SAFE
SAFE
SAFE is a Brussels-based NGO protecting European consumers by monitoring and influencing food safety legislation.
Lobbying Activity
Meeting with Marta Temido (Member of the European Parliament)
14 Oct 2025 · Medical Care Failures
SAFE advocates for healthier green public food procurement rules
24 Feb 2025
Message — Public procurement should provide healthy diets free from NGTs and ultra-processed foods. It must include food waste calculations and prioritize local products to support nutrient recycling. Tax policies should reward winners and municipalities following these green principles.123
Why — The proposal advances SAFE's mission to prioritize consumer health in EU food policy.4
Impact — Companies producing genetically modified organisms or ultra-processed foods would be barred from supply.5
Meeting with Marco Tarquinio (Member of the European Parliament)
7 Feb 2025 · children's right to food in conflict situation
Meeting with Antonella Sberna (Member of the European Parliament)
2 Oct 2024 · Definition of Sustainable Food Systems, consumer protection
15 Apr 2024
SAFE Safe Food Advocacy Europe welcomes the proposed revision of quality control rules for plastic food contact materials (FCMs). Nevertheless, we consider that this revision does not go far enough to be able to ensure food safety for all European citizens. SAFE published a policy report in 2020 which underscored the main limits of EU regulation in this area and would like to further highlight relevant remaining concerns when it comes to these rules, which pertain notably to: the lack of attention on final articles, the lack of scientific and political scrutiny in the risk assessment procedure, and the lack of mechanisms to control Endocrine Disruptors in FCMs. Statistics show that there are over 12,000 distinct chemical substances intentionally used in FCMs , not to mention unknown and non-intentionally added ones. These chemicals, including hazardous ones classified as carcinogenic substances and/or Endocrine Disruptors, can transfer from FCMs into food, representing an important health issue that cannot be ignored. Endocrine Disruptors such as phthalates, adipates, styrene or bisphenol A, to name only a few, are often present in plastic containers and can migrate into food. According to experts, these substances are increasingly believed to be key factors contributing to the ever-growing number of citizens suffering from type 2 diabetes, obesity, reproductive issues, and some types of cancer. Equally important, several studies indicate that the migration level of those substances into food is even higher with recycled plastic. In conclusion, while the proposed revisions represent progress and a step in the right direction when it comes to enhancing food safety and protecting European citizens, there remain pertinent concerns, most notably regarding the three issues outlined above. Addressing these is imperative for ensuring comprehensive food safety regulation across Europe.
Read full responseMeeting with Roberto Berutti (Cabinet of Commissioner Janusz Wojciechowski) and EuroCommerce and
12 Apr 2024 · Meeting to present the research on food waste management
SAFE supports EU ban on Bisphenol A in food packaging
8 Mar 2024
Message — The group welcomes the ban on Bisphenol A and calls for stricter chemical regulations. They advocate for a comprehensive approach addressing multiple hazardous substances simultaneously to protect consumers.123
Why — This helps the organization achieve its goal of prioritizing consumer health in policy.4
6 Feb 2024
SAFE Food Advocacy Europe, a consumer organisation specialising in the food sector, is glad to welcome the Commission's proposal. We would like to emphasise that the presence of micro- and nano-plastics is not only a potential danger, but a real one. There is abundant scientific evidence that shows these components are present in irrigation water and sewage sludge used for fertilisation, which poses a risk of contamination to agricultural land and water. SAFE suggests that the Commission considers this and amends the delegated act to make the risk analysis mandatory. This should include the assessment of micro- and nano-plastics, and the reduction of danger should be required to prevent harm to European consumers. We attach our position paper presented last year to EFSA's Emerging Risk Stakeholder Group.
Read full responseResponse to Revision of the definition of engineered nanomaterial in food
10 Jan 2024
SAFE Food Advocacy Europe is worried that the proposed delegated act undermines food safety, consumer protection, and transparency. We are particularly concerned that most authorized additives will no longer be declared as nanomaterials on food labels. We believe that the current definition of nanofood, combined with the definitions in the proposed delegated act, creates a legislative flaw. This creates a discrepancy with the International Organization for Standardization (ISO) definition. The Commission should reconsider the text, taking into account the comments we have made, which you will find attached.
