Well, whats the timeline that prop calls for?
Most laws have a sunset period and such, that allow producers time to use existing stock and transition.
Changing the label requires no more than 10 minutes in photoshop by an intern, so the cost of that is effectively zero.
If the time is sufficient, then there should be zero additional cost of existing label stock can be used. Just print the new stock with the label.
And the out-of-state thing isnt an issue at all. You dont have to remove the label any more than you have to remove "CA CRV"
Speaking of, every time a state joins or changes their recycling redemption system...a label change! Oh no, you have to add "HI" to your list of states next to the 5 cents sign! .....it's never been an issue.
Same exact thing here.
37 doesn't define some of that outright, hence some of the manufacturing side worry regarding how to label if it passes. I'm still not advocating voting for or against it, that's a personal decision and best left for CaliGAF'ers to make, but the impacts to costs have some merit.
Most marketers would disagree about the "intern and photoshop" bit, really you can't just toss a badge or declaration on the box wherever it fits, there has to be some thought around placement and size and how you communicate to the consumer. So something like Hot Sauce bottles, for example, have very little real estate on the label because they're small- since there's no clear direction on the label requirements yet it's all a question as to how and where companies will have to place the GMO declaration. Box of Cheerios? No problem, it's huge, figure it out. Single serving of peanuts? Not so much.
Depending on the scale of your operation, the costs to update packaging can be quite substantial. You
have to pay printers for setup and new print runs, for a product that sells in the millions it's multiple thousands of dollars per change, that's just how it is. And millions in sales doesn't mean it's always selling at a fantastic margin...
Regardless of how much companies decide to put into the design, the multi state problem is more complicated: anything labeled with the word "natural" "nature" or "words of similar importance" would not be able to put that word
anywhere on the label in Cali. Nature Valley Granola bars- because they have nature in their name- need a new, separate label for California ONLY. I doubt they'd sign up to rebrand across the whole world. That's a massive change, and it wouldn't come cheap for anyone who's in that situation. Every product with "Nature" anywhere on the pack would have to remove it completely based on 37, unless they could make the timeframe to get certified.
And here's the last piece on potential costs, I swear. If a company decided to comply to keep their label clear, they need to certify that there's no commingling of any GM ingredients
anywhere in the supply chain- meaning from farm to fork. If there's a single place where a GMO seed could have been accidentally dropped in with non-GMO seeds, (at the farm, the growers co-op, on a truck, in a silo, a farmer's market, milling, manufacturer, anywhere) then the GMO label has to be applied to the packaging. So to truly have a clean label, companies would have to maintain a separate supply chain for ingredients and manufacturing.
All this has to be certified by a 3rd party in order to validate compliance, which is why it's not more common today (USDA organic automatically qualifies, but that's the only fedral certification, the rest are private companies). The deadline for putting 3rd parties in place is July 2014, and there's going to be an epic backlog of requests as companies all race to sign up for 3rd party audits and approvals. Limited supply of 3rd parties + higher demand = cost go up. And really, if you're not already in the queue with some certifying body by Jan 1 2013, you're gonna be working to proactively label for declaring GMOs. Harsh reality is unless you already have a plan and contacts in place, you're at the mercy of the free market for finding a solution.
I am not asking GAF to vote against 37. I am not asking GAF to vote for 37. Only here to explain cost concerns. Personally, I can't wait to see this at a Federal level and make everyone comply on a level playing field- like USDA organic, which is not only a well defined and maintained program, but also plays well with other certifying bodies like the CCO in Canada.
