EU HYGIENIC REQUIREMENTS in BULGARIAand their IMPACT ON AGRICULTURAL PRACTICES

in HIGH NATURE VALUE AREAS of

HNV SeminarVillage of Brashlyan, Strandzha Nature Park

26 – 27 June 2007

Stanimir Stoychev Independent Consultant

STOYCHEV Consult ЕООD

Emil Petrov Independent Consultant HACCP

STRUCTURE OF THE PRESENTATION

Overview of the ЕU hygiene legislation Overview of the harmonized BG hygiene

legislation Analysis (scenarios) of potential impact of

hygiene legislation on SMALL and MEDIUM-SIZE agricultural producers and processors in High Nature Value (HNV) areas

Conclusions Recommendations

THE QUESTION IS ...

Can traditional practices of milk and meat production and processing in HNV areas be preserved observing existing increased hygienic requirements in accordance with the

national legislation?

Overview of the EU hygiene legislation

Regulation (EC) 852/2004 laying down common rules

on food producing enterprises concerning foodstuffs

hygiene

Regulation (EC) 853/2004 laying down specific hygiene

rules on food of animal origin

Concerning buildings and equipment

Concerning indicators for TNM and TNSCs

Overview of EU hygiene legislation

3. This regulation 853/2004/ЕС shall not apply to:

a) primary production intended for private home use;

b) home preparation, handling or storage of food for private home consumption;

c) the direct supply, delivered by the producer, of small quantities of primary products to the end consumer or to local retail establishments directly supplying the end consumer;

d) the direct supply, delivered by the producer, of small quantities of meat from poultry and lagomorphs slaughtered on the farm to the enf consumer or to local retail establishments directly supplying such meat to the enf consumer as fresh meat;

(e) hunters who supply small quantities of wild game or wild game meat directly to the end consumer or to local retail establishments directly supplying the end consumer.

4. Member States shall establish, according to national law, rules governing the activities and persons referred to in paragraph 3 (c), (d) and (e). Such national rules shall ensure the achievement of the objectives of this Regulation..

Overview of the harmonised BG hygiene legislation (1)

Strategy for the development of milk animal-breeding and improvement of the quality of raw cow’s milk for the period 2006-2009

Law on the support of agricultural producers Law on the veterinary activities Law on foods Law on fodder Law on animal-breeding Regulation No.44/20.04.2006 on the veterinary requirements

concerning animal-breeding sites Regulation No.51/20.04.2006 concerning the national reserve,

individual milk quotas, approval of buyers and the buying up of cow’s milk

Regulation No.61/09.05.2006 concerning the conditions and order for identification of animals, registration of animal-breeding sites and access to the database of the identified animals

(draft) REGULATION CONCERNING THE SPECIFIC REQUIREMENTS of THE PRODUCTION, STORAGE AND TRANSPORTATION OF RAW COW’S MILK AND THE REQUIREMENTS FOR THE TRADE AND PLACEMENT ON THE MARKET OF DIARY PRODUCTS

Overview of the harmonised BG hygiene legislation (2)

Good Manufacturing Practices (GMP) for buying out and processing of raw cow’s milk

Conditions for maintaining the land in good agricultural and environmental condition (Good Agricultural and Environmental practices)

EXAMPLES of the REQUIREMENTS under Regulation 44

Up to 2009, a farm must meet the following requirements : To have separate premises for animals of different

technological groups conforming to the requirements relating to the parameters of the living environment

To have production equipment and premises for storage of milk until its delivery for processing which shall comply with the veterinary-sanitary and hygiene requirements relating to milk production

To ensure adequate conditions for veterinary care and stationary treatment of the animals

To have isolated maternity boxes or to create a delivery premise

To ensure conditions for movements of the animals To possess premises and grounds for open-air breeding

of calves complying with the regulations related to the protection and humane treatment during calf-breeding

To keep and handle waste in a manner preventing environmental contamination.

