1 of 36 EU REQUIREMENTS FOR THIRD COUNTRIES EXPORTING FOOD TO THE EU CTA Briefing on Food Safety...
-
date post
20-Dec-2015 -
Category
Documents
-
view
215 -
download
0
Transcript of 1 of 36 EU REQUIREMENTS FOR THIRD COUNTRIES EXPORTING FOOD TO THE EU CTA Briefing on Food Safety...
1 of 36
EU REQUIREMENTS FOR THIRD COUNTRIES
EXPORTING FOOD TO THE EU
CTA Briefing on Food Safety Standards
Brussels 11/05/2009Jacky Le Goslès
2 of 36
Scope of presentation
SPS agreement and equivalence
Requirements for third countries exporting food to the EU
Key components for a residue control system
Import controls
FVO inspections
BTFS programme
3 of 36
The European Union is the world’s largest importer of agricultural and fishery products
4 of 36
Sanitary & Phytosanitary Agreement
5 of 36
SPS Agreement
Art. 2.2.measures taken to protect public health…should be Science based and appropriate. Art. 2.3. … should not be an unjustified barrier to trade.Art. 3.1. … based on international standards, guidelines or recommendations, where they exist.Art 3.2. ..higher level of SPS protection possible if there is scientific justification
6 of 36
SPS - equivalence
Art. 4.1. Members shall accept SPS measures of other Members as equivalent... if the exporting Member objectively demonstrates … that its measures achieve the importing Member's appropriate level of SPS protection.
7 of 36
EU Food Law (Regulation (EC) No 178/2002)
Equivalence enshrined in Community Food LawArticles 11 and 12: Food and feed imported to the Community shall comply with the relevant requirements of food law or conditions recognised by the Community to be at least equivalent with requirements contained therein
Food shall not be placed on the market if it is unsafe
8 of 36
Requirements for third countries exporting food of animal origin to the EU
Every country wishing to export food of animal origin (FAO) to the EU must satisfy certain animal health, public health, veterinary
certification and residues requirements. Appear on ‘lists of authorised third countries’
Entire country or regionAuthorised commoditiesApproved establishments
Use of model certificates Food produced in accordance with EU rules
NOT ON RESIDUES LIST = NO EXPORTS
9 of 36
Import of FAO From Third Countries
specific requirements (e.g. control plan)
control missions
(FVO)
Specific listing
Import control of products
(BIP)
import
country establishmentVessel ZV/FV
Listing
general import & control legislation+
product specific legislation
general listing
Directive 97/78/EC imposes a veterinary control of food and feed products coming from third countries.
10 of 36
Decision No 4List of establishments
Decision No 2:Specific requirements
Decision No 3:Health certificates (AH and PH)
Request from the third Country
Technical Documentatio
n
Decision No 1:Addition to the list of third countries Standing Committee on
the Food Chain and animal health
Adoption by college of Commissioners
Import FAO From Third Countries
Official Journal
LISTING
11 of 36
Why does the EU require residues controls in FAO both from Member States and trading partners?
12 of 36
BECAUSEBECAUSE
Legislative requirement in EU
Public health - food safety
To detect and prevent abuse of drugs
To facilitate trade in animals and animal products
Equivalent standards expected from the EU’s trading partners: Art. 11, Directive 96/22/EC and Art. 29, Directive 96/23/EC)
13 of 36
Elements of a residue control system
Control systemR
esid
ue t
estin
g La
bora
torie
s
Res
idue
S
urve
illan
ce
(Mon
itorin
g P
lan)
Bor
der
insp
ectio
n po
sts
in t
he E
U
Mem
ber
Sta
tes
Lice
nsin
g an
d co
ntro
ls o
n us
e of
ve
terin
ary
med
icin
esFVO scrutiny
On-the-spot
Desk study
14 of 36
An approved residue plan is a prerequisite for export of food of animal origin to the EU.
Approved countries are listed in Commission Decision 2004/432/EC
Plans must be submitted to the Commission and approved annually
For third countries
15 of 36
What food is tested for residues?
Food of animal originLaid down in Community law
Council Directive 96/23/ECMember States test domestic and imported
16 of 36
Commission Decision 2004/432/EC revised twice in 2007 and twice in 2008
In 2008
10 countries delisted for total of 15 commodities
8 countries were newly listed or relisted for a total of 13 commodities
83 countries now listed
Improved understanding by third countries of EU
requirements
Residue monitoring plan evaluation - outcome
17 of 36
IMPORT CONTROLS IN EU BORDER INSPECTION POSTS (BIP)
BIPs are approved by the European Commission
BIPs are run by Member States
3 fold control, identification (i), documentary (d) and physical (p)
All consignments should be (i) and (d) controlled.
