Letter from Greenpeace in response to McDonald's Letter
20 April 2004
Director of Corporate Relations
PO Box 6644
Cc; Alan Dunn (McDonalds CEO); Mike Rozen (Inghams Managing Director)
Thank you for your letter of 2 April 2004. I write in response to some of the points you make regarding McDonalds policy on GE ingredients and feed.
Firstly Greenpeace commends you for what efforts McDonalds has already gone to in exclusion of GE crop derived ingredients from your products.
There may be more clarity required in terms of what Greenpeace regards as reasonable and thorough GE crop exclusion in that we do not consider the FSANZ (formally ANZFA) compliance standard to be an adequate assurance of a non-GE crop derived status.
However, neither do we expect “solemn declarations” or 100% guarantees of a total GE free status because, in the case of some ingredients, such as soy derived ingredients and animal feed, we acknowledge it may be difficult to reliably achieve a 100% purity. For this reason we consider, in the case of soy meal animal feed, that a 99% purity is a reasonable standard and expectation for any non-GE claim, and as you point out, this is what Tegel New Zealand claim to be consistently achieving for their soy meal feed.
It is worth noting that this is a standard also met by a number of poultry companies in Europe with considerably larger feed demands than Ingham, such as Grampian. In regard to international best practice regarding 1% contamination thresholds, please also note that under new European labelling regulations any ingredient, including feed, with less than 0.9% GE derived content does not require to be labelled as a GMO, but above 0.9% it does require to be labelled. I also note, as is my understanding, that McDonalds has a Europe wide policy of excluding GE in food and poultry feed.
McDonalds avoidance of GE ingredients and feed should not only be done out of a commitment to customer preference and concerns about potential health impacts but also out of a commitment to environmental sustainability. In terms of the environment, non-GE feed supply is very important because it avoids the known and potential harms that GE crop production poses to our agriculture, food supply and environment, such as increased chemical use, lower yields, herbicide resistant weeds and contamination of conventional and organic crops – all of which have resulted from the growing of GE soy in the US and Argentina.
My inference from you letter and our earlier conversation is that McDonalds has or is moving towards a position of preferring that your suppliers are providing animal products, and chicken specifically, that is raised on a diet of conventional or non-genetically engineered feed. However your policy does not actually require this of your suppliers.
In terms of the GE Free Food Guide there are three categorisations. The green category is for companies that have achieved a non-GE crop derived status for both animal feed and ingredients. The orange category is for companies that have an explicit policy of excluding GE crop derived ingredients and feed. The red category is for companies that do not have an explicit non-GE feed and ingredient policy or fail to respond adequately to requests for information.
Unfortunately, whilst we acknowledge your apparent consideration of a non-GE feed commitment, you have as yet no stated policy of excluding GE feed and you certainly have not achieved a non-GE feed status so we cannot categorise McDonalds as orange or green.
I was initially happy to hear that Inghams have a shipment of what they claim is non-GE soy arriving in June. However, contrary to what you assert that “every effort will continue to be made to source non GMO feed”, Mike Rozen has stated that Ingham were not and are not seeking a regular supply of non-GE soy. It seems from what Mr Rozen tells me that it is an accident of circumstance that the soy Ingham are getting may be non-GE. He has also pointed out that it is not a certified or Identity Preserved (IP) supply so there can be no assurance of the actual non-GE purity of the soy.
Mr Rozen claims that Ingham will continue with this supply source if it is of a quality that they are happy with but there is no actual commitment to specifically sourcing non-GE soy on Inghams part now or into the future. This situation is entirely unsatisfactory in that the June shipment or subsequent shipments could be of a significantly GE contaminated status. Thus no one can rightly claim a non-GE feed policy on the basis of this single unverified shipment.
Any claim of a non-GE feed status or actual commitment to sourcing non- GE soy needs to be supported by appropriate testing of the supply and documentation of it’s non-GE status. Responsibility for such verification obviously sits with your supplier if this is what you require of them.
Greenpeace certainly has an understanding of the “complexity of the issues,” and we seek to make our position as clear as possible at all times. Ultimately any company, McDonalds included, is fully responsible for ensuring it is receiving non-GE ingredients and non-GE feed derived animal products from its suppliers, if that is what it wants.
I once again urge McDonalds to establish an explicit non-GE feed policy for your animal products in line with your existing GE ingredient exclusion policy and in line with your European counterparts non-GE poultry feed policies. Until such time I am sorry that McDonalds will be classified in the red section of the Greenpeace GE Free Food Guide.
The Guide is due to be launched on the fourth of May, at which time, as I assured you, statements from your letter regarding McDonalds policy will be published in our online guide.
I remain available to discuss or clarify these matters at any time.
Steve Abel Genetic Engineering Campaign