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Brussels, 28 november 2002
Euro Coop position paper on Traceability
From 1st January 2005, Article 18 of Regulation 178/2002/EC laying down the general principles and requirements of food law, establishing the European Food Safety Authority and laying down procedures in matters of food safety will enter into force.
From this date, it will be compulsory for all feed and food operators to have a traceability system in place. They shall be able "to identify any person from whom they have been supplied with a food, a feed, a food-producing animal, or any substance intended to be, or expected to be, incorporated into a food or feed. To this end, such operators shall have in place systems and procedures which allow for this information to be made available to the competent authorities on demand".
As indicated in previous comments on the General Principles of Food Law and the Commission proposals on hygiene , EUROCOOP welcomes the introduction of traceability as one of the general food law principles. We believe that the traceability of all food and food ingredients along the food chain is a vital element in ensuring food safety and consumer protection. All stakeholders in the food chain must consider themselves as having the duty to take active responsibility for their part of the chain.
EUROCOOP therefore considers that traceability concerns all food-related issues. EURO COOP member organisations, the consumer co-operatives, have been using traceability for many years, and they believe it is an important risk management scheme. Based on their expertise and experience in this field, EURO COOP offers the following comments as a contribution to the debate on the implementation of the traceability requirement for feed and food operators as a step towards the entering into force of this EU legal requirements in three years' time.
- DEFINITION
According to the Regulation 178/2002/EC, "traceability" means 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".
- OBJECTIVES OF TRACEABILITY
The White Paper on Food Safety of 19 January 2002 indicates that adequate procedures should be in place to "withdraw feed and food from the market where a health risk is posed". EURO COOP agrees that traceability is essential for ensuring that there can be effective product recalls if a safety or quality problem emerges. Risk assessment can never be a complete assurance of their safety as science is continuously evolving. Traceability would help to ensure that there could be monitoring of the longer-term implications of products post-marketing and also enable them to be removed from the market if necessary.
As indicated in our comments on the Commission's proposals on GM food and feed, traceability and labelling , we also consider that traceability has the added benefit of enabling claims about products and their potential benefits to be monitored where necessary to ensure that consumers are not being misled.
- SPECIFIC REQUIREMENTS
- As indicated in our comments on the Commission's proposals on GM feed and food, traceability and labelling, we are concerned that the development of many and diverse European traceability systems (e.g., for beef products, GM foodstuffs, etc…) would hamper the consistency and coherency of EU legislation. This would also hinder the easy implementation of EU legislation at the national level. We would also like to stress that food operators should have the choice regarding which traceability system to use, and that this should not be spelt-out by EU legislation. If a single traceability system was to be developed and applied by food operators, it should be based on the functioning of the EAN system. This would simplify the current situation and lead to better monitoring.
- As required in the General Food Law Regulation, EURO COOP wishes to underline that all stakeholders involved in the food chain should be responsible for traceability at their own level only, rather than a requirement to trace back through the entire chain. Traceability is a "One-up, one-down" responsibility - to know who you have obtained it from and who you sell it to.
- Identification of the clients to whom the products have been supplied: EURO COOP stresses that consumer co-operatives cannot always identify what kind of customers they have. Therefore, we reiterate our support to the General Food Law Regulation , which states that the retailers should be exempted from the requirements of forward traceability.
- EURO COOP underlines that traceability should not be confused with labelling or consumer information; rather, traceability is a tool to achieve the objectives of labelling and consumer information. As mentioned above (see "objectives"), traceability can be used to verify the truthfulness of claims.
- Traceability must also be differentiated from identity preservation, which aims at ensuring that a product fulfils specific consumer needs and requirements.
- EURO COOP believes that traceability requirements should apply to products imported from Third Countries. This would ensure a higher level of consumer protection for European consumers. It is all the more important given that we live in an increasingly globalised world; hence the added importance of having reliable traceability systems.
- 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. We therefore welcome the recent Commission proposals on official feed and food controls, which aim at ensuring better implementation of EU and national food legislation.
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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