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the eu's food industry association is calling for a raft of changes to proposed laws, calling some of them unworkable and misleading, including those that would regulate additives and enzymes, flavourings, additives, chemicals and health claims. the eu has been in the process of placing the food industry under increasing regulatory control, mainly due to public concerns about safety, quality and the amount of information it receives about the products they eat. current eu legislative proposals include revisions to current laws or new legislation on additives, enzymes, food contact materials, fortification, novel foods, organic food, nutrition, functional and health claims, sweeteners, infant formulae, chemicals and greenhouse gas emmissions. the proposals are made in the latest memorandum issued yesterday by the confederation of food and drink industries of the eu (ciaa). the document serves as an outline of the group's agenda for lobbying the european commission and politicians this year. the ciaa issues such memorandums as advice to the country that takes over the leadership of the eu presidency every six months, in this case austria. in relation to the european commission's draft proposal for regulations on additives and enzymes, the ciaa finds it "unnecessary and inappropriate" to limit the authorisation of food additives and enzymes to a period of ten years. the proposed law currently requires food firms to go through a reauthorisation process every 10 years. "ciaa considers that the safety of food additives and enzymes should be re-evaluated on the basis of new evidence, as and when this becomes available, not on the basis of an arbitrary time scale," the association stated in its advice. the ciaa also has "serious reservations" about the proposed change to the definition of "processing aid" in the draft proposals. the ciaa wants the definitions of additives and processing aids in 89/107/ec to remain unchanged. "the revised definition as it is now drafted is unworkable and will lead to difficulties in interpretation," the group stated. "moreover, it is no longer in line with the codex definition. the proposed revision of the definition would, without any change to the product or process, automatically move many enzymes into the definition of 'ingredient' in terms of labelling requirements. ciaa cannot accept such a fundamental change in labelling principles, as this will cause chaos and confusion in the marketplace, without offering any benefit to the consumer." currently some enzymes used as additives are regulated under directive 95/2/ec on food additives other than sweeteners and colours, whereas others that are used as processing aids are subject to the laws of individual member states. the proposal consolidates the frequently revised specific additives directives issued by the eu. the proposal would create a "positive" list of additives and enyzmes that may be used in food production. in general the ciaa commends the law for consolidating the process for the authorisation and review of additives and their uses. the ciaa also supports the harmonisation of safety assessment provisions for food enzymes used in the eu. the association also supports the introduction of the eu's "comitology procedure" for all technical provisions and a centralised risk assessment process, to be undertaken by the european food safety authority (efsa). "comitology" describes a process in which the commission, when implementing eu law, has to consult special advisory committees made up of experts from the eu countries. while the ciaa generally supports the draft proposal for a regulation on flavourings and food ingredients with flavouring properties, it is against the removal of the "nature identical" category in the definitions. flavourings are substances used to give taste or smell to food. community legislation currently defines flavourings as either natural, natural-identical or artificial, labels food makers can use in describing the ingredients in their products. some man-made flavours are referred to as being nature identical flavourings. this category of flavourings is identical to natural flavours but manufactured synthetically. artifical flavours are synthesised flavours not found in nature. the ciaa says the removal of the "nature identical" category may have financial implications for the food manufacturing industry, which are likely to increase costs to consumers. ciaa also believes that any attempt to change the labelling terms for the benefit of the consumer should focus on providing the consumer with more meaningful information, rather than simply more information. in general the ciaa welcomes the commission's revision of the current flavourings directive (88/388/eec) and supports the introduction of the comitology procedure for authorisation and for setting maximum levels. the group also supports the draft's scope, the definitions concerning food ingredients with flavouring properties and the exemption of substances that have exclusively a sweet, a sour or salty taste. raw or non compound foods, such as spices, herbs or tea, are also excluded from the draft's scope. "ciaa supports the general intention to revise several aspects of the framework directive 88/388/eec but considers that the revision should not be overly ambitious and try to deal with too many issues at once," the group stated. "in particular, perceived safety concerns linked to the consumption of biologically active principles should not be addressed since this risk has not been fully assessed yet." the ciaa also criticises the commission's draft proposal for a regulation on chemical use in the eu. the ciaa says even