June 24, 2013
Ambassador Michael Froman – United States Trade Representative, Washington, DC
Commissioner Karel De Gucht – European Union Trade Commissioner, Belgium, Brussels
Dear Ambassador Froman and Commissioner De Gucht,
We write to you as representatives of family farm, consumers, faith, public health, development and environment organizations from the European Union and United States. Our organizations promote fair and sustainable food and farm systems in our communities and nations, and share common goals that in many cases cross borders and societies. We embrace multilateralism that is grounded in principles of sustainability, equity and democracy. We demand that you reject calls for the Trans-Atlantic Trade and Investment Partnership (TTIP) to undermine the use of the precautionary principle in setting food safety and public health standards, to give investors power over nations, and to be negotiated almost entirely in secret.
Contrary to the assertions made in a May 20 letter from major U.S. agribusiness and commodity groups, the precautionary principle, which is enshrined in EU legislation and the Lisbon Treaty, encourages rigorous scientific debate along with public input, when setting policy regarding the safety of new and emerging agricultural technologies and food additives. It prioritizes public wellbeing over corporate profits to ensure that products are safe before they enter our food systems and environments.
Those of us in the European Union reject any weakening of the use of the precautionary principle, while those of us in the United States demand that our negotiators not make any proposals that would preclude its use in the future and would remember that the U.S. is already party to treaties that invoke the Precautionary Principle and has incorporated versions of it into U.S. environmental and occupational safety laws.
We have only to look at recent news for evidence of the need for caution:
- The US Food and Drug Administration appears poised to approve the production and sale of genetically modified salmon in the U.S., despite nearly two million public comments to the contrary and the stated refusal of many retailers to sell it in stores. There are serious concerns about the potential environmental impacts if the altered fish should escape into the wild, and as yet unknown public health impacts. Acceptance of US food safety standards as “equivalent” to EU standards under the TTIP would effectively cut off public debate on this contentious new product, as well as other new GMO foods, and compel its sale in Europe as well.
- Ractopamine, a failed asthma drug now used as an additive to increase lean meat production in pork and beef, is associated with hundreds of thousands of cases of animal illness and death. Its use is banned in 160 countries, including the European Union, in large part because of the lack of independent scientific studies assessing its safety for human health. Despite ample reason for caution, the U.S. continues to push EU and other nations to eliminate import bans on meat produced with this questionable additive.
- The EU, for its part, is seeking to overturn the U.S. ban on beef imports from the EU. The United States prohibits the use or import of feed ingredients that include ruminant materials that are known to transmit Bovine Spongiform Encephalopathy, commonly known as mad cow disease. EU policies governing the use of ruminant materials in feed are insufficiently stringent and inconsistently applied to prevent BSE contamination, but the EU is already considering relaxing those standards, which would certainly increase the risk of BSE contamination and transmission.
- The EU may use the negotiations to erode certain important and more stringent U.S. meat safety requirements. The U.S. Department of Agriculture’s standards for pathogen levels in meat and poultry products include zero tolerance standards for Listeria monocytogenes in ready-to-eat products and E. coli 0157:H7 in beef products, while the EU standards do not establish a zero tolerance level for these pathogens. Other U.S. trading partners such as Canada, who have relied on the EU standard, have already challenged this zero tolerance standard.
There is a growing body of evidence of the harm caused by these and similar food technologies to public health and the environment, as well as their pernicious contributions to corporate concentration in agriculture and the consequent weakening of rural farm economies. Local communities throughout the EU and US are rebuilding food and agriculture systems along different lines to produce healthier outcomes for consumers, farmers and our environments. Their right to do so must not be diluted by the TTIP or any other pact.
We also object to the inclusion of investment provisions in the TTIP that would empower investors to sue sovereign nations over rules or conditions that may reduce their expected profits. We have observed the results of these investor-state disputes resulting from other agreements, many of which are direct challenges to state and national laws designed to protect the environment or public health. We challenge anyone to demonstrate why the inadequacies of our respective legal systems justify such an undemocratic and intrusive provision in this pact.
Finally, we are alarmed that the TTIP negotiating mandates do not require the publication of draft negotiating texts and fail to guarantee an informed public debate on the nature of the commitments under the agreement. Many of our organizations have submitted comments on the TTIP or participated in meetings with trade officials charged with starting the negotiations. We fear we will be forced, however, to rely on leaked bits of text to assess the degree to which our proposals are being addressed, which is a far cry from the standards of democracy and transparency that we expect from public policy. All proposals, negotiating texts and supporting documents should be published throughout the TTIP negotiations in as close to real-time as possible.
We are conscious that the concerns raised here are not only an issue for our communities or nations as the rules set in the TTIP could eventually extend to other bilateral and multilateral trade agreements. We will oppose any trade agreement that undermines that process of rebuilding local food systems, whether in our communities or abroad.
Agriculture and Rural Convention, ARC 2020 (EU), Arbeitsgemeinschaft bäuerliche Landwirtschaft (AbL) (Germany), Center for Food Safety (US), Center for International Policy Americas Program (US), Citizens Trade Campaign (US), Confédération Paysanne (France), Corporate Europe Observatory (Belgium), E3D- Ecologie Développement, Durable Démocratie (France),nFair World Project (US), Fondation Nicolas Hulot (France), Food & Water Watch (US), Food & Water Europe, Forum Umwelt & Entwicklung (Germany), Friends of the Earth Europe, Friends of the Earth France, Friends of the Earth US, GardenAfrica (UK), Générations Futures (France), Groupe PAC 2013 (France), Heinrich Boell Stiftung North America, Institute for Agriculture and Trade Policy (US), International Federation of Organic Agriculture Movements (Global), Ligue pour la protection des oiseaux (France), Local to Global Advocates for Justice (US), Maryknoll Office for Global Concerns (US), Mouvement Rural de Jeunesse Chrétienne (France), Organic Consumers Association (US), PowerShift (Germany), Save Our Seeds (EU), Send a Cow (UK), Soil Association (UK), Solidarité (France), United Church of Christ Justice and Witness Ministries (US), World Family UK.
cc: Mr. L. Daniel Mullaney, Assistant US Trade Representative for Europe and the Middle East, Mr. Ignacio Garcia Bercero, Director, Neighboring Countries, U.S. and Canada, EC Directorate on Trade