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TRANSCRIPT
EU REQUIREMENTS FOR FOOD SAFETY
AND TRACEABILITY OF FISH AND
FISHERY PRODUCTS
International Seminar on Sustainable Seafood Value Chain: Traceability28–30 November 2018, Shanghai, China
Vincent André, AETS Thailand
Outline
Introduction
Requirements to access international markets
The EU agri-food trade
The EU obligations of food trade
Food traceability in the EU value chain
Traceability “From Farm to Fork”: Cornerstone of EU food safetypolicy
Traceability needed to combat IUU fishing
Requirements to access international markets
1. The EU Food Law and the Hygiene package (food
safety and labelling
2. The EU rules to combat illegal, unreported and
unregulated fishing (IUU)
3. United Sates of America
4. Japan
1. Codex Alimentarius
2. Office International des Epizooties (OIE)
3. FAO Eco-labelling and sustainable fisheries
4. FAO Technical Guidelines on Aquaculture Certification
5. RFMO catch/trade documentation schemes
1. ISO 22000 and ISO 12875:20112. GS1 Global Traceability
Standards3. TraceFish (EU)4. Trace Register5. CHINATRACE
6. Environmental standard for sustainable fishing (MSC)
7. National Marine Fisheries Service Dolphin Safe Certification (NMFS)
8. EU Fish Processors Association and EU Federation of National
Organisations of Importers and Exporters of Fish (AIPCE-CEP)
9. WWF SFI10. GLOBALG.A.P
11. Global Aquaculture Alliance (GAA)
12. Global Food Safety Initiative (GFSI)
13. British Retail Consortium (BRC)
14. International Featured Standard (IFS)
Regulatory requirements
Official channels- Competent Authority Business to Business communications
Importer Primary production
Processing/
PackingExporter
Non-Regulatory requirements
Requirements to access international markets
Exporters have to comply with the requirements such as:1. food safety;
2. product quality;3. social, environmental and business compliance.
The EU agri-food tradeWhat is the European Union?Unique economic and politicalpartnership between 28 democratic European countries.
The World's largest trader The EU is the world’s largest trader (16%) of manufactured goods and services.
Unlike the USA (-5%) and Japan (-3%), the EU share of World trade has been stable over the last 10 years.
The European Union is the world’s largest importer of agricultural and fisheryproducts: 114 Bn EUR in 2015 followed by the US, China and Japan.
The EU obligations of food tradeMultilateral system (WTO)o SPS and TBT agreementso International Standards Setting Bodies (ISSBs): Codex Alimentarius, OIE
(Animal Health), IPPC (Plant Protection)
The EU Food Safety framework Law: courtesy of Mr Patrick Deboyser, former Minister Counselor of DG SANTE, EC.
EU Legislations on food safetyo General Food Lawo EU food safety legislationso Official Control regulations
EU Legislations on IUURegulation to prevent, deter and eliminate IUU entered into force on 1 January 2010
Food Law requirements of traceabilityThe Codex Alimentarius Commission definesTraceability as “the ability to follow the movement of afood through specified stage(s) of production,processing and distribution”
ISO 8402:1994"Traceability is the ability to trace the history, applicationor location of an entity by means of recordedinformation."
Regulation (EC) No 178/2002Traceability is the ability to track any food, feed, food-producing animal or substance that will be used forconsumption through all stages of production,processing and distribution.
Food Law requirements of traceability
• facilitates withdrawal of faulty food/feed from the market
• provides consumers with targeted and accurate information onspecific products
• covers all food and feed, all food and feed business operators,without prejudice to existing legislation on specific sectors
• affects importers who are required to be able to identify from whomthe product was exported in the country of origin
• obliges businesses to be able to identify at least the immediatesupplier of the product in question and the immediate subsequentrecipient, with the exemption of retailers to final consumers - one stepback-one step forward (unless specific provisions for furthertraceability exist).
Traceability:
Food Law requirements of traceability
Primary responsibility for ensuring compliance with food law - and in particular the safety of the food –rests with the food (or feed) business operators. To complement and support this principle, the competent authoritiesof the Member States must assure adequate and effective controls.
When food or feed is unsafe, business operators are obliged:- to withdraw or recall it- to notify the competent national authorities so as to be able to monitor
whether the appropriate measures have been taken or require thatadditional measures be taken for reducing or eliminating a foodsafety risk.