Read full responseResponse to Waste Framework review to reduce waste and the environmental impact of waste management
12 Sept 2023
As acknowledged by Eurostat in late 2022, in baseline year 2020, around 131 kilogrammes (kg) of food waste per inhabitant were generated in the EU, and this amount is likely to be underestimated . Therefore, at a time where food waste in the EU has reached records levels, SAFE welcomes the targeted revision of the Waste Framework Directive and the inclusion of new binding food waste reduction targets to be achieved by Member States by 2030. Setting new legally binding targets for member states to reduce food waste represents a positive advancement. Nonetheless, SAFE urges EU policymakers to take this commitment further by instituting and achieving comprehensive food waste reduction goals of 50% throughout the entire supply chain, including primary production and thus extending beyond manufacturing, processing, retail, and consumer levels. Any other lower targets would prevent the EU from meeting its climate objectives (as described in the Farm to Fork Strategy) and fulfil international commitments (in particular, the Sustainable Development goal #12.3). SAFE recommends policymakers to uphold the ambitions of SDG12.3, the EU Green Deal and the Farm to Fork Strategy by: - increasing all targets to 50%, covering the entire supply chain from farm to fork, as called for by civil society and the European Parliament; - including ambitious target for the reduction of primary production food waste; - considering setting prevention targets expressed in a maximum of kg/capita per year, as doing so would create a fairer unique baseline for all EU citizens regardless of the level of reduction already attained by Member States.
Read full responseMeeting with Véronique Trillet-Lenoir (Member of the European Parliament) and Competere - Policies for sustainable development
29 Nov 2022 · Front-of-pack labelling reform, event organised by Euractiv
Meeting with Biljana Borzan (Member of the European Parliament, Rapporteur) and EuroCommerce and
3 Nov 2022 · Empowering consumers for the green transition
17 Jan 2022
SAFE’s feedbacks on European Commission’s draft act on Food safety – recycled plastic in food packaging (updated rules)
About Safe Food Advocacy Europe – SAFE
SAFE – Safe Food Advocacy Europe was created with the aim of ensuring that consumer’s health and concerns remain at the core of the EU’s food legislation. SAFE is currently the only Brussels-based NGO specialised in the protection and representation of EU consumers in the food sector.
SAFE strives to ensure safer food standards for consumers by monitoring the EU food legislation process and cooperating with EU stakeholders to draft comprehensive food regulations. SAFE notably supports the development of policies and awareness-raising actions which jointly address health, environment, food safety and sustainability, all-the-while being involved in several EU-funded projects aimed at reducing the environmental impact of the food sector, increasing sustainability and promoting healthier food environments for consumers.
Introduction
Food contact materials (FCMs) are defined as all the materials and articles that are intended to be put into contact with food and beverages or will presumably be in contact with food or beverages. They include food packaging, kitchen equipment, tableware, machinery used in processing food, and objects that are used to transport food. These items can be made from a variety of materials including plastics, rubber, paper, and metal.
Numerous concerns have been raised regarding the health risks FCMs might pose for consumers during exposure, as well as the efficiency of EU legislation in ensuring the safety of these materials. Among them, SAFE focuses on the emerging high-risk issue of the increasing use of recycled plastics in FCMs, which could negatively affect human health through the migration of harmful chemical substances, integrated before and/or during recycling processes, from FCMs into food.
Drawing attention to health risks associated with recycled plastics in FCMs and the shortcomings of relevant legislation, SAFE would like to suggest the European Commission to a few important considerations in the light of the upcoming initiative to ensure European consumers’ health.
1. Shortcomings on the current draft act
Even though plastic recycling used for FCMs is regulated rather strictly in the EU, the health risks associated with recycled plastic FCMs indicate the need for improved legislation in order to better protect consumers’ health. Hence, SAFE would like to elaborate on three main shortcomings in the present draft act on recycled plastic FCMs, namely:
1. Lack of attention on final articles
2. Issues on enforcement and implementation
3. Stricter risk assessment procedure for assessment of new technologies
Further information on the three points are available on the uploaded document.
Read full responseResponse to Food waste reduction targets
29 Oct 2021
Safe Food Advocacy Europe – SAFE welcomes the inclusion of the setting of food waste reduction targets in the objectives of the European Green Deal and the Farm to Fork Strategy, and the efforts shown by the European Commission to allow interested stakeholders to express their comments on the proposal to revise the Directive 2008/98/EC on waste.
