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Koninklijke Belgische Vereniging van de Chocolade-, Praline-, Biscuit- en Suikergoedindustrie

CHOPRABISCO

De vereniging heeft als doel : het informeren, ondersteunen en adviseren van de in België gevestigde chocolade-, praline-, biscuiterie- en confiseriefabricanten in sectorgerelateerde dossiers en dit door tijdig de juiste informatie aan leden of betrokken overheidsinstanties te bezorgen, zodat er op een efficiënte manier kan worden geanticipeerd op problemen, gebeurtenissen en uitdagingen.

Lobbying Activity

Response to Commission Implementing Regulation on the provision of voluntary indication of origin or place of provenance of foods

30 Jan 2018

CHOPRABISCO welcomes the opportunity to provide input into the draft implementing Regulation on the provision of voluntary indication of origin or place of provenance of foods. We support the remarks sent by CAOBISCO and FoodDrinkEurope. We illustrate some of these remarks with "Belgian chocolate". The better regulation agenda aims for targeted regulation that goes no further than required, in order to achieve objectives and bring benefits at minimum cost and administrative burden. We believe that the scope of the draft implementing regulation goes beyond the objective of article 26.3 of FIC : avoid that the consumer is misled as to the true origin of the food. If you have a “Belgian tomato soup”, tomatoes can from Belgium, Spain, The Netherlands … But when you have “Belgian chocolate”, it is obvious for the consumer that the cocoa beans are not from Belgium. Therefore, the consumer is not misled by not indicating the origin of cocoa or by not indicating that their origin is different from the origin of the chocolate. It will bring no benefit to consumers, as they know that cocoa beans are sourced in third countries. This is the reason why we request to exclude ingredients that generally do not originate in the EU or that are exclusively produced from raw ingredients that are generally known not to originate in the European Union from the scope of primary ingredient. If however cocoa will not be excluded from the scope, cocoa is considered as the primary ingredient of chocolate. Because chocolate producers want to guarantee a constant taste and quality and since the availability of cocoa beans is dependent from the season and the weather, blending of cocoa beans from different origins is a common practice in the chocolate sector. Therefore, we welcome the possibility to mention “non EU” as place of provenance. What should be considered as the primary ingredient of pralines (filled chocolate(s)) ? Will it also be the cocoa ? The consumer would be more interested in the origin of the chocolate used to make the pralines instead of the place of provenance of the cocoa of the chocolate … And what about the primary ingredient of a filled chocolate tablet/bar ?
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