Operators' responsibilities
(Directive 2001/95/EC)
Food Law requirements of traceability
(1) Food and feed business operators shall be able to identify any person fromwhom they have been supplied with a food, a feed, a food-producing animal,or any substance intended or expected to be incorporated into a food or a feed.To this end, such operators shall have in place systems which allow for thisinformation to be made available to the competent authorities on demand.
ONE STEP BACKWARD
(2) Food and feed business operators shall have in place systems andprocedures to identify the other businesses to which their products havebeen supplied.This information shall be made available to the competent authorities ondemand.
ONE STEP FORWARD
One step backward – One step forward
Food Law requirements of traceability
The EU traceability requirements only apply within the EU (no extra-territorialeffect):
They apply from the importer to the retailer (i.e. the importer must be able toidentify his supplier in a third country (one step back).
The exporter himself, in the non-EU country, is not bound by the traceabilityrequirements
However, he may have traceability obligations, either under specificrequirements (i.e. products of animal origin) or because of contractualarrangements.
Does this apply to exporters to the EU?
Operator
Supplier 6Supplier 5Supplier 4Supplier 3Supplier 2Supplier 1
Customer B Customer CCustomer A Customer E Customer FCustomer D
► There is no simple supply chain► Is a business operator obliged to match outputs and inputs?
IS INTERNAL TRACEABILITY REQUIRED? (2)Slide from Mr. P. Deboyser, DG SANTE - EU Commission
Food Law requirements of traceabilityIs internal traceability required?
Operator
Supplier 6Supplier 5Supplier 4Supplier 3Supplier 2Supplier 1
Customer B Customer CCustomer A Customer E Customer FCustomer D
IS INTERNAL TRACEABILITY REQUIRED? (3)Slide from Mr. P. Deboyser, DG SANTE - EU Commission
Food Law requirements of traceabilityIs internal traceability required?
Operator
Supplier 6Supplier 5Supplier 4Supplier 3Supplier 2Supplier 1
Customer B Customer CCustomer A Customer E Customer FCustomer D
IS INTERNAL TRACEABILITY REQUIRED? (4)Slide from Mr. P. Deboyser, DG SANTE - EU Commission
Food Law requirements of traceabilityIs internal traceability required?
Operator
Supplier 6Supplier 5Supplier 4Supplier 3Supplier 2Supplier 1
Customer B Customer CCustomer A Customer E Customer FCustomer D
► Is a business operator obliged to match inputs and outputs?
IS INTERNAL TRACEABILITY REQUIRED? (5)Slide from Mr. P. Deboyser, DG SANTE - EU Commission
Food Law requirements of traceabilityIs internal traceability required?
Operator
Supplier 6Supplier 5Supplier 4Supplier 3Supplier 2Supplier 1
Customer B Customer CCustomer A Customer E Customer FCustomer D
IS INTERNAL TRACEABILITY REQUIRED? (6)Slide from Mr. P. Deboyser, DG SANTE - EU Commission
Food Law requirements of traceabilityIs internal traceability required?
Operator
Supplier 6Supplier 5Supplier 4Supplier 3Supplier 2Supplier 1
Customer B Customer CCustomer A Customer E Customer FCustomer D
IS INTERNAL TRACEABILITY REQUIRED? (7)Slide from Mr. P. Deboyser, DG SANTE - EU Commission
Food Law requirements of traceabilityIs internal traceability required?
Food Law requirements of traceability
Food or feed which is placed on the market in the EU shall be adequatelylabelled or identified to facilitate its traceability, through relevant documentationor information in accordance with the relevant requirements or more specificprovisions.
There are specific requirements laid down in vertical legislations:• Pre-packaged food: batch number• In the case of animals: tag• Sector-specific legislation applies to certain categories of food products
(fruit and vegetables, beef, fish, honey, olive oil)• Genetically modified organisms (GMOs)• Products with special labelling schemes e.g. protected origin, halal
LABELLING / IDENTIFICATION
(Directive 89/396/EEC – Article 1(2))
Food Law requirements of traceabilityPre-packaged fruits and vegetables Live animal
Egg Beef meat
Food Law requirements of traceabilityFruits and vegetables
Producers must maintain registers indicating treatments (e.g. pesticides) applied and results of lab tests.