As highlighted by the Commission, food loss and waste (FLW) reduction is pivotal to decreasing the EU food system's environmental and climate footprint and promoting a shift to healthy and sustainable diets. In this respect, SAFE appreciates the commitment of the European Commission in adopting legally binding targets to ensure that Member States take ambitious actions to reduce food waste and would like to share its feedback on the proposed initiative.
In order to efficiently answer the call for feedback on the roadmap concerning Food Waste Reduction Targets, the attached document will further develop a number of important general considerations regarding FLW policies, and will also examine the reference baseline scenario set by the European Commission for other policy options in its Inception Impact Assessment.
In particular, a 50% food loss and waste (FLW) reduction target by 2030, as explicitly expressed in SDG 12.3 voted by all Member States of the United Nations in 2015, is a minimum for significant change to be achieved. The ongoing process of defining targets for FLW reduction should participate to global objectives for food systems, shaping binding targets at the EU level and matching the Union’s ambition on sustainability and climate change.
We must also stress that voluntary commitments and consumers’ education/awareness-raising, while important, will not be an appropriate answer to the challenges ahead. To make sure that food consumption patterns contribute to a sustainable food systems transition and the success of EU political priorities on FLW reduction, it is important to understand how consumption patterns are established in wider food environments. A “food environments” approach requires policy makers to look at what shapes consumers’ decisions to buy, eat and dispose of food – in other words, the responsibility of tackling food waste should not be put on consumers’ shoulders alone, but instead on all actors shaping food systems (from primary production to retail and wholesale). This can be achieved through financial incentives, taxes and binding measures for these actors.
As regards the EC baseline scenario, we recommend the following:
Step 1:
- Scope: Reduction targets should cover the whole food supply chain, from farm gate to final consumer (S1)
- Expression: Food waste reduction targets should be expressed in absolute amounts, in order to reach an overall 50% reduction target (E2)
- The way targets are set for Member States: keeping the same target level for member states (T1) and defining a collective target at EU level (T3)
Step 2:
As expressed above, it is imperative that the Union keeps a high-level of ambition and does not water down the 50% FWL reduction target defined in SDG 12.3. For this reason, SAFE is calling on the European Commission to favour Option 3 – to reduce food waste in the EU by 50%.
SAFE recalls that significant change cannot be achieved:
- Without legally binding targets for Member States;
- Without a swift transcription of EU measures into national legislations in order to meet the 2030 objectives;
- Without targets that would be fairly divided amongst all sectors of the food supply chain, with higher and stricter binding targets for sectors contributing the most to FLW production.
This initiative constitutes an important opportunity to radically change EU food systems in ways that will be both more respectful of our environment and of consumers’ health and well-being. Therefore, we call on the European Commission to strive for the most ambitious targets and objectives towards the 2030 horizon.
Read full responseResponse to Sustainable food system – setting up an EU framework
26 Oct 2021
SAFE – Safe Food Advocacy Europe – strongly welcomes the European Commission’s recognition of the need of a horizontal framework able to facilitate the transition towards a sustainable food system and support the EU intention to establish new foundations for future food policies by introducing sustainability objectives and principles on the basis of an integrated food system approach.
SAFE agrees with the regulatory issues highlighted in the Inception Impact Assessment (IIA), however, we believe that the following considerations are overlooked in the current IIA, and should therefore be further developed:
• Lack of consideration for nutritional related diseases and lack of clear commitment and objectives to improve consumers food habits.
• Too much focus on a product-based approach.
• Attention on the sustainability assessment and on the “EU wide monitoring framework”.
These three issues are reflected in the absence of specific targets set in the IIA whose lack would prevent to conduct fair and coherent assessments and monitoring of the Initiative. In this regards, SAFE wants to specify the need to include the following binding targets:
• Setting of both production and consumption targets to allow measuring progress towards healthy and sustainable diets.
• The need to set a target for reducing obesity levels of a certain percentage by 2030.
• Strong binding reduction targets (50%) for both food waste and food losses by 2030, across the whole food chain (from the farm all the way to the fork).
