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Brussels, 18 october 2000
Euro Coop's comments on the Commission's proposal on hygiene of foodstuffs
Euro Coop is the European Community of Consumer Co-operatives, whose members are the national organisations of consumer co-operatives in 12 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 recent Commission's proposal on hygiene.
Euro Coop welcomes the Commission's proposal for a Regulation on hygiene of 14 July 2000 (COM (2000) 438 final). We support the Commission's intention to reorganise and simplify the 17 existing directives relating to hygiene of foods of plant and animal origin into 4 Regulations and one Directive.
In Euro Coop's view, a rationalisation of the hygiene policy will indeed facilitate its implementation as well as its understanding by consumers and all stakeholders involved in the food chain. Euro Coop also welcomes the holistic approach of the Commission, covering all foodstuffs from stable to table.
However, Euro Coop has identified various points, which could undermine the scope of the reform. We are very concerned that there are producers who may be omitted from the full scope of the proposal. We do not feel that this fully reflects the wish of the Commission to safeguard food production from primary production to the final consumer. Also, we feel that certain practical measures need further consideration to ensure the success of the reform.
We regret that, following the reform announced in the White Paper on Food Safety , the Commission has not fully seized the occasion to bring major improvements to the existing situation. Considering the recent food scares, such as BSE and the dioxin crisis, and the resultant loss of consumer confidence, we urge the Commission to strengthen the existing hygiene rules, rather than just simplify and harmonise them.
The following comments explain more fully Euro Coop's position concerning the Commission's proposal for Regulations on hygiene. Euro Coop requests the Commission to consider the following points:
- Euro Coop welcomes the extension of the Hazard Analysis Critical Control Point System
Euro Coop has always supported the HACCP system. It is a modern method of securing food safety and it is accepted internationally. We therefore welcome its extension across Europe to all non-primary food producers.
As a risk-based control system, HACCP will ensure food producers are assessing and addressing the likely hazards within their complete production system. The system will help to reassure consumers that their food is being regulated throughout its production, regardless of its origin within Europe.
- Euro Coop believes that the HACCP system must be compulsory for farmers
Euro Coop strongly opposes the exemption of farmers from the HACCP system, and urges the Commission to take appropriate measures to implement the farm to table principle.
Euro Coop indeed believes that the HACCP principles should be obligatory for all food operators, including farmers. Recent large-scale food scares could have been prevented if primary producers had implemented food safety regulations. Codes of Good Practices are considered a useful supportive tool to implement the hygiene rules. However, Euro Coop takes the view that the simple use of Codes of Good Practices would not be sufficient because there is no recourse to law. Farmers are not obliged to use them. The codes are produced to help compliance with legal requirements and are guides only.
Furthermore, Euro Coop considers that exempting farmers from the HACCP system is in contradiction to the "farm to table" principle, spelt out in the proposal as "the need to ensure food safety throughout the food chain, starting with primary production".
- Euro Coop asks for more details on control measures
Euro Coop welcomes the Commission's commitment to the production of a new and comprehensive law on food and feed controls by the end of this year in order to improve the quality of control systems throughout the whole of the chain from farm to fork.
Euro Coop considers that a key objective of this law should be to ensure that adequate enforcement and control resources both within Member States and at Commission level are allocated appropriately throughout the food chain. Euro Coop is concerned that at present control resources are concentrated at certain points in the food chain, for example in slaughterhouses.
This new law should include a requirement for enforcement authorities to oversee the implementation of HACCP in an effective way. It should require enforcement authorities to be trained in HACCP procedures and implementation.
The Commission's proposal makes it compulsory for all food businesses to be registered. Euro Coop agrees with this proposal. Most of Euro Coop's members have a registration system in place in their countries, and this system has proved to work.
- Euro Coop does not support exemptions for "traditional food" and remote areas
The Commission's proposal makes available derogations for "traditional food" and remote areas, to exempt them from the HACCP scheme. Euro Coop does not agree with the exception for those regions with supply constraints, nor with the exception for traditional methods of food production. However, we believe that the HACCP system must be flexible enough to be adequately implemented in these particular cases without onerous cost implications.
