Further Supplementary Memorandum by United
Biscuits (UK) Limited
United Biscuits (UB) has already provided significant
input to the Committee.
In July 1998, the company presented a written
submission detailing its views relating to the important issue
of genetic modification (GM) in agriculture.
Subsequently, on October 14, 1998, at the request
of the Committee, the company attended a meeting of the Committee
to answer a series of questions put by Members.
During that presentation, Lord Jopling was particularly
interested in the consultation undertaken with food manufacturers
by bio-sciences companies prior to the introduction of advances
such as the genetic modification of crops.
UB indicated its support of bio-sciences companies
in the development of this technology, however, it did object
strongly when advances were imposed without due consultation and
the opportunity for a reasonable period of scientific review.
UB pointed out that it felt its views had been
"trampled upon" by the fact that its opinions had not
been sought in advance of introduction of co-mingled GM crop to
the UK and Continental Europe. This phrase was not meant to convey
an accusation of systematic cavalier treatment by bio-sciences
companies, so much as a cry of frustration over the way in which
these particular GM crops were introduced.
Lord Jopling asked that UB consider providing
additional details in respect of the lack of consultation and
this supplementary submission is UB's considered response to that
As was pointed out in our October 14 presentation,
consumer anxiety arises when food manufacturers have insufficient
time to consider new developments and to plan their introduction.
This is always true, but it is especially important
when there are aspects of advances which are potentially controversial
or which, through lack of information, can tend to cause anxiety
among our customers and consumers.
Moreover, as was indicated by us, the "forge-ahead-at-all-costs"
approach invariably results in increased costs for manufacturers.
This has certainly proven to be the case for
United Biscuits as the company has:
despatched buyers to many parts of
the world to source traditional/traceable crops;
paid a premium for traceable/traditional
met the costs of extensive additional
testing of crops and final products;
incurred significant additional labelling
devoted much time of many senior
executives to the issue.
Additionally, this approach works against providing
consumers with choice if manufacturers through no fault of their
own, cannot meet customer expectation. Despite strenuous efforts
to source traceable traditional croponly to find that there
is trace presence of GM material, the dilemma is clearly whether
or not to label. If the approach is to label, this would result
in blanket labelling and offer consumers no choice.
Due consultation before the introduction
of these new crops would have resulted, UB believes, in less consumer
anxiety, less expense and consumer choice. The process of introduction
could, and should, have been handled more slowly so as to generate
greater confidence and more ready acceptance.
While this has been a frustrating and unsatisfactory
period UB believes that there can be a positive outcome if lessons
In future, United Biscuits would like to see:
A period of consultation with all
relevant partiesprior to commercialisation of GM in the
case of crops or marketing of the product.
An opportunity to review existing
science and to influence new research to underpin the introduction
of GM foods during the above consultation period.
Communication of consumer benefits
flowing from the new advance.
Traceability, if needed, is confirmed.
All regulatory issues in Europe,
including labelling, must be clear, before commercialisation of
Greater clarity of principle and
setting of threshold levels, where appropriate.
Scientifically accurate and up to
date information to be developed and a communication programme
informing consumers, opinion formers and the media to be undertaken
in advance of introduction of GM materials.
It is United Biscuits' view that if a more orderly
and patient approach were adopted, the likelihood of consumer
acceptance would be maximised and food manufacturers would not
be placed in the difficult position of having to go to considerable
expense and effort in order to supply their customers and consumers
in the way they wish.
UB supports the Government's announcement to
establish a new Ministerial Group which will oversee strict monitoring
of first commercial plantings of GM crops. Managed development
of GM crops prior to commercialisation, will we believe help allay
concerns and ensure that advances in the technology can continue,
but with adequate scientific assessment and evaluation.
United Biscuits welcomes the Committee's enquiry
into this important topic.
The company believes that, in the long term,
there are likely to be benefits to society as a whole and to individual
consumers, from the introduction of genetically modified foods.
However, because any changes in the supply chain,
or the introduction of bio-tech advances impact strongly on the
operations of food manufacturers, we believe their views are most
relevant and prior consultation must take place.
Companies like United Biscuits can do much to
ease the introduction of new advances in food by working with
the broader industry to devise and implement information programmes,
by monitoring consumer attitudes, by working with Governments
to effect workable regulations and, ultimately, to deliver a better
product to customers and consumers alike.
UB commends the Committee for its deliberations.
28 October 1998