Food Related Regulation in Africa Compared to EU and US

The debate about food safety policies is one that is unlikely to end any time soon. While the obvious objective of setting food standards is for consumer protection, it is interesting that the world cannot agree on common regulations in this regard. One would expect safe and unsafe food products to hold up to such claims without any cause for doubt. But interestingly, every country seems to have a different approach on these matters. Let us take a look at some of the food related regulations governing the African market as compared to those in the US and EU markets.

Food Safety Policy

Food safety policy refers to the structures put in place to ensure that food is handled, prepared and stored in a way that minimizes contamination risks. It is a pertinent global issue as foodborne illnesses account for a high number of casualties. Food hygiene regulations aim to prevent food poisoning cases. They involve equipment and surface sanitizing, high personal hygiene levels, effective pest control and proper storage and heating. While there are general guidelines applied across the global divide, some aspects set apart regional regulations in different locations.

African Food Safety

Most African countries rely on subsistence farming. They also feature widespread food vending in the urban spaces. But being a continent of contrasts, it also has some first-world farms and developed food processing provisions. South Africa is prominent on the list as one of the most developed countries on the continent. Its food production and retail system is above among others. The same applies to its food-related regulations and standards.

But because most African countries are embracing international trade, they are in the recent past paying a lot more attention to food safety than before. There have been plans to create a common guideline framework for the countries. Many of the existing regulations have no scientific basis making it easy for lower quality goods to find their way into the market.

The African Union (AU) has formulated a promising project in this regard. It is bringing together willing participants from the different regions to work together toward a common food standards framework. This has encouraged meaningful participation and also helped inspire confidence from other countries. The project is still in the early stages, focusing on minimizing public health risks and getting consumers to trust the local food system.

Food safety related problems still account for almost 2,000 fatalities on the continent daily. Contamination, diarrhea and foodborne illness outbreaks are still very high. Dangerous food additives still make their way into soft drinks and snacks without any warnings on the food labels. However, with governments giving higher priority to these issues and literacy levels increasing, the continent’s food safety standards are on the correct trajectory.

US Food Safety vs. Europe

A look at European vs. American food standards tells a different story. While the outlook might not necessarily be the same, both regions have stringent protective standards. European food standards require food business entities to offer safe food to consumers, offer traceability provisions and to import or export only those foods that comply. Unsafe foods should be immediately withdrawn or recalled. The National Food Crime Unit (NFCU) sees to it that consumers can easily report any malpractice.

Some European nations have however voiced complaints about dual quality foods in the different regions. Certain prepackaged food products look the same on the outside but have marked ingredient differences. While some food manufacturers claim that these products are customized for different markets, consumers consider it discriminatory. The EU’s greatest challenge is to harmonize European food standards across the entire region.

The US food standards are not as strict as the EU’s. Certain food additives are banned in the EU because of their effect on consumers are accepted in the US. Moreover, there are pesticides and herbicides that are not allowed in Europe but are vastly used in the US. What marks the difference between these two markets is the EU’s precautionary principle.

This principle requires that in the absence of scientific clarity, substances that pose any risk level are better off prohibited. On the other hand, the US requires demonstrable proof of risk before any product is prohibited from the market. This implies that food quality in Europe vs. America is not necessarily different. But the authorities’ approach is what sets the two markets apart. While consumer demands and regulations in other countries are the major driving forces in the US market, the EU’s authorities are more involved in the assessment and regulation processes in their region.

Food Labels

Food labels do not only serve a promotional role. They carry out the important function of telling consumers what they are ingesting. They contain nutritional information, alert us to the presence of allergens and also help us calculate our intake of individual dietary requirements. But a closer look at the European food labels vs. American reveals a lot more.

African Food Labels

There is no common authority on African food labels and the requirements differ from country to country. South Africa offers a suitable example in this regard with a few basic traits that characterize most food labels:

  • Company name
  • Net weight
  • Year of manufacture
  • Expiry or best-by date
  • Hazards warnings

US Food Labels

The Food and Drug Administration (FDA) is in charge of labeling. They offer concise rules on mandatory inclusions on food labels. They also have a comprehensive list of stipulations, exceptions and specific nuances. At the moment, the FDA requires the following details to feature all labels for US food products:

  • Ingredients listed from the most concentrated to the least
  • Names for all present products
  • The amount of each product present
  • The presence of specified allergens – these include milk, peanut or tree nuts, soybeans, eggs, wheat, and fish.

All food product packages in the US should also have a nutrition information label. This one includes calorie count, serving size, the cholesterol, protein, fat, sodium, carbohydrate, mineral and vitamin levels. The latest revisions to these requirements are aimed at addressing lifestyle habits. For instance, calorie count should be made prominent and they should make a separate mention if added sugar. They were also required to bring up-to-date their portion sizes so as to reflect current eating habits.

These changes have been implemented in order to provide an indirect solution for lifestyle health risks. When consumers have easy access to accurate information on what they eat, they are better placed to avoid such risks.

But according to some sources, these changes are not comprehensive. Some values are still listed in terms of quantity instead of daily recommended value. Consumers have a hard time relating to gram values. They still do not know how to translate such figures to determine daily consumption.

