Jeannie Vergnettes

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FOOD AND FEED TRACEABILITY PERSPECTIVE FROM E.U.
COMMISSION

• Jeannie Vergnettes
• Principal Administrator
• General Food Law
• Health and Consumer Protection Directorate-General
  

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OVERVIEW OF PRESENTATION

• EC traceability requirements
• Applicability to third country operators
• Commission implementation guidelines

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TRACEABILITY a general requirement of food law

• THE DEFINITION(covers all food/feed and the
  entire food and feed chain)
• 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
• Stages of production, Processing and Distribution
  means any stage, including import, from and
  including the primary production of a food, up to
  and including its storage, transport, sale or
  supply to the final consumer and, where relevant,
  the importation, production, manufacture,
  storage, transport, distribution, sale and supply
  of feed

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TRACEABILITY OBJECTIVES

• Objectives
• Food safety (withdrawals, identification and
  containment of a problem, facilitate controls)
• Labelling of information related to products
  characteristics
• Fair trade between operators

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TRACEABILITY THE REQUIREMENT (article 18)

• The traceability of food, feed, food producing
  animals, and any other substance intended to be,
  or expected to be incorporated into a food or
  feed shall be established at all stages of
  production processing and distribution.
• Food and feed business operators shall be able
  to identify from whom and to whom their products
  have been supplied and to have systems and
  procedures in place that allow for this
  information to be made available to the
  authorities
• More detailed requirements by sector-specific
  legislation, as appropriate

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TRACEABILITY Art.18 - A general requirement

• Art. 18 makes mandatory the supplier
  traceability  first step  and customer
  traceability  third step
• (the second step being internal traceability or
  process traceability.)
• It does not provide for any means / system/
  technology
• Up to business to opt for the most appropriate
  technology depending their business activity and
  size

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TRACEABILITY HYGIENE RULES FOR FOOD

• Requirements
• Registration of establishments (for all food
  business and production)
• A health mark (by veterinary authorities, for
  food of animal origin)
• An identification mark (by companies, for food of
  animal origin)
• Objective safety, facilitate control
• Means applied directly to the product, the
  wrapping or packaging, or printed on a label
  affixed to the product/or an non-removable
  tag.

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SPECIFIC TRACEABILITY

• IDENTIFICATION OF FOOD (lot numbering)
  (Directive 89/396/EEC
• FRESH FRUITS AND VEGETABLES REG. EC/2200/1996
• BEEF TRACEABILITY (REG. EC/1760/2000)
• TRACEABILITY REQUIREMENTS FOR FISH (REG. EC/
  2065/2001)
• GM TRACEABILITY (REG. EC 1830/2003)
• TRACEABILITY OF EGGS (REG. EC/2295/2003)

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APPPLICABILITY TO THIRD COUNTRIES

• Concerns about applicability to imported products
  and third country operators
• No extra- territorial effect outside E.U.
• Applicability to E.U. importers
• Possible traceability requests on a contractual
  basis

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EU implementation guidelines

• To harmonise the implementation by member States
  and E.U. operators
• Available on SANCO website

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Implementation issues

• Identification of suppliers and customers
• Internal traceability
• Types of information to be kept
• Time for record keeping
• Maximum time for reaction