JOINT FAO/WHO FOOD STANDARDS PROGRAMME
CODEX ALIMENTARIUS COMMISSION
Twenty-Third Session, FAO Headquarters, Rome, 28 June -3 July 1999
Agenda Item 9
DRAFT AMENDMENT TO THE STANDARD FOR FROZEN FISH STICKS (FISH FINGERS), FISH PORTIONS AND FISH FILLETS -- BREADED OR IN BATTER, ALINORM 99/22, para. 36, Appendix IV
Comments of the
INTERNATIONAL ASSOCIATION OF CONSUMER FOOD ORGANIZATIONS
IACFO supports the adoption of the Amendment requiring the mandatory declaration of fish content that would enable consumers to make more informed choices when purchasing frozen fish products. More broadly, IACFO supports quantitative ingredient declarations (QUID) for all foods and urges the Commission to direct the Committee on Food Labeling to initiate the development of a Codex standard requiring QUID for all multi-ingredient foods.
Specifically, IACFO recommends that the Committee develop a standard requiring that
(1) all food labels state in their ingredient lists the percentage of all major ingredients, i.e., those that comprise 5% or more of the total weight, and (2) the percentage of any ingredient that appears in the name of the food or that is highlighted on the label through words or pictures appear on the principle display panel in type size at least as 50% as large as the words or images that refer to that ingredient.
QUID informs consumers if a particular ingredient is present in a significant amount and allows consumers to compare the relative amounts of ingredients between two seemingly similar products. For example, one brand of spaghetti sauce may contain 50% water and 40% tomatoes, while another brand contains 70% water and 20% tomatoes. QUID is necessary to indicate the proportion of ingredients, allowing consumers to select the more desirable product. In addition, Quid helps clarify claims on food labels. Many labels imply, through words or pictures, that a food contains significant amounts of meat, fruit, vegetables, or whole grains yet those ingredients may be present in only trivial amounts, if at all. While those deceptions should be forbidden, many governments fail to take adequate enforcement action. By providing consumers with the information that they need to make informed purchasing decisions, QUID decreases the probability that consumers will be duped by exaggerated claims and provides manufacturers with the incentive to increase the quality of their food products.
We therefore urge the Commission to approve this topic as an agenda item for the Committee on Food Labeling.