Read full responseResponse to Setting of nutrient profiles
29 Jan 2021
European consumers diet is not in line with dietary recommendations. As the Farm to Fork (F2F) strategy recalls, unhealthy diets contribute to the prevalence of many non-communicable diseases including obesity, diabetes and cardiovascular diseases, and their related healthcare costs for society and individuals. In this context, it is crucial for consumers to be able to make informed choices without being misled by unhealthy products whose ingredients information (suggested quantity of sugars, salts, fats to be consumed, additives, colourants, etc...) are unclear.
In the last years, Safe Food Advocacy Europe – SAFE contributed to the debate on a harmonised front-of-packaging (FOP) nutrition labelling, to ensure consumers are enabled to make healthy and sustainable choices. Therefore, SAFE thanks the European Commission for having the chance of commenting on the revision of rules on food information, specifically on following issues: FOP nutrition labelling, date making, and setting of nutrient profiles.
Full contribution in attachment.
Read full responseResponse to Revision of EU rules on food contact materials
27 Jan 2021
Safe Food Advocacy Europe (SAFE) would like to express its view on the raising concern about hazardous food contact materials (FCMs) which are all the materials and articles that are intended to be put into contact with food, and beverages, or will presumably be in contact with food, or beverages.
This response to the current European Commission feedback call would like to draw attention on various health problems caused by FCMs such as endocrine disruptive (ED) effects and increased chemicals found in the human body on account of chemical components migrating from food packaging into food.
As recycled plastic is also a growing concern due to harmful chemicals integrated during recycling processes, SAFE thanks the European Commission to open this feedback session to revise the current FCMs Regulation and ensure a better legal framework for European citizens’ food and health.
Attached the full contribution.
Read full responseMeeting with Stella Kyriakides (Commissioner) and European Environmental Bureau and
5 Jun 2020 · VC Meeting - Farm to Fork
Response to Farm to Fork Strategy
16 Mar 2020
SAFE thanks the Commission for allowing interested stakeholders to express their comments on the Roadmap on the Farm to Fork Strategy for sustainable food systems.
While SAFE appreciates the will from the European Commission to adopt a strategy aiming at the transition to more sustainable food systems for the EU, we would like to point out some elements we believe are essential to the achievement of this ambitious and commendable objective. For a more detail explanation of those elements, please refer to SAFE position paper in attachment.
1. NEED FOR EU FOOD SYSTEMS TO PROMOTE AND MAKE AVAILABLE HEALTHY DIETS FOR ALL EU CONSUMERS
SAFE is welcoming the European Commission’s will to propose a Strategy that also takes into account consumers’ health and well-being. To ensure this Strategy can deliver on this objective, we believe that it should include the following points:
1.1. The creation of EU healthy diet guidelines
1.2. Stricter origin labelling for meat and dairy
1.3. Create EU guidelines for public procurement promoting sustainable and healthy food and amend the Public Procurement Directives
1.4. Promotion of products reformulation to decrease sugar, salt, and fat contents
1.5. Create an environment orienting children and teenagers to healthier food choices
1.6. Amend the EU Food Contact Material Regulation
2. NEED FOR THE FARM TO FORK STRATEGY TO ANSWER CONSUMERS’ DEMAND FOR MORE SUSTAINABLE PRODUCTS
Consumers’ concerns about climate change and the environment are now impacting their expectations regarding the food they consume. They are increasingly asking for the opportunity to be able to purchase and consume food produced in a way that respect the environment and limits its impact on climate change. Furthermore, producing food in a more sustainable way can also protect consumers from the health issues linked to the use of chemical pesticides or the excessive reliance on fertilisers. Therefore, SAFE congratulate the Commission’s initiative to launch a Strategy aiming at making food systems more sustainable. In particular, we believe that this Strategy should focus on:
2.1. Promote more sustainable way of farming such as permaculture and stock-free organic farming
2.2. Promote the production and consumption of plant-based proteins
2.3. Creation of a sustainable labelling framework
2.4. Reduce food waste with a special attention to harvest food waste
3. CONCLUSION
SAFE congratulates the Commission for launching a public consultation on the Roadmap on the Farm to Fork Strategy for sustainable food systems. We believe that this Strategy constitutes an unprecedented opportunity to radically change EU food systems in way that will be both more respectful of our environment and of consumers’ health and well-being. Therefore, we call on the European Commission to strive for the most ambitious objectives possible and fix specific targets to make sure to achieve those objectives.
