / Inputs Proposal(s) put forward We are concerned that labelling is only triggered where there is 5% or more GM content. This has no scientific basis, is misleading to consumers and is inconsistent with the threshold set by the DTI for the export of goods. We recommend that a positive GM labelling should be triggered at 0.9% as GM content is detectable at this level, is consistent with the threshold level set for export and provides accurate and meaningful information for consumers. Products that contain between 1 and 5% GM content do not need to labelled as containing GM, despite the fact that this content is scientifically detectable The absence
a positive GM labelling misleads consumers into believing that such products do not contain detectable GM ingredients or components, when in fact they do. A threshold of 5% is unnecessarily and unreasonably high, sanctioning high levels
contamination. It is inconsistent with the threshold set by DAFF for export shipments with non- GM status, which is set at 0.9%. We ask why one standard is set for export and another is set for local citizens?
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Stakeholder Comments / Inputs Proposal(s) put forward South Africa is the only country that has allowed the genetic modification of its staple food. Millions
South Africans are eating GM maize daily, in a semi-processed. This is unheard of anywhere in the world. In order to assist in properly monitoring the impact of consuming GM foods and also to allow individuals that may have developed an allergic response to such foods to avoid them, it would be wise to follow the example
and implement a “process-based” labelling system instead
a “content –based” system. There is inconsistency in what may and may not be labelled as containing GM content. If those wishing to label NOT GM can test at 0.9%, there is no reason that those who are required to label as CONTAINING GM content should not be required to do so at 0.9%. The definition
“not feasible” is unclear We recommend that the words “or not feasible” be deleted from this sub regulation.
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Stakeholder Comments / Inputs Proposal(s) put forward For purposed of section 24(6) of the Act, and subject to subregulation (4) and (6) this regulation applies to all goods that contain 5% or more genetically modified ingredients, irrespective of whether such manufacturing
goods Retailer would like clarity if the 5% refers to 5% of the total ingredients in the product or 5% of the specific ingredient. Any good to which subregulation (3) applies may not be produced, supplied, imported or packaged unless a notice meets the requirements of section 22 of the Act is displayed on, or in association with the packaging of those goods in a conspicuous and easily legible manner and size without stating, without change that the good contains genetically modified ingredients. Please clarify what is a conspicuous and easily legible manner and size, specify minimum letter size and position e.g. back
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Department of Health had given the food industry 24 months on R146 (Regulations relating to the labelling and advertising of foodstuffs) to implement changes due to the limited no of provision houses to action the changes on labels. Requests that we be given twenty four months to implement the changes once the regulation has been finalised to ensure that all the labels can be updated. GM testing is not reliable in processed ingredients or foods, due to degradation of the target DNA
removal during processing We would like to propose that the GM regulations only relate to foods that still contain GM in their DNA. Labelling should not exclude certain information for fear of certain practices being exposed. If I choose that those practises such as GMO do not suit my daily requirements of substance intake that is my right.
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Stakeholder Comments / Inputs Proposal(s) put forward Please, we live in a country that has huge food security issues – there is more than enough evidence to prove that GM crops are not the answer. Why are we not banning them outright like 61 other countries have, and turning our entire country organic like Bhutan has? Kindly note that the ingredients have not been genetically modified, it is the crops (maize, soybean and cotton) that have been genetically modified or improved for insect resistance and for weed control in the field. Thus the ingredients or components are derived from genetically modified crops. We thus call for this section of the law to be re-written or scrapped, as we found
and hence we still have very ambiguous amendment labelling regulations Supports requirements for accurate and informative product labels which communicate information that is relevant to health, safety and nutrition. We propose revised and accurate wording
engineered ingredients.
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Stakeholder Comments / Inputs Proposal(s) put forward I was made aware of the counter challenge made by the ….. group regarding the wording of the mandate for GMO labelling laws Generally many would argue that if a crop is genetically modified than it follows that the ingredients that results from that specific genetically modified crop would be genetically modified also, be it direct or indirect. I am one of those who would argue so. ( own note : proof??) The fact that the initial crop was genetically modified can never be taken away even when the crop has been changed into an ingredient of another product. ( own note : proof??)
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Stakeholder Comments / Inputs Proposal(s) put forward Since cigarette companies must label their products to warn consumers of the dangers of smoking, the GM made products (or derived from GM crops) should also carry the warning to help consumers decide whether or not, they're willing to take the health risk for their children and themselves. ( own note : food scare??) With countless studies already showing a direct correlation between GM products and cancers, and with a world-wide epidemic of cancer, it's imperative to label products loud and clear which are GM made or derived from GM crops
the milk from cows injected with growth hormones.
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Stakeholder Comments / Inputs Proposal(s) put forward With the GM maize in South Africa, millions of people who eat maize daily are affected. These are the workers and backbone of the country. Should we allow a continuing practice of poisoning children and the larger population of this country for the sake of greed? We have a right to know when a product fits the above category, especially since so many products are sold as "natural" or "organic" when indeed the products are GM made or derived from GM plants.
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Johnson & Johnson recently announced in the newspapers that they are considering the removal of cancer forming ingredients in their products, and thus implicating that they acknowledge that their products are in part responsible for cancers and that they have known about it. Shouldn't all such companies be forced to label their products so that unsuspecting parents will for instance, not feed their babies Gerber products or use shampoos which cause health problems? Since these companies such as Monsanto & DuPont and product manufacturers related to them are proud enough to advertise their products and so-called health benefits associated with their products, they should be proud enough to also clearly label their products as GMO/GM According to the rights in the Consumer Protection Act, companies must communicate risks to consumers in everyday language. As such these companies are not and should be fined for not doing so or their products withdrawn from the shelves.