OBJECTIONS to Regulation 44

This regulation should only apply to large animal-breeding complexes

This regulation provides no requirements related to the pastures and meadows needed for ruminant animals (cattle and sheep)

This regulation does not apply to traditional animal-breeding practices, e.g. breeding sheep herds in movable pens (sheepfolds) on harvested fields

The requirements related to summer mountain animal camps are not addressed

Mountainous breeding of calves and weaned lambs are not addressed

This regulation describes “bookish” norms for animal-breeding but it has been forgotten that norms depend on the applied breeding technology

This regulation should provide conditions for the development of not only “large” but “small” farms, as well

EU Legislation

Presents complicated requirements

within large limits

Makes possible interpretations

Implementation of these large

requirements into practice is not

accompanied by concrete requirements

and model implementation scenarios

No clear relation of EU hygienic

requirements with the EU policy

relating to rural development exists

Presents very well translated hygiene

requirements contained in EU

regulations with increased and ambitious

objectives

Limited transitional period for

implementations

Poorly presented to farmers and limited

transparency relating to specific

requirements

Diverse interpretation on local level

Improperly trained officials for the

control of hygienic requirements

Lack of clarity with respect to direct sale

practices

BG Legislation

SITUATION OF ANIMAL-BREEDING IN THE DAIRY SECTOR (intensive regions)

Plovdiv Region: 30 registered milk buyers

Farms of group 1 129 farms with 7,696 dairy cows Average herd size: 60 cows Varying from 11 to 792 cows

Farms of group 2 112 farms with 2,707 dairy cows Average herd size: 24 cows Varying from 5 to 78 cows

Sliven Region: 18 registered milk buyers

Farms of group 1 72 farms with 4,180 dairy cows Average herd size: 58 cows Varying from 11 to 550 cows

Farms of group 2 59 farms с 1,115 dairy cows

Average herd size: 19 cows Varying from 6 to 70 cows

SITUATION OF ANIMAL-BREEDING IN THE DAIRY SECTOR (areas of HNV)

Bourgas Region: 7 registered milk buyers

Farms of group 1 38 farms with 2,131 dairy cows Average herd size: 56 cows Varying from 11 to 296 cows

Farms of group 2 35 farms with 640 dairy cows Average herd size: 18 cows Varying from 4 to 146 cows

Smolyan Region: 12 registered milk buyers

Farms of group 1 59 farms with 667 dairy cows Average herd size:– 11 cows Varying from 5 to 79 cows

Farms of group 2 25 farms with 303 dairy cows Average herd size:– 12 cows Varying from 5 to 75 cows

EXAMPLES of the REQUIREMENTS of REGULATION 853/2004

CATEGORYMilk farm

Transitional period TNM TNSC BUILDINGS

Group I up to 100,000/ml

up to 400,000/ml

Requirements met

Group II

Start 2008End 2009

from 300,000/ml

up to 100,000/ml

up to 400,000/ml

Requirements met

Up to end 2007

from 500,000/ml

up to 300,000/ml

от 500,000/mlUp to

400,000/ml

Group III Up to end 2007

up to 500,000/ml

up to 500,000/ml

Requirementsnot met

SITUATION OF ANIMAL-BREEDING IN THE DAIRY SECTOR– as of 1 June 2007

STRUCTURE OF MILK HERDS IN BULGARIA

78%

8%

14%

1

2

3

INDICES CATEGORYGroup 1 Group 2 Group 3

Number of farms 1,145 1,353

?Number of diary cows 47,970 28,779

Average number per farm 42 21

Total number of dairy cows as of 2005: 350,000 Total number of milk producers with quotas for shipment and direct sale: 96,572

CONCLUSIONS

Greatest impact have the requirements concerning milk

hygiene and the requirements concerning buildings

Lack of clarity on how direct sales have to be carried out

Lack of clarity with respect to milk processing at farm level

Lack of nationally represented organisation for protection of

small and medium-size milk processors

Existing conflict of the legislation regulating cow’s milk

producers organisations

RECOMMENDATIONS

Introducing amendments in BG legislation correcting 2 things: Milk processing on “farm” level practicing “direct sales”

Establishing a national organisation of “small” milk processors processing on “farm” level and applying direct sales

Establishment of milk producers groups on regional principle practicing traditional methods of agriculture who will be able to apply for support of up to EUR 3,000 for the production of traditional products under the RDP (2007–2013)