The Tories’ election campaign embraced this with religious fervour. And it is fraught with politics. No surprise then that the new government was keen to take it away from non-ministerial FSA.
Food labelling legislation protects the consumer but the main enthusiasm for compulsory COOL comes from farmers hoping to sell more of their national products. It is important that the European Commission Food Information Regulation in which COOL will be enshrined is not detrimental to consumers’ interests, particularly by making food more expensive by reducing flexibility to source raw materials.
Consumers interested in provenance can already opt not to buy food of unknown origin. Those not interested may find food from undeclared sources cheaper. Research by the IGD think tank has found that the top driver for food purchase is price. COOL comes in ninth.
The original proposal called for declaration of places or countries of birth, rearing and slaughtering of animals.
Taking an extreme example: bacon could come from pigs born in one EU member state, reared in another, and slaughtered in yet another before being cured in the UK. COOL would have to mirror this if this overzealous stipulation is included in the final regulation.
It would be more sensible if the wording of the regulation referred to ‘place’ rather than country. Then labels could state ‘EU’ instead of itemising each country.
It would be easier for large firms to comply with mandatory COOL. So small and medium sized enterprises (SMEs) could be unfairly penalised.
When there is a shortage of UK product at the right price, suppliers will have to seek other sources or cease production, which could put an SME out of business. Also, the government’s desire for the strictest possible protection for UK farmers is at odds with its other manifesto pledge to reduce the red tape burden for business.
So, do we need mandatory COOL? Food Labelling Regulations 1996 already contain an offence for misleading the purchaser as to origin.
That ought to be sufficient and is easier to enforce. If it became an offence not to declare provenance, that would encourage fraudulent labelling. It would be harder for enforcement to obtain proof that the labelling was wrong than the fact of its absence.
Let us hope common sense will prevail over the politics.