EU food safety regulations a business perspective

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EU food safety regulations - a business
perspective

• Olivier Hottlet

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Introduction

• A few highlights of points that seem relevant,
  based on over 20 years experience as frozen
  seafood importer in Europe
• Beside being a businessman, also very active in
  several professional organisations such a IAFI,
  SIPA (the Seadood Importers and
  ProcessorsAlliance), Belgafood, Fedis, Frucom
  and Eurocommerce

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Discussion points

• Brief historic overview
• What is being checked
• Who is paying
• What exporters should learn
• Points of special attention

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1. Brief historic overview

• Before 1983 (general gtlt France, Spain and few
  others)
• 1983 Shighella food poisoning in NL gt the Benelux
  regulations
• Early 1990s the EU approach (government to
  government)
• Today a cascade of regulations, increasing
  every day, hard to keep track of

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2. What is being checked

• Earlier main focus on final processing and
  microbiological aspects
• Nowadays more focus on the environment and on
  residues and contaminants

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Ranking of food safety issues in relation to
human health

• Microbiological contamination 100 000
• Unbalanced diet 100 000
• Environmental contamination 100
• Natural toxins 100
• Pesticide residues 1
• Food additives 1
• HACCP is for operators but not necessarily for
  authorities. Risk perception is a major element
  in policy making

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3. Who pays

• The importer is on the front line to pay for all
  shortcomings
• The exporter follows shortly after, and must also
  pay for all required improvements and added
  controls
• The consumer will not always pay more the prices
  he pays are set by supply and demand

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4. What exporters should learn

• Make each link in the chain accountable
  especially important for residues and
  contaminants
• This is only possible with a good traceability
  system in place
• Knowing what happens and where will help avoid
  food crisises and/or help solve them faster

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5. Points of special attention

• Health certificates the tower of Babel
  revisited
• Microbiological standards still far from being
  harmonized
• Residues and contaminants the limits of science
  and the precautionary principle
• EUs new eagerness in requesting importers to
  destroy goods

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5.1 Health Certificates

• Very complicated and detailed, per products and
  per exporting country
• Established in the language of the country where
  the goods arrive in the EU that of the country
  it is destined for does the signing person
  understand ?
• Versus certificate of origin very simple
  format with numbered boxes, in English or French
  only all underlying agreements are negotiated
  from government to government

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5.2 Microbiological standards

• Far from harmonized in the EU
• RAS notices most are based on national
  criteria, not EU criteria listeria, salmonella,
  vibrio parahaemoleticus, total plate count, etc
  (non tarriff barriers ?)
• Pervert effect of RAS notices in some countries

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5.3 Residues and contaminants

• Its not because one cannot prove that a
  contaminant is not harmful for health that it
  automatically presents a danger for health
• In a polluted world, zero tolerance for residues
  and contaminants is not a viable option, with
  labs soon capable of tracking a single molecule

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5.4 Destruction

• Some EU MS are very eager to destroy
• Danger for public health ? 1 ppb SEM in
  shrimps is dangerous and requires destruction
  (in spite of 96/23) gtlt 10 ppb SEM in babyfood is
  no reason for alarm
• Authorities try to force the operators to make
  the decision
• Exporting country has no right for recall

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CONCLUSION

• EU food safety regulation extremely complex and
  to be learned thoroughly
• Very usefull global approach and accountability
  of each link of the foodchain
• Full of boobytraps - not the least thet fact that
  EU is eager to destroy goods
• GOOD LUCK