As part of the EU Food Information to Consumers (FIC) regulation, an independent report on the impact of mandatory country of origin labeling was recently filed to the European Commission (EC) for review.
Conducted by an external consultant, the report pooled data and comment from a number of food and drink manufacturers and associations, including the ESA. A final report from the Commission is expected by the end of the year.
Ylenia Maitino, regulatory and scientific affairs manager for the ESA, said the association had willingly participated as country of origin labeling for snack makers was a “very big concern”.
“The concern is that our supply chain, especially for our products and our sector, is very complex. So this means, for example, our members don’t get their ingredients or raw materials from just one source or one origin; we have multiple sources and origins that obviously depend on so many factors, the main one being seasonal variations,” she told BakeryandSnacks.com.
Potatoes and nuts: A multi-origin supply
While industry agreed that misleading statements should not be made, a mandatory origin labeling system would be “really problematic” for ESA members and the broader snack sector, she said.
With potato snacks, for example, there is no single potato variety that could supply EU manufacturers all-year-round, meaning companies rely on different supplies throughout the potato crop season.
On average, savory snack makers changed potato origins up to six times per year, according to an internal ESA member survey. One ESA member in the UK, for example, sourced potatoes from seven merchants and these merchants sourced from 50-70 different growers.
Manufacturers mixed product to ensure consistent quality and feed to packing lines, Maitino explained, and so while traceability was maintained, origin labelling would be “an impossible logistic challenge to meet”.
“And it’s even truer for nuts and nut-based snacks,” she said. “Nut processors rely on shipments and third world countries and there can be delays; there are controls at the port of entry, so they always have to have good planning but also contingency plans. This means they can’t rely on just one source, they’ll have to have multiple sources.”
One major European nut processor, for example, changed its supply 60-70 times per year, she said.
The same complex supply chains applied to snack makers working with corn and other cereal-based products, she added.
“In terms of practicality, if you have a product which has so many origins and you have to state all the origins, imagine what the labelling would look like.”
No help for consumers or food safety, choice would be better
From a consumer standpoint, Maitino said mandatory origin labeling would “bring little benefit for consumers, would definitely have an impact on cost, and would have no impact whatsoever on food safety”.
The link between origin labeling and food safety was a mistake often made, she said.
“We think it would be even more misleading to consumers, suggesting to them that the origin of part of a product would imply a higher level of food safety and quality.”
Asked what the ESA would want instead of mandatory food origin labeling, she said: “Well, I suppose the status quo – whoever wants to state the origin is free to do so.”
For certain food sectors there was a clear desire to cite country of origin, she said, and systems were already in place that enabled these manufacturers to do so.