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How should the 5% be calculated? Calculation based
weight, volume, particle count, components, ingredients, organisms etc. may result in different results. How will the 5% be affected by the combined effect of components or ingredients each carrying different levels
The public may not even be willing to consume GMO products with a contamination of 5%. The producers, suppliers, importers may apply for a right (may receive a certificate) to all them to label the product as zero, below 1%, below 5% or whatever predefined limit. The concerned public have a right and a need for the detailed information. There appears to be no scientific reason why a food product with less than 5% GM components would be less hazardous than a product with a higher concentration of GM components. We therefore propose the removal of a threshold of 5% for GM components, and mandate that any GM components to a food product attract an appropriate label.
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GMO products are unsafe at ANY level of content and informed consumers don’t want GMO whatsoever in their food. The fact that a product may still contain 5 % GMO ingredients means that the consumer is still in danger of the toxic effects of GMO at a rate of 5%. We don’t want 1% of GMO in our food so it should be labelled as such and should NOT be allowed to say “GMO free”. Full disclosure of GMO content is required which is not limited to some percentage. All GM food must be labelled, irrespective of the amount of GM contamination it contains. Why start at 5%? Faster working poisons are clearly labelled no matter the percentage active ingredient they contain.
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I would like to point out that there is no scientific basis for this 5%. How does one determine how much any single person would eat of any GMO products and therefore how much poison they are ingesting? The percentage clarification should not be included because even 5% could be extremely harmful. The deleterious effects of GMO products are such that there should be labelling to the same extent that is used for possible allergy-producing things such as nuts. I call for disclosure of even a minimum trace of GM ingredient in any food products that might come about from the surroundings in a factory that uses GM ingredients in any
its products, plus the disclosure of even minimal amounts in the product itself. The 5% rule will give too many companies another opportunity to waiver having to place the correct info on the labels. Besides the fact that too many companies with products containing more than 5 % GM content will obviously be inclined to let it slide and force the government to prove it, I am not happy to have any % of GM in my body if I have a choice and in a democracy.
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Why the arbitrary “5%
more ingredients
components” before labelling are mandatory? Consumers who have strong beliefs, reactions and/or reasons for avoiding GM food should know fully what their food contains. Foodstaff which contains more than 5%
GMF contained in the food and manufacturers and producers must be forced to label their products reflecting this %. That you make any food with 5% or less GM content to be labelled “5% or less of GMF”. All the food containing any percentage of GMO should be labelled accordingly. The consumers have a right to know and the right of choice. Nobody should be expected to consume food that contains even a trace of any GMO- not even 0.5%. GMO containing foods or crops should be banned altogether in SA.
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We should be labelling all food that contains any GMO. We would propose that the 5% threshold be lowered to 1% or less. Please can you explain on what scientific basis is the 5% threshold is being put in place? With something as deadly as GM food we have to act decisively. Please set a limit no higher than 0. 9% as the limit that does not require labelling. The health of the entire population is at risk. I have studied a lot of information about GM food, and I am convinced it is a health risk and very obviously a risk to
I urge you to implement the strictest labelling possible. I hear there is talk of only labelling food with more than 5% GM
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I would like to suggest that it be set at least at 5% of any 1 ingredient in such a product, it should be labelled. Actually I believe products should be labelled as such if they have ANY GMO’s in them at all. The people who make GM foods care nothing for health or the earth, only for profits. The 5% content is arbitrary and
I hope that the meat will also be labelled if the animals diet contains GMO’s. 5% GMO is too high. Ban all GMO’s that are herbicide/pesticide resistant and/or are able to replicate and contain the terminator gene before it is too late.
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More and more independent research is showing that there negative side effects from consuming GM foods and GM products for both humans and animals. All ingredients that are genetically modified must be indicated on the labels, even if the content is below 5% of the product. I’m not in favour of the threshold of 5%
All foods containing any amount of GM ingredients should be labelled with a warning “This food contains …. % of GM ingredients”. Most countries require labelling of GMO foods that contain more than 1% GMO ingredients. Please act in the best interest of South African consumers, farmers and
environment and tighten the controls on GMO labelling to the internationally accepted level
1% GMO content labelling.
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While being delighted that labelling will now become compulsory, I remain at loss to understand why the figure
5% was chosen? The rationale behind the choice of that figure eludes me. I would be far happier to see a figure closer to 2%. I was devastated when I found out that the cereals I had fed my daughter contained very high % of GMO content. I urge you to stick to the 5% minimum and possible make it even smaller. I hope to see products containing less than 5% GMOs being labelled “may contain GMOs”. The requirement for the information pertaining to there being GM
should be more precise. The 5% threshold is too high, it should be Zero.
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5% threshold is not good enough. The 5% threshold is not based on any scientific measure but purely
commercial considerations We would like to be informed on the label even if there is only 0.00001% of the product consisting of GMO food. Unscrupulous corporate manufacturers have shown time after time again that they cannot be trusted and that the only safeguard we have against them is watertight legislation to protect our people. Even allowing a 5% compromise as to the amount that is required to be published
labelling material in respect
GMO’s is
to manipulation and abuse. 5% of sand in your petrol tank would not be good for your car. Especially if there was 5%
sure you would want to know if the fuel you are putting into your car contained even 1%
decision whether to use that fuel or a brand that contained no sand. Labelling something as GMO free when it may contain 5% GMO is, in the long run, neither frugal nor ethical as it is misleading to the general public.
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As a concerned consumer, I urge you to not give in to demands for changing the labelling laws to fit Africabio. Whether a crop has been GMO raised with built-in insecticides such as BT Corn, sprayed with herbicides which are harmful to the human, are made Roundup ready, genetically modified
plants, the health effects on the human are the same
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