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CONSUMERS' ASSOCIATION THE QUALITY OF LIFE

EKPIZO

EKPIZO – Consumers’ Association The Quality of Life established in 1988, protects consumer rights and improves their quality of life; it is a nongovernmental, nonprofit and accredited association, administered by a 7 members Board, has over 23000 members, 10 employees and 36 volunteers (2023 data).

Lobbying Activity

Response to Revision of the definition of engineered nanomaterial in food

26 Dec 2023

EKPIZO welcomes the opportunity to provide feedback on the draft Delegated Act updating the definition of engineered nanomaterial We are very much afraid that the proposed revised definition does not meet the level of EU consumer protection we are used to being an example to be followed by other countries, notably the USA. Nor is it compliant with consumer safety and information legislation, thus being a serious setback We would urge the Commission, as BEUC and other members do, to consider a nanoparticle number threshold as low as possible and in any case below 10%, considering that: - In 2012, the European Food Safety Authority (EFSA) recommended that, in view of the uncertainties over safety, a nanoparticle number threshold lower than 50%, e.g. 10%, should be considered for food related nano applications; - In 2014, the European Parliament objected to a previous attempt to update the nano food definition, as it considered that a threshold of 50% (as already proposed by the Commission back then) would violate the aim of pursuing a high level of protection of consumer health and interests; - The French food safety agency, Anses, wrote in a scientific opinion that the nanoparticle number threshold of 50% included in the horizontal nano definition is not based on sound scientific arguments (rather a political choice), and recommended setting a lower value for this threshold; - Detecting nano food ingredients (e.g. additives) based on a 10% nanoparticle number threshold is feasible, since this is the cut-off value currently applied by the French Directorate General for Consumer Affairs, Competition and Fraud Control (DGCCRF) in its control activities We really hope that finally, the EC will continue to upgrade consumer protection by pursuing the highest level possible,by responding to its own standards, by respecting the other EU/national institutions opinion, by taking into account consumers interests and will and not other interests
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