For most of the authorised TC only for 20% of the consignments are submitted to (p) control
Samples are taken and relevant analyses carried out only randomly (consignments kept until analyses results)
Positive results :rejection or destruction and RASF information
Protective measures (e.g. Histamine analyses on 100% of tuna swordfish consignments)
18 of 36
http://ec.europa.eu/food/international/trade/guide_thirdcountries2006_en.pdf
All relevant Community legislation may be obtained from:
http://europa.eu.int/eur-lex/lex/en/index.htm
19 of 36
FVO MISSION INSPECTION/AUDIT METHODS
METHOD: EVALUATION OF THE EFFECTIVENESS OF THE OFFICIAL CONTROL SYSTEM OF FAO EXPORTED TO THE EU (documented system ensuring the 2 above mentioned objectives)
EVALUATION OF THE CA CONTROL ACTIVITY IN ITS OFFICE, files of at least the visited farms, vessels and establishments
SAMPLE OF FARMS/VESSELS/ESTABLISHMENTS IN ORDER TO VERIFY CA CONTROL ACTIVITIES
SOME CHOSEN BY THE CA
SOME CHOSEN BY THE FVO: RASFF, FOLLOW UP OF A PREVIOUS MISSION OR TARGETTED MISSION
VERIFICATION IN SITU (FARMS/VESSELS, ESTABLISHMENTS)
20 of 36
E.G. MAIN FINDINGS RELATING TO FISHERY PRODUCTS EXPORTED TO THE EU
KNOWLEDGE, IMPLEMENTATION, CONTROL, ENFORCEMENT OF COMMUNITY REQUIREMENTS
CA EFFICIENCY, i.e. inspection frequency, scope, depth, follow-up, enforcement
BUDGET for CONTROLS/ANALYSES
LAB CAPACITIES/QUALITY OF ANALYSES
RESIDUE MONITORING PLAN FOR EXPORTED AQUACULTURE PRODUCTS
21 of 36
E.G. MAIN FINDINGS RELATING TO FISHERY PRODUCTS EXPORTED TO THE EU (cont.)
RUNNING/POTABLE/CLEAN WATER (ICE)
FRESHNESS OF FISH LANDED
HYGIENE OF OPERATIONS
COLD CHAIN
HYPER-CHLORINATED WATER USE
FP TRACEABILITY:
• FROM VESSELS TO PLANTS
• WITHIN PLANTS
• RAW MATERIAL IMPORTED OR COMING FROM NON « EU APPROVED » VESSELS OR ESTABLISHMENTS
HACCP Plan inappropriate, inadequate/insufficient documentation
NUMBER OF OWN-CHECK ANALYSES AND OFFICIAL ANALYSES
ADDITIVES (crustaceans)
HEALTH STATUS OF STAFF
22 of 36
FOOD of VEGETAL ORIGIN
Principal results from reports
General Lack of control by CA
Dependance on private standards
Poor performance in laboratories
No/poor controls at export
23 of 36
Principal Results Pesticides
High frequency of use
Lack of control on GAP or on registered users
Lack of control in application or follow up
Variable MRLs
Poor equipment/analytical capability and poor quality control in laboratories
24 of 36
Phytosanitary Controls
Problems with understanding of community regulations
Monitoring and official controls limited
Lack of documentation/ tracability
Principal Results
25 of 36
HOW TO IMPROVE THE SITUATION
Pressure on TC: pre-listing on hold, appropriate and proportionate protective measures, action plans and follow-up (on-desk exercise and FVO missions)CA official training: SANCO programmes, « Better Training for Safer Food » (Indonesia, Colombia and Senegal in 2006, Morocco, Mauritius, UAE, Chile and Viet Nam in 2007, Philippines and Jamaica in 2008)technical assistance provided by Commission services (DEV, AIDCO, TRADE, SANCO) following TC requests
26 of 36
Import From Third Countries
Import Control: reinforced measures
Test on each arrival/lot Additional costs supported by importers
Listing of • countries• establishments
Results significantly not conformand/ornegative report from FVO
De-listing
Results significantly not conform
Legislation and controls guarantee that exported products comply with EU legislation and consequently that their safety is not compromised
Safegardclause
27 of 36
BTFS programmeThe programme started in 2005-2006. Commission Communication COM (2006) 519 has identified a long-term steady state of 6,000 participants and budget of €15million annually (around 2011-2012)
0
500
1000
1500
2000
2500
3000
3500
4000
4500
5000
5500
6000
6500
7000
2005 2006 2007 2008 2009 2010 2011 201.
