US embassy cable - 04ROME1158

UNCLAS  ROME 001158 
 
SIPDIS 
 
 
BRUSSELS PASS USEU FOR AG MIN-COUNSELOR 
STATE PASS USDA/FAS FOR BSIMMOS, EJONES 
FAS/FAA FOR SBLEGGI 
USDA FOR EUR/AGS, S/CT,EB/TPP/ABT,OES, E:PCHASE 
STATE PASS TO USTR 
EU POSTS PASS TO AGRICULTURE 
 
E.O. 12958:  N/A 
TAGS: EAGR, ETRD, TBIO, ECON, GM 
SUBJECT:  NO IMPLEMENTATION PLANS FOR 
TRACEABILITY AND LABELING IN ITALY 
 
 
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 
products. 
 
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 
 
 
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 2004ROME01158 - Classification: UNCLASSIFIED