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Transparency and sustainability of the EU risk assessment model in the food chain

Food safety, Public health

As announced in the Commission Communication on the European Citizens' Initiative "Ban glyphosate and protect people and the environment from toxic pesticides", the objective of the proposal is to increase the transparency, the accountability, and the sustainability of the EU scientific assessment model and the risk assessment based decision-making, and other aspects such as the governance of EFSA, by amending the General Food Law Regulation and related sectorial legislation

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Public consultation

ID: 1519

Lobbying Activity

34 responses

Consultation response

Bureau Européen des Unions de Consommateurs, 21 Jun 2018

BEUC, the European Consumer Organisation, welcomes the European Commission’s move to make EFSA’s scientific assessments more transparent. Nevertheless, we recommend strengthening the proposal with the following clarifications/changes: • It must better ensure that public health prevails over…

Consultation response

Bureau Européen des Unions de Consommateurs, 16 Jan 2018

BEUC deplores the unfortunate timing for the publication of the roadmap, which has not allowed proper consultation of our members. It is also regrettable that the findings of the General Food Law ‘REFIT’ evaluation were published only two days before closure of this consultation. Our detailed…

Chemical Industry Urges Stronger Confidentiality Safeguards in EFSA Transparency Rules

European Chemical Industry Council, 25 Jun 2018

The organization requests stronger procedural safeguards for confidentiality claims, including a right to administrative review similar to REACH regulations. They want removal of the Aarhus Emissions Rule reference and oppose early publication of studies before scientific assessment begins.
This would protect commercially valuable business information from competitors and reduce disincentives for innovation.
Public interest groups lose broader transparency on chemical emissions and safety data.

Consultation response

European Chemical Industry Council, 17 Jan 2018

Cefic, the European Chemical Industry Council, appreciates the opportunity to respond to this consultation, despite the short deadline arising from its launch during the holiday period. On this regard, we note that the Commission seems to have decided not follow its own Better Regulation…

Consultation response

EuroCommerce, 20 Jun 2018

EuroCommerce is the principal European organisation representing the retail and wholesale sector. It embraces national associations in 31 countries and 5.4 million companies, both leading multinational retailers such as Carrefour, Ikea, Metro and Tesco and many small family operations. Retail and…

Consultation response

European farmers, 16 Jan 2018

Fifteen years after the adoption of the principles laid down in the General Food Law (GFL), EU farmers would like to stress once again their support for and commitment to these principles. We believe that this is a fundamental piece of legislation which sets the foundations for food and feed…

Consultation response

European agri-cooperatives, 16 Jan 2018

Fifteen years after the adoption of the principles laid down in the General Food Law (GFL), EU agri-cooperatives would like to stress once again their support for and commitment to these principles. We believe that this is a fundamental piece of legislation which sets the foundations for food…

Consultation response

FoodDrinkEurope, 22 Jun 2018

FoodDrinkEurope is representing Europe’s food and drink industry, the largest manufacturing sector and leading employer in the EU and a key contributor to its economy (289,000 companies, 99% SMEs, 4.2 million employees), welcomes the opportunity to respond to the proposal. FoodDrinkEurope…

Consultation response

CropLife Europe, 25 Jun 2018

We support the overall objectives of the Commission’s proposal: increasing transparency in the EU risk assessment process can contribute to strengthening public trust in the system. This is why we committed globally to publish all information related to the safety of pesticide active substances…

Consultation response

CropLife Europe, 17 Jan 2018

ECPA supports the Commission initiative to increase public confidence in the EU risk assessment process, including those actions intended to improve transparency. We recognise the legitimate societal demand for transparency in evaluation procedures. On the measures described in the roadmap, our…

Consultation response

EuropaBio, 22 Jun 2018

We fully support the Commission’s objective to increase trust and confidence in the EU’s procedure for risk assessment in the food chain, by making it more transparent and sustainable. The EU’s risk assessment system is robust, but looking ahead, we agree that it should become more efficient,…

