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AFFI objects to Canadian proposal that restricts exports.

While commending Agriculture Canada for efforts to open borders through free and fair trade, the American Frozen Food Institute (AFFI) objected to provisions in an Agriculture Canada proposal that attempts to resolve conflicts with the General Agreement on Tariffs and Trade (GATT) and the U.S. - Canada Free Trade Agreement.

According to AFFI, the proposal satisfactorily addresses many concerns raised in the U.S. frozen food industry about trade activity. However, as AFFI pointed out in comments to Agriculture Canada, portions of this proposal would continue to restrict AFFl's members' ability to export frozen food products to Canada.

Specifically, AFFI objected to the product weight and volume packaging requirements in the proposal. Agriculture Canada's requirement that a container must provide a volume of product that is a whole number multiple of 500 grams and 500 ml is not a function of the marketplace, and is inconsistent with customary package sizes currently in use, said AFFI President Steven C. Anderson in the comments.

"AFFI members believe that package weight and volume should be a function of market forces rather than restrictive regulatory requirements," he said.

"This regulation will place unnecessary costs on both U.S. and Canadian frozen food producers, as processors are forced to undertake an otherwise unnecessary plant retooling process," Anderson continued. "The ability of the foodservice industry to order product based on actual usage will be limited as well."

If a standard packaging size is adopted, AFFI strongly urges that the current de facto standard at the foodservice level become the allowable standard size for frozen food products.

Anderson also suggested that the regulations be implemented in a way that allows U.S. exporters to obtain market access immediately after the final rule is published.

The proposed requirement that the government inspection service in the country of origin certify compliance with the regulations and inspection programs is also of concern to AFFI.

"All food processing facilities in the U.S. are subject to regulations and inspection requirements by the Food and Drug Administration and the U.S. Department of Agriculture, as well as the Occupational Safety and Health Administration and the Environmental Protection Agency. Food processors in this country also must comply with Good Manufacturing Practices in the manufacturing, packaging and holding of human food," Anderson said in the comments.

"AFFI believes that the existing U.S. regulatory schemes should be recognized by Agriculture Canada as equivalent for these regulations," he said.

Lastly, Anderson stated that the pre-approval process for labels imposed on U.S. exporters must be equal to the process imposed on domestic industry. He further requested that the language in that section of the proposal be changed to require the director to provide the importer with written information that labels are acceptable, or unacceptable, within 30 days.

"An unspecified, and perhaps prolonged, confirmation time-frame would be construed as unduly restrictive because it would result in the inability of U.S. frozen food processors to meet customer-specified deadlines," Anderson concluded.

AFFI is the national trade association that has represented the interests of the frozen food industry for over 50 years. Its 550 corporate members account for approximately 90 percent of the total U.S. production of frozen food.
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Title Annotation:American Frozen Food Institute
Publication:Frozen Food Digest
Date:Apr 1, 1993
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