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Application A583 – Country of Origin Labelling Requirements for Unpackaged Pork Products – Initial Assessment Report

7 February 2008

Dear Sir/Madam

Thank you for the opportunity to comment on this application. The New Zealand Food Safety Authority (NZFSA) has the following comments to make.

In 2005 New Zealand opted out of the Standard mandating Country of Origin labelling (CoOL), under the provisions of Annex D of the Food Treaty, on the grounds that implementing the Standard in New Zealand would impact third country trade.

New Zealand has maintained a consistent domestic and international position in opposition to mandatory CoOL. Any reduction in the scope of the Standard1.2.11 (Country of Origin Requirements) (Australia Only) is consistent with New Zealand’s position on CoOL.

For many years New Zealand has favoured a voluntary system of CoOL. The reasons for taking this position include:

• CoOL does not provide information relevant to food safety or public health (which is the primary reason for existing mandatory labelling requirements);

• it is potentially trade restrictive;

• relevant and adequate legislation governing deceptive practices already exists in current consumer legislation;

• to maintain access for New Zealand exports to overseas markets, New Zealand has consistently opposed mandatory CoOL in various international fora;

• it is primarily a marketing tool, not a consumer protection measure, and is best employed voluntarily by companies in response to consumer demand;

• it may be anticompetitive and may mislead consumers as to the quality or environmental impact of a product;

• the cost of mandatory CoOL to industry and consumers would exceed potential benefits; and

• it is a competitive disadvantage to countries such as New Zealand that rely on a high proportion of imported ingredients in food manufacturing.

NZFSA would be interested in the outcomes of the cost/benefit analysis for A583 and any investigations regarding consumers’ understandings of CoOL requirements, including the value consumers place on information regarding CoOL and how it influences their ability to make informed choices.

NZFSA considers that the Draft Assessment Report should make reference to the New Zealand situation, i.e. that New Zealand has opted out of the CoOL Standard and that Application A583 is therefore “Australia Only”.

Yours sincerely