Items	EUCCK’s Proposal	Comment
Standard of Ethyl Carbamate (EC) generated in red wine	There are currently no agreed international stands for EC in wine. The regulation shall take into account the fact that EC levels can increase naturally when product is subjected to increase temperatures. EUCCK views the establishment of new standard as unnecessary regulation.	Upon the examination of the amount of naturally occurred ethyl carbamate due to an increase in temperatures during distribution, the increased levels are assessed as not significant. Canada and other advanced countries already have mandatory or recommended tolerances for ethyl carbamate. It is deemed necessary to continue monitoring ethyl carbamate for the purpose of protection of public health, as the substance is classified by the International Agency for Research on Cancer (IARC) as a Group 2B, possibly carcinogenic to humans, and thus there is a need for control ethyl carbamate.
Labeling requirement	Korea should repeal the labeling requirements which exceed those prescribed by the CODEX labeling standard. Korea should develop a greater degree of co-ordination among the various government agencies regulating labeling measures for alcoholic products. In addition, the labeling requirement for separate channels should be reviewed, but priority should be given the removal of the ‘for discount store only’ label for all the imported liquor products, since it has already been withdrawn for Wine, Vodka and Chungju (refined rice wine).	Since most imported OEM products are labeled in Korean, which makes such products possibly mistaken as locally manufactured products, and since Korean OEM products also do not bear OEM labels, consumers cannot distinguish OEM products. Therefore the labeling requirement for distinction of OEM is considered necessary in view of provision of accurate information to consumers. 1399 indication on food containers, packages enables consumers to promptly report food adulteration or contamination, and businesses to supply safe products.
Regulation on OEM imported food including liquor	Ministry of Health’s shall not impose sanitation inspection obligation etc. on OEM foods importers. It should respect the sanitation/quality ensuring procedures of the exporting countries. Customs Service shall not treat OEM imported foods differently from non-OEM imported foods and domestic OEM foods (discriminatory). Or at least products of which the consumers are not likely to be confused about country of origin (for example, Scotch whisky, Cognac, Champagne etc.) should be exempted from the new labeling requirement.	Sanitary inspection is conducted at least once a year on local manufacturers for the purpose of safe food supply. In case of non-compliance with Korean requirements, the KFDA takes administrative actions including business suspension. As all imported OEM foods are manufactured to be supplied to Korean consumers, the KFDA believes all OEM products, imported and locally produced ones alike, should be subject to the same level of control. The practical application will be determined after considering methods to minimize burdens on manufacturers of the importing country. Implication of the country of origin of imported goods comply with the GATT agreement and recommendation and the provisions of the Foreign Trade Act of Korea for establishment of fair trade order and consumer protection, and the Korea Customs Service is enforcing the relevant regulations. The regulations on the country of origin marking of OEM imported food have been newly made or revised, without infringing the existing principles, to make it easy for consumers to identify their country of origin, so as to satisfy people's right to know and strengthen importers' responsibility on their goods. It is impossible to exclude OEM imported liquor from application of the regulations as its country of origin, which can differ depending on the country where blending is carried out, can be as confusing as that of other OEM imported food.
Obligation to report to KFDA the consumer complaints of foreign matters in the food product	Ministry of Health/KFDA shall treat liquor importers equally with liquor producers and exempt liquor importers from the reporting obligation as well as from the business registration obligation.	The reporting requirement is to enable prompt actions in response to foreign matters in food products in an effort to provide safe foods to consumers. All products circulated in the domestic market under the control of the KFDA are subject to this obligation.