Consultation response

EuropaBio, 17 Jan 2018

EuropaBio welcomes the opportunity to provide our views on the roadmap and trusts that any forthcoming legislative proposal will be accompanied by an impact assessment. More transparency of the EU risk assessment: EU legislation already provides for public consultations and opportunities…

Consultation response

Plastics Europe, 25 Jun 2018

PlasticsEurope acknowledges the Commission initiative from 11 April aiming at increasing transparency and independence in the risk assessment process and appreciates the opportunity to provide input to the ongoing consultation on the proposal, by means of addressing comments and…

Consultation response

Verbraucherzentrale Bundesverband, 25 Jun 2018

Der vzbv begrüßt die Initiative der EU-Kommission zur Verbesserung der Transparenz der Risikobewertung der EFSA sowie zur Stärkung der Risikokommunikation als wichtigen Schritt zur Stärkung des Vertrauens der Verbraucher in den regulatorischen Rahmen der Lebensmittelproduktion. Jedoch ist der…

Consultation response

Association of the European Self-Care Industry, 25 Jun 2018

AESGP fully supports the proposal’s objective to improve the citizens’ trust in the EU risk assessment in the food chain by improving its transparency and sustainability. As an EFSA registered stakeholder, AESGP has always been supportive of the effort thus far taken by EFSA to implement the…

Consultation response

Association of the European Self-Care Industry, 17 Jan 2018

The Association of the European Self-Medication Industry (AESGP) welcomes the opportunity to comment on the Commission Roadmap on transparency and sustainability of the EU food and feed safety risk assessment model. As a matter of principle, AESGP stands for a policy-making system that is…

Consultation response

Union Européenne du Commerce du Bétail et des Métiers de la Viande, 25 Jun 2018

Founded in 1952, the European Livestock and Meat Trades Union (UECBV) is the voice of national federations representing livestock markets, livestock traders (cattle, horses, sheep, pigs), meat traders (beef, horse meat, sheep meat, pig meat), and the meat industry (slaughterhouses, cutting plants…

Consultation response

AnimalhealthEurope, 25 Jun 2018

AnimalhealthEurope welcomes the proposal to address concerns around public confidence in the risk assessment process under the General Food Law. In particular, we welcome the increased focus on risk communication. In our opinion science based risk communication is the most important factor in…

Consultation response

Fédération Européenne des Fabricants d'Aliments Composés, 16 Jan 2018

FEFAC comments on the EU Commission consultation on Transparency and Sustainability of the EU Risk Assessment model in the food chain 1. FEFAC is the European Federation of manufacturers of compound feed and premixtures for food producing animals. 2. As a matter of principle, FEFAC is of the…

Consultation response

The EU Vegetable Oil and Proteinmeal Industry, 12 Jun 2018

FEDIOL welcomes the Commission proposal on the transparency and sustainability of the EU risk assessment in the food chain. Overall, it supports work to address public perceptions on the EU risk assessment in the food chain and improvements in risk communication. Industry supports increased…

Consultation response

The EU Vegetable Oil and Proteinmeal Industry, 16 Jan 2018

FEDIOL welcomes the opportunity to provide input. FEDIOL participated in past consultations steps on the General Food Law. FEDIOL also provided feedback on EFSA functioning such as in EFSA external evaluation 2017. FEDIOL is also an accredited EFSA stakeholder since the start. FEDIOL supports…

Consultation response

Testbiotech, 17 Jan 2018

In principle, Testbiotech welcomes this initiative. However, its priority must be to strengthen the precautionary principle. There are several possibilities to move forward: For example, research programs focussing on the protection goals should become crucial element. These research programs…

Federchimica warns early data disclosure threatens chemical industry innovation

Federazione Nazionale dell'Industria Chimica italiana, 25 Jun 2018

Federchimica urges the Commission to release supporting data only after the authorization process is finalized to protect technical know-how. They also advocate for a review mechanism regarding confidentiality decisions and better alignment with pharmaceutical assessment standards.
Delaying disclosure allows companies to protect their research investments and maintain market competitiveness.
Rival firms lose the advantage of accessing trade secrets before new products launch.