Read full response21 Jun 2019
SAFE thanks the Commission for allowing citizens and interested stakeholders to provide a feedback on the migration limits for lead, cadmium and other materials from ceramic and vitreous food contact materials.
We take this opportunity to provide the Commission with inputs on the issues which need to be covered during the impact assessment and we would like to point out some elements that are worthy of concern.
First of all, there are many materials largely used as FCMs (such as paper, ink, adhesive or glues) which are not controlled by harmonised EU-level laws. Even though they are commonly used in Europe, they are unregulated and their safety has not been evaluated by any national authority. On this matter, we recommend the adoption of specific rules on those non-harmonizingly regulated materials and encourage the Commission to adopt a legally binding legislation which includes all FMCs to secure a higher level of protection for EU consumers.
Thanks to its chemical composition, glass presents several advantages for food contact material applications and is considered to be safer when compared to plastic. Latest data show glass recycling rates reached 74% across EU member states, with more than 11.6 million tons of glass bottles which are transformed into new glass containers. However, repeated recycling of glass may lead to the accumulation of unwanted substances in the material which may form during the recycling process. Therefore, SAFE would like to draw the attention on the recycled and reusable glass and calls for a binding legislation to guarantee its safety. For instance, glasses from applications other than packaging should not be included in container glass recycling due to a different chemical composition which can affect the safety of the material by introducing hazardous elements.
Lastly, with regard to ceramic articles, the current EU legislation (Directive 2005/31/EC) regulates only the well-known elements of lead and cadmium while it does not consider other metals, such as aluminium, cobalt, chromium, manganese, fluorine, arsenic, nickel or zinc which cause high safety concerns as well. Studies show those elements represent considerable risk for public health as they can potentially migrate from the material into foodstuff, especially in case coloured glazes are applied. It is therefore important to have updated studies on the issue to minimize the migration of heavy metals through good manufacturing practices.
In conclusion, SAFE calls for a comprehensive legislation which takes into consideration other toxic trace elements with a view to ensure a higher level of protection among European consumers.
Read full responseResponse to Establishment of a methodology of measurement of food waste
28 Mar 2019
We commend the Commission’s recognition of food waste as an urgent issue which needs to be addressed to ensure environmental sustainability – and the obligation on member states to measure food waste is an excellent step in this direction.
However, we are concerned that food that is ploughed back in or left to rot in fields has been excluded from EU measurement. Between 11-34% of EU’s food waste occurs at primary production level, and the majority of this is left in the field. Harvest food waste is food that is mature enough to be ready to harvest, but wasted at the harvest stage through being left to rot or ploughed back into the field. It is vital that the EU provides guidelines to enable member states to at least voluntarily report their harvest food waste.
Additionally, the Commission needs to urgently clarify that food wasted at later stages of the supply chain, but then returned to their agricultural suppliers to be ploughed back into the field, should be measured as food waste at the stage of the supply chain where it is wasted, before it is returned to the farm. Otherwise, this is a significant loophole which could perpetuate and worsen the current situation of companies dumping food waste on their agricultural suppliers.
If it is not legally possible to include harvest food waste in compulsory measurement, the Commission should:
• Add harvest food waste as an additional point (f) under Article 3 which member states can voluntarily report on – defined as edible food that is mature and ready for harvest but wasted at the harvest stage by being ploughed back in or left to rot in the field
• Provide examples of some means of harvest food waste measurement in Annex III and IV – such as physical measurement, crop-cutting surveys or visual assessments.
• Recommend as best practice to member states that they measure and report harvest food waste
• Fund several member states to conduct pilot studies of harvest food waste in their countries
Please find in attachment a policy paper detailing the argumentation supporting our view on this draft.
There are many cases of farmers who are forced to plough whole fields of produce back into the soil, or leave thousands of tonnes of their produce in the field due to factors like cosmetic outgrading and last minute order cancellations from retailers each year. Measuring harvest food waste would help EU farmers avoid the costs of food waste, reduce Unfair Trading Practices and carbon emissions, liberate nutritious food for EU food security, and save valuable land. Separating farm food waste from the Waste Framework Directive would force member states to treat farm food waste in silo, punishing farmers for food waste which is often the result of retailer policies. Not providing guidelines for measurement of harvest food waste will send the message that this is insignificant, inhibit member state measurement and reduction of this food waste, and harm farmers and the environment.
