JOINT FAO/WHO FOOD STANDARDS PROGRAMME
CODEX ALIMENTARIUS COMMISSION
Twenty-Third Session, FAO Headquarters, Rome, 28 June -3 July 1999
Agenda Item 9
CODEX COMMITTEE ON FOOD IMPORT AND EXPORT INSPECTION AND CERTIFICATION SYSTEMS
Comments of the
INTERNATIONAL ASSOCIATION OF CONSUMER FOOD ORGANIZATIONS
Draft Guidelines for the Development of Equivalence Agreements Regarding Food Import and Export Inspection and Certification Issues
The International Association of Consumer Food Organizations (IACFO) is concerned that the draft guidelines do not provide for adequate public participation in the development of equivalency agreements.
Paragraph 37 of the Draft Guidelines states To enhance public confidence in the agreement while respecting legitimate concerns to retain confidentiality, the relevant competent authorities of the particular country should provide the public including consumers, industry, and other interested parties an opportunity to comment at an appropriate time on the proposed content of the agreement.(footnotes omitted and emphasis added).
IACFO believes it is crucial that consumers and other interested parties be given the right to participate in all phases of the development and approval of equivalency agreements in order to ensure that such agreements establish an appropriate level of protection. In this regard, we wish to note that the Trans-Atlantic Consumer Dialogue organized by the European Union and the United States issued a resolution in Brussels on 24 April, 1999, calling for governments to support such measures.
We therefore strongly urge that paragraph 37 of the Draft Guidelines be amended to require full public participation including the disclosure of relevant documents that justify the acceptance or rejection of proposed agreements. The guidelines should specifically provide for a public notice of an initial decision to develop an equivalency agreement and an opportunity to submit oral and written comments during a period of at least 60 days. The guidelines should also provide for a subsequent public notice of the availability of a draft equivalency agreement together with another opportunity to submit oral and written comment during a period of at least 60 days before an agreement is finalized.
IACFO urges that the guidelines be approved at Step 8 only if such provisions for public participation are provided for.