after a major watering down of the legislation in favour of industry, the current proposal still leaves the position of the food and feed sector unclear. a number of product categories, including some food ingredients, have been excluded from the scope of the reach proposal since they are covered by other eu legislation. "the fact that some food materials are in, and some are out of the scope, causes confusion and inconsistency at many levels," the ciaa stated. existing eu food and feed legislation already ensures the general objectives of a high level of protection of human life, health and consumers' interests, the ciaa argues. ciaa has petitioned the commission to make further amendments explicitly excluding all food, feed and their ingredients from its scope. this would help to achieve consistency within eu legislation and avoid duplication of legislation, the group argues. it would also avoid confusion between the responsibilities of efsa and the new eu chemicals agency. on a draft proposal for a regulation on nutrition and health claims on foodstuffs the ciaa calls on the austrian presidency to make changes to article 12, which sets the principle for a community list of permitted claims based on generally accepted scientific data. such a list should be a list of relationships between a nutrient, food component or a food and a health benefit rather than a list of claims. the remit of the efsa should be limited to the evaluation of the scientific substantiation. the responsibility to communicate with the consumer on the basis of the established scientific substantiation, should be left to the responsibility of the food business operator, the ciaa believes. for the same reasons, the procedure should be limited to a general set of principles controlling the scientific substantiation of the claim. the control of the wording should be left to the responsibility of the food business operator. the procedure itself should be proportionate and predictable, the ciaa stated. "all claims that are scientifically substantiated and well understood by consumers should be permitted," the ciaa believes. "the communication of the claim as such (wording of the claim) should remain the responsibility of the food operator. ciaa believes that the criteria for the substantiation of a claim should be the same for all types of claims in terms of evidence. however, the process of evaluation may differ." the principle of proportionality should apply to both the level of substantiation that is required to make a claim and to the marketing procedures applicable to products bearing claims, the ciaa stated. the bill has had its first reading in the eu parliament. a political agreement on the bill by member states was made early in june 2005. on a draft proposal for a regulation relating to the addition of vitamins, minerals and certain other substances to foods, the ciaa calls for a limiting of efsa's remit. the legislation sets the principle for a eu list of permitted claims based on generally accepted scientific data. such a list should be a list of relationships between a nutrient, food component or a food and a health benefit rather than a list of claims, the ciaa believes. the remit of the efsa should be limited to the evaluation of the scientific substantiation and the responsibility to communicate with the consumer should be left to the responsibility of the food business operator. the ciaa commends the draft law as a positive step towards the creation of a real single market for fortified foods. consumer safety must be the only criteria for the fixation of maximum levels for the addition of vitamins and minerals to foods, the ciaa stated. "from the market viewpoint, statistics strongly prove that liberal regulations on fortification have not led to the indiscriminate use of fortified foods," the ciaa noted. "as regards legal concerns on the marketability of a product, any potential restriction should be defined on a case-by-case basis and should be fully justified on public health grounds." the ciaa is also concerned about the development of the eu's geographical indication (gi) system. the gi system was established to protect a product's name that is based on specific quality, method of production or geographical link. gi products can be classified as pdo (protected designation of origin), pgi (protected geographical indication) and tsg (traditional speciality guaranteed). a pdo describes foodstuffs produced, processed and prepared in a given geographical area using recognised know-how. in the case of the pgi the geographical link must occur in at least one of the stages of production, processing or preparation. a tsg does not refer to the origin but highlights traditional character, either in the composition or means of production. currently there are about 720 food names protected under the system and 300 applications pending. "this tendency to such a rapid increase of registered names and an insufficient assurance as regards the specific characteristics of the products may make pdo and pgi products commonplace," the ciaa stated. "there is a risk that foodstuffs recognised as pdo or pgi lose their comparative advantage." the commission plans to submit a proposal amending the regulations on pdo and pgi for agricultural products and foodstuffs to the council of ministers in the coming months. the ciaa called for technical amendments to the regulations to clarify and improve the procedure for registration. the commission recently published proposed amendments to the regulation to bring it into compliance with the conclusions of a world trade organisation ruling. ciaa called for member states to identify a national body specialised in the monitoring of markets.