Yours sincerely,
Read full responseMeeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis) and Global Feedback Ltd
6 Dec 2018 · Statement on food waste measurement methodology
1 Feb 2018
SAFE welcomes this initiative and thanks the Commission for allowing Consumers’ Organisations to express the collective EU consumers’ opinion on this matter. SAFE supports a mandatory Country-of-Origin Label (CoOL) as it is better for consumers.
While SAFE appreciates the fact that this much-awaited proposal was finally published, we would like to point out the following elements that are worthy of concern:
_ The voluntary character that appears in the Commission’s text is difficult to accept seen the legislative framework of FIC. SAFE recalls that art.26 (3) FIC, to which the implementing regulation applies, is part of FIC’s Chapter IV, “Mandatory Food Information”, Section 2, “Detailed provisions on mandatory particulars” (art. 17-28). There is some paradox arising from the Commission’s text, as it seems that the approach chosen is voluntary despite referring to mandatory legislative provisions.
_ SAFE believes that withholding the primary ingredient(s)’ provenience misleads consumers, for example when consumers have environmental criteria. Furthermore, labels are not included in this implementing legislation, hence producers may use an identifying symbol of a Member State in their products’ labels, whereas none or very little of their products’ ingredients was grown and/or processed in said Member State. Mandatory CoOLs are the adequate answer to prevent such unfair actions.
_ SAFE wonders what certain proposed definitions could mean, and what they imply for consumers. “EU and non-EU” is questionable if it does not spell out the proportions of the EU and non-EU parts of the food. Consumers may be misled to think that, when this label applies, the product may be 50% from the EU and 50% from outside the EU. With no further details, the most informed consumers would find difficult comparing products if they must consider that, under a “EU and non-EU” label, the part of the product coming from the EU goes from 99,99% to 0,01%.
_ A “non-EU” label which does consider all non-EU provenance as the same will be too vague. Any normally informed average consumer would search such information firstly, and foremost, on the food package. Removing such information, or providing a too broad provenience, will prevent a consumer to be normally informed.
_ With the “Region, or any other geographical area either within several Member States or within third countries” label, SAFE wonders if foods from Regions across EU external border are considered identical, whether produced in EU or not. For such foods, SAFE sees that the proposed implementing regulation, while attempting to create legal certainty, may bring in more uncertainty for the consumers.
_ To ensure that origin information is not misleading consumers and allows to make enlightened choices, SAFE cannot accept art.2 (b) of the proposed implementing regulation: leaving to producers the possibility to declare that “this ingredient is not from the country identified as Country-of-Origin of the food”, without specifying its actual origin, could create more confusion for consumers. Art.2 (b) allows partial and misleading information.
_ SAFE wished for the Commission to follow the European Parliament resolution of 12 May 2016 on mandatory indication of the country of origin or place of provenance for certain foods, which acknowledged that the most complete indication of the country of origin or of the provenience of food, or of ingredients used in foods, increases consumers’ confidence in the food chain by increasing the transparency of the product, and can be a useful tool (among others) to prevent food fraud.
Read full responseResponse to Transparency and sustainability of the EU risk assessment model in the food chain
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 weaken the outcome of the assessment and, consequently, of the political decisions that are build upon. Food safety in Europe is related to the capacity of the European independent agency to carry out a proper assessment on the potential harmful effects of the tested substances. If this risk assessment is not reliable and based on verifiable scientific data, and the EU relies on non-publicly available documents and non-independent experts for such important decisions, then the health of EU citizens is not protected.
It is fundamental for EFSA to regain a serious credibility in the EU. If its work is not deemed trustworthy by the EU consumers nor by independent scientists, it cannot support, in an efficient manner, strong European policies. The glyphosate affair, unfortunately, demonstrated the lack of trust from founding Member States such as Italy, France and Belgium towards EFSA’s risk assessment on glyphosate. This is a very risky and dangerous position for the future of EFSA; there is an urgent need to improve EFSA’s risk assessment model.