Common marketing standards lay down the specific indications whichproducts must bear, such as:
• name of the variety (if applicable) • category • country of origin • name and address of the packager or dispatcher
Food Law requirements of traceabilityFish and fishery products (when sold to the final consumer)
(Regulation No 104/2000/EC and No 2065/2001/EC)
Traceability to combat IUU fishingThe European Union rules
To close the loopholes that allow illegal operators to profit from their activities: Only marine fisheries products validated as legal by the relevant flag state orexporting state can be imported to or exported from the European Union. A European black list has been drawn up covering both IUU vessels and
states that turn a blind eye to illegal fishing activities. European Union operators who fish illegally anywhere in the world, under any
flag, face substantial penalties.
Traceability to combat IUU fishingEU Legislation
o Regulation (EC) No 1005/2008 establishing a Community system to prevent,deter and eliminate Illegal, Unreported and Unregulated fishing Is the legal base to identify IUU fishing, applied to all fishing vessels Seeks to ensure full traceability of all marine fishery products traded with
the EU Excludes freshwater fishery products, aquaculture products, ornamental fish
Chapter III, Catch Certification Scheme forimportation and exportation of fishery productsArticle 12: Catch Certificate
o Regulation (EC) No 1010/2009 is the implementing regulation, establishing theCatch Certificate
Traceability to combat IUU fishingEU Legislation (2)
o Regulation (EC) 1224/2009 established a Community control system forensuring compliance with the rules of the common fisheries policy: The whole chain of production and marketing should be covered by a control
regime
The control regime should include a coherent traceability systemcomplementing the provisions of Regulation (EC) 178/2002
It should also protect the interests of consumers by providing the informationconcerning the marine products
Traceability to combat IUU fishingEU Legislation (2)
o Regulation (EC) 1224/2009
Fisheries and aquaculture products placed on the market or likely to beplaced on the market in the Community shall be adequately labelled toensure the traceability of each lot.
Lots of fisheries and aquaculture products may be merged or split after firstsale only if it is possible to trace them back to catching or harvesting stage.
Member States shall ensure that operators have in place systems andprocedures to identify any operator from whom they have been supplied withlots of fisheries and aquaculture products and to whom these products havebeen supplied. This information shall be made available to the competentauthorities on demand.
Traceability to combat IUU fishing
The minimum labelling and information requirements for all lots of fisheries andaquaculture products shall include:
(a) the identification number of each lot;
(b) the external identification number and name of the fishing vessel or the name of the aquaculture production unit;
(c) the FAO alpha-3 code of each species;
(d) the date of catches or the date of production;
(e) the quantities of each species in kilograms expressed in net weight or, where appropriate, the number of individuals;
(f) the name and address of the suppliers;
(g) the information to consumers provided for in Article 35 of Regulation (EU) No 1379/2013 of the European Parliament and of the Council
Traceability to combat IUU fishingEU Legislation (3)
o Regulation (EU) No 1379/2013 on the common organization of the markets infishery and aquaculture products Regulates the labelling indications for all fishery and aquaculture products
marketed within the EU, irrespective of the marketed method, offered to thefinal consumer or to a mass caterer
Makes reference to the Food Information to Consumer (FIC) Regulation(EU) 1169/2011:Mandatory information:1. Commercial designation and scientific names2. Production method3. Catch area / country and body of water / countryOf production4. Fishing gear5. Defrosted6. ‘Best before’ date / ‘Use by’ date7. Allergens
Voluntary information
Traceability to combat IUU fishing
SummaryEU Regulation on food Safety EU regulation on IUU
Principle Safety of European consumers Sustainable fisheries
Scope European member states and European operators
European member states and non-EU countries trading with the EU
Objective To provide basis for the assuranceof a high level of protection ofhuman health and consumers inrelation to food.
To ensure compliance with the rules of the common fisheries policyTo prevent, deter and eliminate IUU fishing.
Unique identification
All food products, includingfishery products, have to beidentified by lot. The establishment authorized to supply the EU market must be licensed.
All the fishing vessels must belicensed and the fish productsidentified when entering the EUmarket.
Data capture and management
Required for the information tobe made available to the competent authority on demand.
Required for all marine fisheryproducts traded with theEC, by means of a catchcertification scheme.
Data communication
Rules on labelling of food products and fish products.
Template of the catch certificatein the regulation.
THANK YOUTHANK YOU
Vincent ANDRE
Tel: +66 (0)2 651 5490
Mob: +66 (0)86 617 16 09
Vincent ANDRE
Tel: +66 (0)2 651 5490
Mob: +66 (0)86 617 16 09
www.aets-consultants.comwww.aets-consultants.com