Consumers need to be reassured that the farm to plate food safety system is complete and the whole food chain is controlled. Euro Coop feels that there are undefined limits to these exemptions and they could easily be used as excuses for non-compliance of European and national legislation.
- Euro Coop believes that supporting measures should be planned for the small and medium enterprises
Euro Coop is very concerned about the managerial and financial problems the small and medium enterprises (SMEs) will encounter to implement the HACCP scheme.
Euro Coop strongly believes that supporting measures should be planned for the SMEs to ensure the effective implementation of the farm to table principle. We consider that the Commission should make sure that all stakeholders involved in the food chain are able to implement the HACCP scheme and that the new hygiene policy has no exclusion.
Euro Coop believes that European funding and training would be required for the SMEs to understand the purpose of and implement the HACCP principles. Such supporting measures are vital to ensure the effective implementation of the new hygiene regulations, and therefore consumer safety.
- Euro Coop considers that training and information should be widely available, from farmer to consumer including enforcement authorities
The proposed hygiene policy underlines the need for food business operators to be trained. Euro Coop agrees with this proposal. However, Euro Coop takes the view that training is also an essential prerequisite of the system for all control officers at the local, regional, national, and European levels.
We also consider that consumers should have readily available advice and information on food safety and be informed about the reasons for HACCP. This would allow them to better understand the close linkage between hygiene and food safety and the HACCP system.
- Euro Coop believes that transparency is vital to regain consumer confidence
Euro Coop considers that the Commission's proposal does not contain effective measures that would ensure the transparency of the inspection procedure. Consumers should be given the possibility to be fully informed about the implementation and working of the HACCP system. This is vital to regain consumer confidence as well as to encourage effective implementation of the HACCP principles.
- Traceability is welcomed but Euro Coop is concerned about the method of implementation
The Commission's proposal introduces the principle of traceability of all food and food ingredients. Euro Coop agrees that the traceability of all food and food ingredients along the food chain is a vital element in ensuring food safety. Moreover, Euro Coop considers that traceability concerns all food-related issues, including hygiene, but also all the other food safety issues, such as, for example, genetically modified organisms and beef labelling.
Euro Coop acknowledges the cost implications of the traceability requirements. However, we are concerned about the method of implementation proposed by the Commission. Euro Coop believes that all stakeholders involved in the food chain should be responsible for traceability at his own level only, rather than a requirement to trace back through the entire chain. We feel that the provision on traceability is not detailed enough, and we request the Commission to provide more information about the traceability procedure planned in the hygiene proposal.
Regarding the Commission's power to ensure appropriate traceability for food and food ingredients, Euro Coop asks for more details on Article 10, 3 of the Proposed Regulation N° 2000/178 (COD) on the hygiene of foodstuffs.
- Euro Coop approves the choice of Regulations as legislative instruments but expresses concerns about their correct drafting
The new hygiene policy is contained in 4 Regulations, which will be binding in their entirety and directly applicable in all Member States. Euro Coop understands that the recourse to Regulations would ensure a faster implementation of the new hygiene scheme. However, Euro Coop stresses the need for the regulations to be correct and clear in their drafting, as they will be prescriptive and mandatory.
Euro Coop is concerned about the implementation date proposed by the Commission. The 1st January 2004 may not be the most appropriate date, as all stakeholders involved in the food chain are fully occupied at this time of the year. This is particularly the case for retailers where Christmas and New Year are very busy seasons.
In conclusion, Euro Coop considers that the rationalisation of the current hygiene rules is a positive move towards consumer protection, but is concerned that the proposed reform may not be effective unless specific measures are planned to put the principles in practice. A complete food safety system would enable all stakeholders to actively scrutinise his part of the food chain by self-assessment and minimise future potential problems to consumers.
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