Association Belge des Consommateurs Test-Achats / Belgische Verbruikersunie Test-Aankoop

Test-Achats

As a consumer organisation our goal is to inform, help and defend consumers in all their 'consumer activities'.

Lobbying Activity

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans) and EUROCONSUMERS AISBL

10 Sept 2020 · Consumer policies in support of the European Green Deal

Meeting with Vytenis Andriukaitis (Commissioner) and

22 Jul 2019 · Access to medicines

Response to Commission Regulation on maximum levels for glycidyl esters in certain foods

19 Sept 2017

The values for GE contaminants contained in the Regulation proposal expose infants and babies, fed with infant formulae only, to unwanted risks that should be avoided. Based on EFSA suggestions and considerations, the only way to keep consumers safe from the risks of genotoxicity and carcinogenicity that glycidyl esters have, is a MoE value of 25000. Any MoE figure below 25000 is a possible risk for consumers. The most vulnerable group of consumers is the one of infants and babies up to 6 months old when no breastmilk fed, because the level of GE contaminants that are allowed in breastmilk substitutes – based on the actual text of the Commission Regulation, lead to a MoE well below the safety value of 25000. The calculation is easily made using the daily portions suggested by baby milk producers for babies 1, 3 and 5-month-old, and WHO percentile tables. We suggest diminishing up to 5 time the values of GE limits so to grant to all babies a safe Margin of Exposure.
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Response to Commission Regulation on the use of Listex™ P100 against Listeria in ready-to-eat food products

13 Jul 2017

The Belgian Consumer Association Test-Achats/Test-Aankoop generally disapproves of the use of ‘decontamination’ treatments as we are concerned they may result in a lowering of EU hygiene standards. Less scrupulous food business operators might see them as a convenient substitute for good husbandry and hygienic practices on farm and in the abattoir. Moreover, many of these treatments are of questionable efficacy and bacteria can develop resistance to them. While EFSA found that ListexTM P100 itself does not raise any food safety concern, its verdict on the efficacy of this treatment is much more mitigated (1). First, between 2.5% and 9.5% of naturally occurring Listeria strains exhibit resistance to bacteriophage P100. Second, the efficacy of ListexTM P100 in a real-life setting is not well demonstrated. EFSA noted that “there were very limited data on the effect of Listex™ P100 on RTE foods naturally contaminated with L. monocytogenes” and stated that “predictions of the magnitude of the efficacy of Listex™ P100 in reducing L. monocytogenes contamination of RTE foods in specific processing plants are highly uncertain”. EFSA also warned that “P100-resistant variants [of Listeria monocytogenes] might be selected as a consequence of its use in industrial settings” in the absence of proper cleaning and disinfection of the areas where ListexTM P100 is used and/or in case it is not used properly. This might put consumers’ health at risk, especially if food businesses have lowered their guard on good hygiene and instead over-rely on decontamination with ListexTM P100. Finally, from the consumer perspective, we would insist that ListexTM P100, if at all authorised, should be labelled. The effect of ListexTM P100 persists during storage and therefore it should be considered as a food additive, and not as a processing aid. This answer by the European Commission to a parliamentary question from 2007 on ListexTM P100 shows that the status of this treatment (additive vs. processing aid) is far from clear-cut. As far as we can see, the annex to the draft Regulation specifying the conditions of use of ListexTM P100 does not foresee any specific processing step to rinse off/remove the treatment after it has been used. Consequently, we question its classification as a processing aid (under Regulation (EC) 853/2004 on the hygiene of foodstuffs of animal origin) and believe it should be considered as a food additive. (1) EFSA Scientific Opinion on the evaluation of the safety and efficacy of Listex™ P100 for reduction of pathogens on different ready-to-eat (RTE) food products.
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Response to Commission Reg. (EU) on the application of control & mitigation measures to reduce the presence of acrylamide in food

3 Jul 2017

In the new proposal from the Commission: "A recital (Recital 15) was added which says “the setting of maximum levels for acrylamide in certain foods should be considered”. In our opinion the main goals should be that maximum levels are established and implemented as soon as possible.
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