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Country of Origin Labelling
Why has New Zealand taken this position on CoOL?
• New Zealand has favoured a voluntary system of CoOL labelling for domestic foods for many years.
• The reasons for not supporting mandatory CoOL include: cost to consumers and industry, flexibility for destination market if labelling not mandated and the high prospect of New Zealand processed foods including ingredients from other countries.
• New Zealand exports between 80 and 90% of all food produced. We need as much flexibility as we can for marketing our food and that applies to both domestic and export markets.
• New Zealand’s position internationally on CoOL is entirely consistent with our domestic position – that CoOL is a commercial and trade matter and we will oppose it being mandated on imported products where ever we can.
• Australia and New Zealand have both separately also voiced opposition to Bills in the US and Canada proposing mandatory labelling for meat imported into these countries claiming that it will act as a barrier to trade and will add unjustifiable costs to Australian and New Zealand products.
Is CoOL a food safety issue?
• No. CoOL is a commercial decision for consumer information purposes only.
• CoOL says nothing about the safety of the food.
• If food manufacturers considered they could get market advantage by labelling product as ‘product of New Zealand’ for the domestic market then they are free to do so.
What assurance about food safety can be given to consumers?
• Food needs to enter the market place as safe. Once it is in the market, it is too late. This is why we have pre-market assessment for foods such as additives and processing aids, novel foods and GM foods.
• New Zealand and Australia have both argued – in Codex and in response to other country’s seeking to impose CoOL – that food should be safe before it enters the marketplace and that current pre-market clearance processes for foods are one of the best assurances that foods pose no threats to human health.
What about post-market problems with food?
• Sometimes there are problems with our foods and we need to notify the public about these and recall them. We do this by using more accurate information - producer/processor identification, product description and batching. These are already mandatory in the Food Standards Code and in our primary production legislation.
• If there is a problem with other products such as a car these are not recalled as ‘made in Australia’ or ‘made in Japan’ they are recalled by manufacturer, by description and by model. Food is no different.
But aren’t there already mandatory CoOL requirements in New Zealand?
• Foot wear and clothing (a carry over from high tariff times) and wine (currently a transitional standard in the joint Australia New Zealand Food Standards Code while New Zealand determines its position on this matter).
What ‘Buy New Zealand’ Programmes are available?
• A ‘New Zealand Made’ programme has been in place in New Zealand since 1988 – the symbol is a stylised ‘red kiwi in a blue triangle’ and ‘New Zealand Made’ across the bottom. The objective is to encourage buying New Zealand products on the basis that this helps to create jobs, promote growth and improve our balance of payments.
• The ‘Buy New Zealand Made’ campaign is a user pays programme a bit like the Heart Foundation ‘Pick the Tick’ programme – participants pay to use the symbol based on an annual fee between $150 and $5,000 depending on the size of the business.
• Other commercial programmes are around – in Feb 2003 one of the supermarket chains has established a ‘Celebrate New Zealand’ event to promote New Zealand products and a number of well known suppliers are participating in it as an annual event.
• A new programme is under development that will greatly expand the use of ‘Buy New Zealand’ efforts.
Who regulates origin information in New Zealand now?
• The Fair Trading Act regulates on misleading and deceptive labelling.
• The Commerce Commission published a booklet in 1999 on “Place of Origin – a guide for importers, manufacturers and retailers”
• The Fair Trading Act does not require all products to be labelled with a place of origin but where it is so labelled, the information on a product must be truthful.
• Case law supports this – a distributor was fined for falsely representing that canned tomatoes from Spain were of New Zealand origin. Although “Espana” was stamped on the top of the can, the wrap-around label said “Product of New Zealand”.
Background on the Australian review of its domestic position on CoOL and New Zealand involvement
• CoOL was under review by Australian National Food Authority in the early 1990s and has continued to be reviewed to the current date.
• Responsibility for review passed to the Australia New Zealand Food Authority (ANZFA) in 1996, the time when New Zealand joined with Australia to set joint food standards.
• ANZFA conducted an ‘Initial Assessment’ in June-July 2001 (Proposal P237).
• ANZFA asked ANZFSC (Australia New Zealand Food Standards Council) for policy guidance on CoOL in Oct 2001. This responsibility passed to the successor body, the Australia New Zealand Food Regulation Ministerial Council (ANZFRMC) in July 2002.
• The Food Regulation Standing Committee (FRSC - set up to advise first ANZFSC then ANZFRMC) established a Working Group to consider issues (Feb 2002).
• ANZFRMC considered the matter and its decision was reported in its Communique of 12 December 2003. At that time a policy guideline was issued by ANZFRMC for FSANZ to draw on in developing a Standard. The Policy Guideline is on the Food Regulation Secretariat website at http://www.foodsecretariat.health.gov.au/policydocs.htm
• FSANZ issued a draft assessment in March 2005, a further assessment in August and a final assessment in September.
Australia’s position
• Australia has taken one position internatioally – opposing CoOL (for the same reasons as New Zealand – it is a major food exporter and this non-safety related labelling adds costs to trade for no safety gain) and another position domestically – supporting CoOL.
• Australia has retained CoOL domestically for many years and the current review has been underway in Australia for over a decade.
• Australia also has a very strong ‘Buy Australia’ programme which has recently been expanded to include a new programme for primary/food products.
New Zealand’s position
• New Zealand has taken a coherent and consistent position on CoOL in relation to food both nationally and internationally. CoOL in New Zealand for cheese was repealed in 2002 and the final area where CoOL currently applies in food (wine) is under active review.
• New Zealand has consistently advised of its position on CoOL to FRSC, ANZFRMC and latterly to FSANZ in its development of a standard.
• The joint food standards setting process provides that New Zealand may vary from a standard on the grounds of exceptional health and safety, third country trade, environmental or cultural factors.
• New Zealand’s position historically has reflected the view that CoOL is a commercial matter and is supported for voluntary application. CoOL is not a food safety matter and, for a major food exporting nation, would add costs to trade for very limited but unquantifiable consumer benefit.
• On this basis, New Zealand has sought to vary from the proposed mandatory CoOL standard on grounds of third country trade. New Zealand has effectively ‘opted-out’ of the joint standard.
New Zealand Food Safety Authority
68-86 Jervois Quay
PO Box 2835
Wellington
NEW ZEALAND
Phone: +64 4 894 2500
Fax: +64 4 894 2501
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