Estimated trend of participants
Starting-up phase
Steady state
28 of 36
2006 2007 2008
budget Number of training activities training days Number of participants
7.0 M€
3.5 M€
41255
1.400 71
615
2.900
110
800
4.000
9 M€
BTFSEvolution 2006-2008
29 of 36
BTFS
Food hygiene and controls
3 modules of 5 five-day courses on:
Meat and meat products
Milk and dairy products
Fishery productsFishery products
25 participants per workshop
Theoretical sessions, practical exercises, site visits, discussion as appropriate
30 of 36
BTFS
Hygiene and controls of fishery products (main subjects)
Organisation of official controls
Live Bivalve Molluscs: controls and applicable legislation
Controls of marine bio-toxins
Primary production
Hygiene requirements in freezers, vessels, processing establishments, fish farms and cold storage
31 of 36
Africa-EU Joint Strategy
Capacity building activities in the SPS field in Africa
2009-2010 (€10M)
32 of 36
Activity 1 (OIE)Evaluation of Performance of Veterinary Services + follow-ups
Activity 2 (OIE)Improvement of national / regional legal framework
Activity 3 (OIE)Laboratory capacity (twinning)
Activity 4 (OIE)Training of CVOs / National Focal Points
Activity 5 (AESA Cons.)-12 five-day Regional ‘training of trainers’ workshops:
-2 one-day (opening and closing) conferencesActivity 6 (AESA Cons.)
Sustained missions and ad hoc assistance (e.g. SMEs):1,560 days / 12 experts / 6 Regions (~ 26 countries)
33 of 36
EU SPS rules for import of food
of animal origin from Third Countries to the EU
SUMMARY
CTA Briefing on Food Safety Standards
Brussels 11/05/2009J. Le Gosles Adviser DG SANCO
34 of 36
Main Points to keep in mind
Food safety has become more important in the EU
EU first food importer in the world, e.g. More than 50% of fish consumed in EU are imported from TC/DC
Increase of establishments approved for export to the EU ( including freezer and factory vessels in TC)
More added value processed products imported
35 of 36
Main Points to keep in mind
EU rules based on SPS Agreement principles
Art. 2.2.measures taken to protect public health… should be Science based and appropriate.
Art. 2.3. … should not be an unjustified barrier to trade.
Art. 3.1. … based on international standards, guidelines or recommendations, where they exist.
Art 3.2. ..higher level of SPS protection possible if there is scientific justification
Art. 4.1. : Members shall accept SPS measures of other Members as equivalent... if the exporting Member objectively demonstrates … that its measures achieve the importing Member's appropriate level of SPS protection.
EU and EQUIVALENCEEquivalence enshrined in Community Food Law (Regulation (EC) No 178/2002)
Articles 11 and 12: Food and feed imported to the Community shall comply with the relevant requirements of food law or conditions recognised by the Community to be at least equivalent with requirements contained therein
36 of 36
Main Points to keep in mind
Import of FAO From Third Countries
specific requirements (e.g. residue monitoring programme)
control missions
(FVO)
Specific listing
Import control of products (BIP)
import
country establishmentVessel ZV/FV
Listingcontrol
missions(FVO)
general import & control legislation+
product specific legislation
general listing
Directive 97/78/EC imposes a veterinary control of food and feed products coming from third countries.
37 of 36
Decision No 4List of establishments
Decision No 2:Specific requirements
Decision No 3:Health certificates (AH and PH)
Request from the third Country
Technical Documentatio
n
Decision No 1:Addition to the list of third countries Standing Committee on
the Food Chain and animal health
Adoption by college of Commissioners
Main Points to keep in mind
Import of FAO From Third Countries
Official Journal
LISTING
38 of 36
Main Points to keep in mind
A Competent Authority (or more but need for a very good cooperation/coordination) and laboratory capacities;
Official (documented) controls all along the FAO production chain, including primary production and sampling/analyses
Residue and environmental contaminant monitoring programme;
FBO Establishments
: Structures and equipment requirements, Good Hygiene Practices (SSOPs) and HACCP system in place
Ensuring the eligibility of the FAO exported to the EU (« sanitary » traceability) from primary production to exported consignments;
Better Training for Safer Food (BTFS) programme and Technical Assistance (TA )