The EU Food Labels

The European market has for a long time been fragmented in the matter of food labels. But in the recent parts, efforts have been made to create a comprehensive structure guiding the different nations. In comparison to the US regulations, these ones offer higher flexibility.

The EU system uses grams to define caloric information. This is quite different from the US system that breaks down this information into servings. It however allows manufacturers to provide this information voluntarily. Some take advantage of this opportunity to connect with health conscious consumers who appreciate these details.

The European food labeling dictates are a lot more inclusive than their US counterparts. For instance, in the case of vegetable oils the European system requires manufacturers to specify the source. They allergen listing requirement in the EU is also more inclusive than that of the US. The US system only requires this listing for prepackaged foods but in the EU it covers all food items. Moreover, the European legislations go beyond product labeling to include advertising but the US requirements are more lenient.

However, in the matter of E numbers, the US system proves to show more attention to detail. EU numbers refer to numbers assigned to common food additives. In the US, food additives must be identified by their names. But in Europe these numbers suffice.

GMO Regulations

Genetically Modified Organisms (GMOs) refer to organisms whose genetic makeup is altered using a method that does not occur naturally. These alterations aim to develop specific traits in plants and animals like disease-resistance, increased productivity and better nutrition.

GMO Regulation in Africa

On the African continent, only Algeria, Rwanda and Madagascar have bans in place for GM crops. Considering the common food production constraints experienced on the continent, GM technology offers a welcome reprieve. It has boosted agricultural output and subsequently, food security in many sub-Saharan countries.  Research has shown positive economic results as well from these crops. There are initiatives aimed at relaxing policies in the sector to reduce product prices. They also aim at educating the general populace to reduce the general skeptic view of such products.

The public has not been as enthusiastic with environmental and agricultural bodies warning of adverse health effects. But regulations in most countries are gradually becoming more flexible particularly in the face of drought and famine.

GMO Regulation in the US

In the United States, GMOs are regulated under different authorities depending on the type involved. Food-related GMOs also fall under the FDAs charge. They focus their approach product nature and not the production process. Considering how much of an impact they make on the US economy, the regulations seem quite flexible. The FDA in effect considers a majority of GMO food products equivalent to their non-GMO counterparts. Such products do not therefore require any pre-market production approvals.

However, in cases where a transgene introduced into an existing product results in a significant structure alteration that might pose a risk to human health, the FDA is more stringent. The body introduced a voluntary consultative arm to allow developers the opportunity for product review at the pre-market stage. Such assessment focuses on checking for toxicity and allergenicity in genetically modified plants.

GMO Regulation in Europe

The EU has more stringent requirements in place for GMOs. In fact, GMO regulation in Europe is enforced using one of the most extensive evaluation procedures globally. This system is applied on individual assessments conducted. A successful evaluation gives applicants 10-year tenure before having to repeat the process.

GMO products in the EU market are carefully labeled to create consumer awareness and allow for traceability. The different EU members have the freedom to govern GMO cultivation in their relative regions.

Comparative Analysis of GMOs in Europe vs. US

It is clear that the US is a lot more lenient with regards to its GMO regulations. The EU operates on a pre-authorized plants list to determine what can or cannot be produced using the process. This aspect of development is therefore greatly limited with authorities citing animal and human health protection. Opinion on the US approach is mixed with consumers wondering whether the voluntary evaluation system is really viable. The EU populace seems to appreciate the protective measures afforded by the strict regulations. The greatest majority of countries that ban GMOs are actually found under the European Union. But studies have also been carried out in the region to show the viability of GMO foods on economic performance.

 Understanding the Different Food Market Regulations with WaystoCap

It is evident that even within the African continent food related regulations are far from uniform. While certain products are considered risky in one market, they are a staple in another. The same applies to the US and EU markets where different rules apply for distinct food products. This means that in order to succeed in international trade, you would need to have these regulations on your fingertips. This will help you avoid losses that would result from consignment rejection due to quality issues. It is true that having all that information is no easy feat. That is where Waystocap comes in handy.

Waystocap has a team of dedicated professionals working to ensure your import export business stays on track. We offer updated information on the regulations governing different markets on the African continent. We help you to successfully carry out trade with these countries without any fear of failure at customs quality control.

We go beyond this to provide you with a safe trading platform that unites entrepreneurs on a global scale. You can be sure to find viable partners to work with on out platform as well as other useful provisions to help you succeed. We will alert you on important trade fairs and exhibitions that could help you network and promote your brand with greater ease. Sign up with us today to enjoy these and many other benefits.

Sources :

https://www.theguardian.com/lifeandstyle/2015/sep/08/food-labeling-us-fda-eu-health-food-safety

https://gmo.geneticliteracyproject.org/FAQ/where-are-gmos-grown-and-banned/

https://www.loc.gov/law/help/restrictions-on-gmos/eu.php

https://www.loc.gov/law/help/restrictions-on-gmos/usa.php

http://www.ifpri.org/publication/genetically-modified-crops-africa

http://www.ifpri.org/publication/genetically-modified-crops-africa

http://www.foodqualityandsafety.com/article/out-of-africa/?singlepage=1

https://www.politico.eu/article/a-snack-by-any-other-name-varying-food-standards-irk-new-eu-countries/