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JOINT FAO/WHO FOOD STANDARDS PROGRAMME
CODEX COMMITTEE ON FOOD LABELLING
Thirty-First Session

OTTAWA, CANADA, APRIL 28 MAY 2, 2003

Draft Amendment to the Guidelines for the Production, Processing, Labelling and Marketing of Organically Produced Foods - Section 5. Criteria
(at Step 6)

COMMENTS OF THE INTERNATIONAL ASSOCIATION OF CONSUMER FOOD ORGANIZATIONS (IAFCO)

IACFO would like to suggest adding a sentence to paragraph 5.1 as follows. The suggested sentence is underlined.

Section 5

5.1

At least the following criteria should be used for the purposes of amending the permitted substance lists referred to in Section 4. In using this criteria to evaluate new substances for use in organic production, countries should take into account all applicable statutory and regulatory provisions. The competent authority should compile a list of all related regulations, and make them available to all interested parties and stakeholders. Any new substances must meet the following general criteria.

Rationale:

Adding this line would assist national authorities responsible for organic regulations to take into account all applicable statutory and regulatory provisions, and would thus facilitate the implementation of this guideline. The current guideline says, "countries should take into account all applicable statutory and regulatory provisions," although, neither organic operators nor competent authorities know what "all applicable statutory and regulatory provisions" are. "All applicable statutory and regulatory provisions" may include not only the agriculture related laws but other field such as environmental law, hygiene law, air and water quality, building standards, waste treatment laws, etc.

Many regulations and laws are outside the jurisdiction of the competent authority for organic food, and it is difficult for producers to understand all related laws and regulations that may apply to them. For example, in Japan, the Ministry of Agriculture, Fishery and Forestry is the competent authority for organic food. However, environmental law is under the jurisdiction of Ministry of Environment, water quality is under jurisdiction of Ministry of Health, Labor, and Welfare, and building standards are under the jurisdiction of Ministry of Land, Infrastructure, and Transport. Also, since the competent authority for organic food regulation does not have the authority to order other government sections to inform producers of other applicable statutory and regulatory provisions, it is difficult for producers to learn of all such applicable provisions. By adding the proposed text, the competent authority of organic food will be able to request the cooperation of other related government sections and develop a list of all applicable statutory and regulatory provisions applicable to organic producers.

It is also important for national authorities to provide such as list to all interested parties and stakeholders, including certification bodies, and consumers. If such a list is not provided, it will be difficult to implement and enforce the Codex guideline.