SAFE has already proposed various solutions to the EU risk assessment model’s transparency and sustainability, in the area of the food chain. During its last Annual Conference, titled “EU Food Safety Regulation: Putting Consumers First – An overview of current issues and how to increase consumers’ protection”, which took place on March 21st, 2017 . How awareness could be raised and how better assessments could be achieved were actively discussed during the conference’s workshop, to which several NGOs, industry stakeholders and civil servants from EFSA participated. Confronted to the question “How can EFSA bring consumers and stakeholders together?”, the participants proposed the following recommendations for EFSA that would be satisfying for both stakeholders and consumers :
• To strengthen the information to consumers and to raise awareness about food components, which should be done by enhancing direct communication via short commercials on social media and on television;
• To provide independent, industry-free information, to consumers;
• To organise forums and discussion that will effectively involve all stakeholders in the risk assessment process, and that should not be just consultative events;
• To strengthen the data transparency, by publishing all research documents from EFSA;
• To provide for the independence of research, thanks to economic independence of EFSA: we propose it to be done through an “industry tax”.
Read full responseResponse to Evaluation of Food Contact Materials (FCM)
22 Dec 2017
Due to the evolution of scientific knowledge, changes in practices, new materials emerging, experience acquired in the last decades, and more consumers’ awareness, it is time to update the Regulation 1935/2004 to answer current questions and gaps and to face future challenges.
SAFE considers that the Commission must address the legal issues arising from the current regulation: while the general principle for FCMs is that it can be found in food under a certain risk quantity (scientifically determined), common standards on these risk quantities are not uniform in the EU for all FCMs, leading to dangerous doubts and gaps that hamper the internal market and the interests of consumers. Supporting the findings of the European Parliament, SAFE recommends the adoption of specific EU rules for non-harmonized materials.
SAFE is also worried about shortcomings in traceability, enforcement and controls. Deeper harmonisation is required on enforcement controls, still differing across Member States. SAFE believes better framework rules, helping Member States to perform regular monitoring and in situ controls more efficiently as well as ensuring that they have the necessary staff trained to do such controls, will result in a safer food for consumers.
The fact that some essential rules, such as the standards to draft declarations of compliance, mostly remain at the Member States’ discretion, does not allow to secure a high level of protection of human health and the interests of the consumers. SAFE believes that the Commission should engage in benchmarking and harmonising to develop single EU standards (especially for FCMs analytical testing).
Furthermore, any improvement in the FCMs’ regulation’s functioning should impact EFSA, whose capacity to effectively control FCMs is not optimal. The general task of evaluating substances intended to be used for and additional risk assessments in relation to FCMs are carried out by the Panel on Food Contact Materials, Enzymes, Flavourings and Processing Aids (CEF), which is also responsible to answer to ad-hoc requests from the Commission to review FCMs in the light of new scientific information and/or changing conditions and/or use. Therefore, CEF’s capacity to perform independent analyses and to coordinate more the activities of national authorities is essential for the good performance of an independent scientific assessment.
Going into more details on the scientific assessment, SAFE supports the findings of the CES Scientific Opinion of December 2015, in which it is clearly stated that the tiered approach recommended by the SCF in 2001 is updated based on scientific progress. There is the need, SAFE believes, for new guidelines, foreseeing more accurate analyses and new research. SAFE supports CEF’s suggestion to perform new screenings on toxicity data related to the expected human exposure level (higher exposure, greater risks). This is very important in areas, such as recycled materials, Cocktail Effects and NIAS, that have not been sufficiently investigated yet.
SAFE believes that there is a necessity for the FCMs’ legislation to propose clear, general legal criteria defining endocrine disruptors (ED), together with a comprehensive policy response to it. A holistic approach towards food contaminants should be envisioned. Given that EDs are found in FCMs, therefore potentially in consumed foods, any FCMs legislation not assessing them will threaten the EU's precautionary principle whereas the latter should however be the prime focus of this legislation. With EDs still under investigation, SAFE believes this is an opportunity for deeper research, including EDs in the FCMs deeper researches advised by CEF.
Finally, SAFE argues that better coordination between the various legislative texts, in particular regulations on FCMs and REACH, should be foreseen. Consequently, agencies involved in assessing in each regulation (EChA, EFSA) need to cooperate.
Read full responseMeeting with Vytenis Andriukaitis (Commissioner) and
9 Dec 2016 · Acrylamide