Cablegate: No Implementation Plans For

This record is a partial extract of the original cable. The full text of the original cable is not available.




E.O. 12958: N/A

1. Summary The Italian Feed Association
Assalzoo convened feed manufacturers and
Ministry of Health officials in Bologna on
March 18 to discuss Italian implementation of
Traceability and Labeling (T&L) and Food and
Feed regulations (F&F). The meeting came one
month prior to the deadline for enforcement
of the EU Council's regulation on T&L.
Industry contacts confirm that without
further GOI or EU guidance T&L and F&F are
unworkable. The GOI showed no evidence of
detailed implementation guidelines on
testing, sampling, or penalties ready to
launch in April.

2. Assalzoo convened their membership by
invitation to what they called a technical
session, attended also by GOI Health
Ministry officials empowered to address T&L.
The Ministry of Health's advisory board, the

Instituto Superiore di Sanita (ISS),
participated but did not take up new issues.
A rudimentary reading, but no interpretation,
of the Commission's T&L
regulation was given. Assalzoo's audience
already understood the situation in Italy:
the country imports 90% of soybean
consumption; imported soybeans are probably
mostly biotech-grown; these are legal
imports, and have been consumed widely in
animal feeds in Italy for years. In April
they will have to be labeled, as will soybean
or corn oil sold at the consumer level; meat
and cheese derived from animals fed biotech
soybean are not subject to labeling.

3. Italy depends on imports for 90% of its
soybean consumption; Assalzoo sought to
clarify for its membership what the Ministry
will enforce, but no one in the GOI cleared
up doubts about the array of unknowns:
specifics of PCR testing protocols,
sampling, definition of what constitutes an
infraction, what words should appear on
labels and disclosure of the penalties the
GOI will apply for non-compliance with the
regulations. The picture that emerged is that
the GOI is not yeat ready for implement and
enforce the T&L regulations, and that it is
still waiting for the Commission to come
forward with more guidance.

4. Assalzoo raised a question about
genetically modified microorganisms used for
fermentation, an ingredient in some feeds.
This was another unanswered question among
many. Assalzoo has cautioned its members that
using "non-GM" or "GM-free" labels is
probably indefensible, if and when labeling
enforcement comes. Assalzoo has also
cautioned its membership to not individually
answer to Greenpeace. The feed association
fears this or other NGOs will step in and
become the defacto enforcer of labeling,
since Greenpeace has already canvassed
Italian feed compounders many months in
advance of the legislation's implementation
date, asking when they will begin labeling,

and if they use biotech ingredients in their

5. It is also conceivable that Italy's
regional authorities will become the
enforcers of the EU's T&L. The Italian
regional authorities have the Local Health

Administration (ASL) labs that coordinate
under the National Ministry of Health. The
ASL already carries out testing of products
entering ports. The regional environmental
agencies (ARPA) may also be given a role in
checking products for correct labeling. The
upshot of not having central government
control over labeling is that the Ministry of
Agriculture's Repressione Frodi (Fraud
unit)and the regions' ASL units will have the
freedom to decide in each region how to carry
out testing, but no one appears to be
directing them yet or coordinating actions
among agents.

6. The impact on the market of T&L is
unknown. The ability of the feed compounder
to reformulate or substitute non-biotech
soybeans or other proteins is limited. Others
have indicated a readiness to avoid biotech
labeling by avoiding biotech-produced
ingredients. According to the Italian oil
processors and food industry association, soy
oil from soybeans crushed in Italy will be
sold elsewhere, perhaps to Africa, but in any
case avoided as an ingredient for foods
processed in Italy. Reformulation in
processed foods is likely.

7. Comment. Absent guidance on T&L either
from the Commission or from the GOI, Italy
faces a vacuum in which the regional
governments or NGOs are likely to fill in the
gap. This would be a recipe for inconsistent
and nontransparent implementation of the T&L
regulation in Italy. Sembler

2004ROME01158 - Classification: UNCLASSIFIED

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