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T raceability and Labelling of Fishery products in the EU

T raceability and Labelling of Fishery products in the EU. Gerard Roessink Food and Consumer Product Safety Authority The Netherlands. Traceability what is it. Definition

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T raceability and Labelling of Fishery products in the EU

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  1. Traceability and Labelling of Fishery products in the EU Gerard Roessink Food and Consumer Product Safety Authority The Netherlands

  2. Traceability what is it • Definition • The ability to trace and follow a food, feed, food-producing animal or substance intended to be, or expected to be incorporated into a food or feed, through all stages of production, processing and distribution.

  3. Traceability – the requirements and their understanding • Food Law – Regulation 178/2002 article 3 point 15 and article 18 • Guidance on Implementation of art. 11,12, 16, 17, 18, 19, 20 in the Food law (20. December 2004)

  4. Trace ability • When something has gone wrong we need to find who is responsible • To avoid the same mistake will be made again • Product liability, histamine example

  5. Trace ability is it new? • Should be a part of the food safety system • Together with HACCP • Thinking ahead which problems might occur and have a solution ready before it happens

  6. New interest in trace ability • After crisis in the food industry namely: • Mad cow disease (BSE) 1996 in UK • Dioxin contamination in Belgium 1999

  7. EU LEGISLATION Three basic principles : 1. Safe food from Farm to fork – from Water to mouth 2. Producer is responsible 3. Supervision CA through Trace ability HACCP

  8. Traceability • Apply to • All stages of production, processing and distribution • Includes • Food, Feed, food producing animals, and any other substances incorporated in the food

  9. Trace ability • Origin of food stuffs • Processing history • Distribution and location after delivery • Storage circumstances

  10. Traceability • Require • Food and Feed Business operators shall have systems and procedures in place which allow them to identify • immediate suppliers of substances to be incorporated in a specific product • buyers related to a specific product. • Such information shall be made available to competent authority at demand

  11. HOWEVER • This will often be required as part of commercial contractual arrangements • Specific requirements which involves traceability still apply, eg. • primary producers control and record keeping in regard to feed, veterinary medicines and diseases still apply (Reg. 852, Annex1): certificate of origin for bivalves (Reg. 853, Annex x) • The application of identification marks (Reg. 853, Annex I)

  12. Internal Traceability ? • Food Law – article 14 part 6 • If a part of a batch is considered unsafe – the whole batch will be considered unsafe • Unless a detailed assessment show evidence that this is not the case • Suspected unsafe: Withdrawal of a product, even if in conformity, is possible

  13. Internal Traceability ? • Food Law – article 14 part 6 • If a part of a batch is considered unsafe – the whole batch will be considered unsafe • Unless a detailed assessment show evidence that this is not the case • Suspected unsafe: Withdrawal of a product, even if in conformity, is possible

  14. Labelling • Health or Identification Marks (Regulation 853/2004 Art. 5 and 6 and Annex 2) • Other Labeling • Directive 104/2000 on common organisation of the Market • Article 4 on consumer information (specifically for fishery products) • Directive 2000/13 on labelling, presentation and advertising of foodstuffs • Specific requirements for bivalves • 853 ch. VII section VII

  15. Food Buisness Operators Obligations • Apply Identification Mark on all products placed on the market – also imported products • Health and Identification Marks shall be applied only to products produced in approved or registred establishments

  16. Traceability and Import to EU • The Scope of article 18 of Food Law (or Reg. 178/2002) • Only intra-territorial effect, i.e. • the article apply only from importer up to retail level in EU. • the importer in EU must be able to identify only the exporter in the 3. country • the importer do not need to require tracebility beyond the exporter in the 3. country.

  17. Identification Marks • Shall be placed on the product before it leaves the company • Shall include information about country in which the establishment is located and approval number • If re-packing and re-processing takes places the Health Mark shall be linked to the operation where this takes place.

  18. Commission Regulation 104/2000 Labelling requirements: • commercial designation of species • production method • catch area and: physical appearence or specific treatment fresh or frozen

  19. Commission Regulations 2065/2001 and 104/2000 1. the commercial designation of species list of local names Examples of member states lists • Art. 4 and Regulation 104/2000 Annex I-IV 2. production method wild catch fresh water / sea aquaculture fresh water / sea • catch area or country of production

  20. (EG) 2065/2001 Catch areas: • wild catch at sea: FAO areas • wild catch in fresh water name country • aquaculture products: name country end phase

  21. Market stall

  22. Other labelling requirements • General requirements for labelling, presentation and advertising (Directive 2000/13) • Applies to all products to be delivered to the ultimate consumer (retail packs and catering)

  23. THE LABEL • Always compulsary (article 3) • Name under which the product is sold • List of ingredients • The quantity of certain ingredients or “categories of ingredients” (= also additives) • The net quantity • Minimum durability or “used by” date • Special storage conditions or conditions of use • Name or Business name and adress of manufacturer, packager or seller established in EU • Particulars of the place of origin if lack of such may mislead to consumer • Instructions for use, if otherwise impossible to use the product appropriately. ………

  24. The label says • Some requirements of specific relevance to fishery products from 3. countries (article 5.3) • Specific information about the treatment (frozen, smoked, dried…) • Information about ionising radiation if such is used (in relevant member state language) ……..

  25. Trace-ability

  26. Trace-ability • Each link in the chain from water to mouth must be able to know where the fish comes from and where the fish will go.

  27. Trace-ability • Can be done with • expensive equipment • But simple systems • are OK

  28. Trace-ability

  29. What is a simple system • Paper record; paper trail • Could be the invoice • Health check document addition

  30. Thank you for your attention

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