Origin labelling should remain voluntary for agricultural bulk commodities
A mandatory rule to indicate the place-of-provenance or Country-Of-Origin Labelling (COOL) of their bulk agricultural raw material(s) would severely affect current production practices for most flour millers, who are essentially small and medium-sized companies. Moreover, indicating the origin of the wheat could be misleading although true, by suggesting that the flour or the flour-based products possess "qualities" or special characteristics when all similar products possess such "qualities" or characteristics.
Regulation (EU) 1169/2011 currently addresses the interests of European consumers in the labelling of flour in two ways. First, no indication of origin may be provided which may mislead consumers as to the true provenance of the product. Second, the flour miller may choose to voluntarily indicate the origin of wheat on the package in order to draw consumer’s attention to the "qualities" of their products (recital 30).
In practice, blending & quality vs. origin
Wheat is blended, processed and sold on the basis of its inherent characteristics, not on the basis of origin. Blending is essential to the flour milling process: the miller buys, stores, blends and mills different types of traced wheat of different qualities. The miller stores wheat by quality and not by origin.
Millers may also blend different flours in order to produce the product demanded by their customers. By blending together the many different flour streams produced by the mill, a miller can create further variations in features such as flour colour.
Meeting new origin labelling requirements (including mandatory origin labelling) would require the need for additional silo capacity to cater for each origin, in addition to those existing for the various qualities.
Milling is a continuous process
Milling is a continuous process and flour mills are operating 24 hours a day. The flour millers must secure wheat supply in the required quality and quantity, as the process cannot be interrupted. This takes away the flexibility to deviate the sourcing of wheat, as this would notably imply the stopping and restarting of production to accommodate the changes of origin(s) on the labels.
Adapting the production process for the millersIntroducing mandatory origin labelling would bring substantial changes in the production process and therefore bring new costs due to in particular:
- The need for additional silo capacity to cater for the storage of each grain origin (in addition to those already existing for qualities)
- The need for additional silo capacity to cater for each flour type, if millers need to also store flour per origin of the grain in addition to the storage of flour per quality
- The change of packaging materials with each origin change and, as a result, additional administrative costs
For flour & flour-based products: does that make sense to assess their quality?
The miller buys, blends and mills different types of traced wheat from different quality (mainly from intra- but also from extra-EU origins) to produce a mix capable of yielding the required specific functional property and quality of flour. Protein level, gluten content (elasticity) or alpha-amylase activity (…) in the grain will vary from one cereal harvest to another and lastly condition bread quality, whatever the origin of the grain is. Some regions may provide the millers with specific wheat qualities but not for all harvests.
In the end, indicating the origin of the wheat could be misleading although true, by suggesting that the flour or the flour-based products possess "qualities" or special characteristics when all similar products possess such "qualities" or characteristics.
European consumers first rank price over origin
When shopping for food, European consumers first consider taste and price as very important factors and origin only comes in the fifth place, according to the "BEUC consumer survey on origin labelling on food" issued in January 2013.
For the European consumer, COOL is less important for staple foods like flour
When asked how important they think it is that the country of origin is labelled on specific foodstuffs in the same survey, European consumers rank staple foods (e.g. flour, sugar, salt) as the less important products.