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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


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


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:


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)


(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


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





Operator



► Is a business operator obliged to match inputs and outputs?



Operator






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


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


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

[email protected]

Vincent ANDRE

Tel: +66 (0)2 651 5490

Mob: +66 (0)86 617 16 09

[email protected]

Vincent ANDRE

Tel: +66 (0)2 651 5490

Mob: +66 (0)86 617 16 09

www.aets-consultants.comwww.aets-consultants.com

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