Consultation response

SAFE, 17 Jan 2018

EFSA has a very important role in Europe, being the Agency tasked with the review of the analyses and the assessment of risks regarding food and feed. Therefore, it is responsible for the EU consumers’ health and safety. The current risk assessment of EFSA clearly lacks transparency; this can…

FEFANA urges protection for intellectual property in risk assessments

FEFANA, 25 Jun 2018

FEFANA calls for a postponement of the decision until a comprehensive impact assessment is completed. They request that transparency measures exclude non-safety-related efficacy data and protect companies' inventions from disclosure. The association also emphasizes the need to prevent competitors from accessing and abusing proprietary business strategies.
These changes would protect their market position by preventing competitors from using their research.
Stakeholder groups lose the ability to perform alternative evaluations of the industry's data.

Consultation response

Food Supplements Europe, 23 Jun 2018

Food Supplements Europe represents the manufacturers of food supplements and food supplement ingredients. In our sector, innovation is key and this proposal should not undermine the objectives of the Commission laid down it its better regulation programme. With this in mind, we are surprised…

Consultation response

Food Supplements Europe, 16 Jan 2018

Food Supplements Europe welcomes the opportunity to comment on the proposed roadmap. A revision of the General Food Law Regulation requires a coherent approach integrating all necessary changes into the framework that has already demonstrated its effectiveness, as confirmed in the Fitness Check.…

FEFANA Urges Strong IP Protections in Food Safety Transparency

FEFANA, 16 Jan 2018

FEFANA demands that new transparency rules must secure the protection of intellectual property rights. They call for an appropriate balance between public access and private ownership. They insist science remain free from pressures caused by emotional public campaigns.
Protecting intellectual property safeguards investments in research and development for member companies.
Public interest groups might see reduced access to raw scientific data for review.

Consultation response

European Crop Care Association, 25 Jun 2018

ECCA would like to express its support for any initiative that improves clarity and transparency of the regulatory system for pesticides. With regard to the current proposal, we have concerns with regard to certain parts, as expressed below: CONFIDENTIALITY The Commission proposal includes…

Consultation response

EU Specialty Food Ingredients, 22 Jun 2018

EU Specialty Food Ingredients represents a united voice for the specialty food ingredients industry on scientific, technical and regulatory issues relating to food products in Europe. In total, more than 200 international and national food ingredients companies (of which 22 % SMEs) are currently…

Primary Food Processors urge context for food risk data

Primary Food Processors, 12 Jun 2018

Sensitive data should only be published together with the final EFSA opinion. PFP calls for releasing exclusively data actually used in risk assessments. This avoids damaging industry competitiveness and creating unfounded fears.
Restricting data access prevents competitors from identifying company methods and protects brand reputation.
Transparency advocates and researchers lose immediate access to raw data before official conclusions.

Consultation response

Lebensmittelverband Deutschland e. V., 17 Jan 2018

Bund für Lebensmittelrecht und Lebensmittelkunde (BLL) represents the whole food sector in Germany. BLL thanks the European Commission for sharing the roadmap on transparency and sustainability of the EU risk assessment model in the food chain in a public consultation. The roadmap hints at…

Primary Food Processors Urge Science-Based Food Safety Transparency

Primary Food Processors, 16 Jan 2018

The association supports risk assessments based on sound science regardless of the funding source. They advocate for educational campaigns to improve public perception and avoid false messages about food. New transparency measures should follow existing laws and build upon current agency initiatives.
This would protect the validity of industry-funded research and reduce public opposition to their products.
Groups seeking to restrict private funding from safety evaluations would find their objectives blocked.

Consultation response

European Manufacturers of Feed Minerals Association, 17 Jan 2018

Please find our feedback in the attached document