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Brussels, 14 February 2003
Euro Coop is disappointed at the incomplete proposals on microbiological criteria for foodstuffs
Euro Coop is the European Community of Consumer Co-operatives, whose members are the national organisations of consumer co-operatives in 11 of the 15 Member States of the EU and in 4 Central and Eastern European countries.
Created in 1957, Euro Coop today represents over 3,200 local or regional co-operatives, membership of which amounts to over 19 million consumers in the EU and 2 million in the associated countries of Central and Eastern Europe. Euro Coop's major objectives have been to promote, defend and represent consumer interests at European level.
It is on the basis of this expertise that Euro Coop has prepared the following comments on the draft Regulation on microbiological criteria for foodstuffs and food production.
Euro Coop, the European Association of Consumer Co-operatives, welcomes the Commission's initiative to revise and set horizontal microbiological criteria based on each category of foods. As mentioned in previous position papers on the hygiene of foodstuffs and on zoonoses1, Euro Coop believes that strict measures should be adopted to prevent food poisoning and ensure consumer safety. Food borne pathogens such as Salmonella, Campylobacter, E. Coli 0 157, and L. monocytogenes are a public health problem, and especially so for vulnerable groups such as the elderly, infants, and pregnant women.
However, we have identified a number of points, which could hamper the effectiveness of the proposed Regulation. We are in particular concerned that the draft proposal does not properly implement the farm to fork principle. It will indeed be in line with the Commission proposal on the hygiene of foodstuffs, which exempts farmers from the HACCP system. Furthermore, Euro Coop regrets that the proposals are incomplete, and considers that some microbiological criteria do not go far enough to achieve the objective of strengthening consumer safety.
- Euro Coop is concerned that the draft Regulation on microbiological criteria would not properly implement the "stable to table" principle
Euro Coop welcomes the stable-to-table approach of the Commission enshrined in the new EU Food law legislation. Euro Coop has always argued for an integrated approach, which it has reiterated in its comments on the Commission's proposal on the general principles of food law and establishing the European Food Authority2. Recent food scares have proved that contaminated animal feeds have been an indirect cause of food hazards and need to be strictly controlled to prevent future problems occurring.
However, Euro Coop is concerned that the draft Regulation on microbiological criteria for foodstuffs and food production may impede the full implementation of the farm to fork principle. This draft proposal indeed refers to the Commission's proposal on the hygiene of foodstuffs, which exempts farmers from the HACCP system. Euro Coop reiterates its opposition to this exemption and urges the Commission to take appropriate measures to implement the farm to table principle. Exempting farmers is in contradiction with the "farm to table" principle.
- Euro Coop agrees that microbiological testing is a HACCP verification tool, but calls for more details on their implementation
Both the strategy and the draft Regulation recognise that microbiological testing is limited as a HACCP verification tool. Failure to detect a pathogen does not necessarily imply that a food is safe. Euro Coop agrees however that microbiological criteria on their own cannot achieve the improvements in product safety envisaged by the Commission Services.
However, we believe that future EU legislation will be only be effective and practical if the actors of the food chain can determine through HACCP what is appropriate for them. We would therefore like to see further details on the implementation of such criteria based on HACCP principles. Euro Coop understands that the recourse to a Regulation would ensure a faster implementation of the microbiological criteria. However, Euro Coop stresses the need for the regulation to be correct and clear in their drafting, as it will be prescriptive and mandatory.
- Consumer safety requires completion of Annex I
Euro Coop notes that the draft Regulation will be updated on the basis of the three forthcoming Opinions of the Scientific Committee on Salmonella, Verotoxigenic E.coli and S.aureus. However, we regret that the proposal is circulated as incomplete as we find it difficult to comment a list (Annex I), which still appears to be at an embryonic stage. Therefore, the following comments represent preliminary remarks. We hope to comment more fully at a later stage once a complete draft of Annex I is available.
Evidence shows that the existing problems in the food chain regarding Salmonella, Campylobacter, EHEC including E. Coli 0 157, L. monocytogenes, and other foodborne pathogens need urgent consideration3. Euro Coop believes that microbiological criteria can play an important role in verifying the safety of foodstuffs, but we consider that they should be realistic and practical. Furthermore, Euro Coop agrees with the legal basis of the draft Regulation (i.e. the future Regulation on the hygiene of foodstuffs) as it is important to ensure legal consistency of the EU legislation. Euro Coop considers that the Commission should follow the scientific advice of the Scientific Committee on Veterinary Measures and Public Health (SCVPH) regarding the distinction made between Guidelines and Standards. As a minimum, the criteria should be compulsory for pathogens, although guidelines may be sufficient in the other cases.
Our initial specific comments on Annex I are the following:
- In principle, Euro Coop is concerned that the criteria for L. monocytogenes do not cover all foods. We are disappointed to see that some products, such as for example bread and biscuits and similar products, sugar, honey and sweets, fresh, uncut and unprocessed vegetables and fruits4, are excluded from the scope of the proposed Regulation. We believe that none of these foodstuffs should be sold if they contain more than 100 cfu/g. Furthermore, some Euro Coop members consider that L. monocytogenes must be absent in 25g of any food which to great extent support the growth of L. monocytogenes (i.e. soft cheeses, whether they are made from raw, thermized or pasteurised milk).
- Regarding Salmonella and E. Coli 0 157, Euro Coop proposes to have the following criteria for both of them: they must be absent in 25 g of any ready-to-eat food, and the action in case of detection should be to withdraw the product from the market.
- Regarding salmonella in minced meat and meat preparations, Euro Coop notes that the proposed Regulation does not contain any indication about the criteria to be followed. We believe the existing criteria (absence in 10g) should be adopted, rather than a criteria for 25g as proposed by the SCVPH.
As already stated, the above represents preliminary comments. Euro Coop looks forward to receiving the new version of the draft Regulation with a view to providing more concrete comments.
1. Position papers on the hygiene of foodstuffs and on
zoonoses
2. comments on the Commission's proposal on the general principles of food law and establishing the European Food Authority
3. Discussion Paper on Strategy setting microbiological criteria for foodstuffs in Community legislation, 3.12.2002 (SANCO) 1252/2001 Rev. 8, page 23 (Annex II: "Summary of the report experts participating in Task 2.1).
4. See page 9 of the draft Regulation on microbiological criteria for foodstuffs and food production.
For further information, contact:
Dónal WALSHE, Secretary General
or
Aude L'hirondel, Food Policy Officer
Tel.: +32.(0)2.285.00.74 - Fax: +32.(0)2.231.07.57 - E-mail: alhirondel@eurocoop.org
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