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©2007 Waters Corporation Food Safety Regulation: Food Safety Regulation: Comparing the EU and Japanese systems Comparing the EU and Japanese systems Paul B Young, PhD Paul B Young, PhD Waters Corporation Waters Corporation [email protected] [email protected]

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©2007 Waters Corporation

Food Safety Regulation:Food Safety Regulation:

Comparing the EU and Japanese systemsComparing the EU and Japanese systems

Paul B Young, PhDPaul B Young, PhD

Waters CorporationWaters Corporation

[email protected][email protected]

©2007 Waters Corporation 2

About WatersAbout Waters

Waters is a technology-based company focused on separation science, mass spectrometry and informatics.

Waters creates business advantage for laboratory-dependent organizations, such as healthcare delivery, environmental management, food safety, and water quality worldwide.

Waters has driven scientific discovery and operational excellence with customers worldwide for nearly 50 years.

Waters prides itself in pushing the boundaries of scientific possibilities and is committed to providing our customers novel

tools that address the real needs that they face.

©2007 Waters Corporation 3

ContentsContents

Consumers are focused on food safetyFood safety scares have high profile in the mediaRapid growth in sales of premium priced organic produce

Regulatory food safety analysis serves 2 main purposes1. Protects consumer health2. Protects agricultural export markets

An effective programme must be comprehensiveRelying on 3rd country assurances alone is riskyRelying on testing of imports alone is expensive

An effective programme requires collaborationCollaboration between governmentsCollaboration between government, industry and technology leaders

©2007 Waters Corporation 4

Increasing demand for foodIncreasing demand for food

0

5

10

15

20

25

30

Incr

ease

d C

onsu

mpt

ion

(%)

Beef

Pork

Poultry Fish

Apples

GrapesTomatoes

Lettuce

Source: USDA ERS (http://www.ers.usda.gov/publications/FoodReview/May2002/frvol25i1a.pdf)

US Projected Market Growth 2000 - 2020USDA Predict that by 2020, US consumption of many food commodities will increase by more than 10% over 2000 rates

Horticultural product demand is expected increase by around 20%

©2007 Waters Corporation 5

Global trade in food increasingGlobal trade in food increasing

56.014

45.687

62.409

52.656

62.516

57.736

68.721

64.025

40

45

50

55

60

65

70

$ (b

illio

n)

2003 2004 2005 2006

US Agricultural Trade

Agricultural exports Agricultural imports

Many countries are actively pursuing the expansion of export markets. This is reflected in the declining US trade balance

US exports to “high income” markets are declining. Now shifting towards developing markets (China and Mexico currently account for >25% of exports)

©2007 Waters Corporation 6

Increased agricultural exports is Increased agricultural exports is goal in many countriesgoal in many countries

465856 657

1237

25141874

4279

6125 6225

4705

6933

14517

4902

7245

15341

0

2000

4000

6000

8000

10000

12000

14000

16000

X 10

000

Tons

1978 1990 2000 2003 2004

Increase in Outputs of Main Farm Products in China

Aquatic products Meat Fruit

The increase in production is mirrored in an increased volume of exports

This is a frequently stated goal of many countries (Thailand Department of Fisheries mission statement – “To increase aquaculture production by 5 % per year”)

©2007 Waters Corporation 7

Food concernsFood concerns

In a Japanese survey around 70 % of consumers rated food safety as the most important issue

By contrast, only 8 % thought price was the major concern

©2007 Waters Corporation 8

22 31 30 15

26 37 24 9

26 39 26 8

27 41 22 8

28 42 21 7

29 38 23 8

0% 20% 40% 60% 80% 100%

Mad cow disease (BSE)

Pollutants (mercury, dioxins)

Bacterial contamination (salmonella ineggs, listeria in cheese)

Antibiotic/hormone residues in meat

Pesticide residues in fruit/veg/cereal

New viruses (e.g. AI)

EU concerns about food contamination

very worriedfairly worriednot very worriednot worrieddon't know

Consumer concerns in EUConsumer concerns in EU

European Commission Special Eurobarometer 238

©2007 Waters Corporation 9

World Trade Organisation World Trade Organisation AgreementsAgreements

Article 20 of the General Agreement on Tariffs and Trade (GATT) allows governments to act on trade in order to protect human, animal or plant life or health, provided they do not discriminate or use this as disguised protectionism.

Sanitary and Phytosanitary Measures Agreement (SPS)allows countries to set their own standards. Regulations must be based on science, but “precautionary principle” may be applied.

The Technical Barriers to Trade Agreement (TBT) tries to ensure that regulations, standards, testing and certification procedures do not create unnecessary obstacles. It encourages countries to recognize each other’s procedures for assessing whether a product conforms.

©2007 Waters Corporation 10

Establishment of European Food Establishment of European Food Safety AuthoritySafety Authority

EFSA – Independent scientific point of reference for risk analysis

Ensures scientific basis for food law

Establishes the Rapid Alert System for Food and Feed (RASFF)

Requirement for traceability for all stages of production

©2007 Waters Corporation 11

EU Approach EU Approach –– Domestic ProduceDomestic Produce

Defines the sampling and testing frequencies for domestic producee.g. 0.4 % of all cattle slaughtered must be tested for the presence of veterinary drugs and other contaminants

Defines Maximum Residue Limits (MRLs; tolerances)Applies precautionary principle where safe level has not been established

©2007 Waters Corporation 12

Method used must be fit for purposeMethod used must be fit for purpose

EU Does not prescribe analytical techniquesAllowing labs to improve efficiency through the use of new technologies

Methods must be demonstrated to be fit for purposeValidation procedures are defined to demonstrate suitability

Methods must be capable of detection and confirmation at level of interest

Strict criteria must be applied to ensure unequivocal confirmation

Control laboratories must be accredited under ISO 17025

2002/657

©2007 Waters Corporation 13

EU Demands equivalent assurances EU Demands equivalent assurances from 3from 3rdrd countries wishing to exportcountries wishing to export

EU Maintains lists of establishments in each 3rd country which are approved to export a given commodity

Approval is subject to submission of acceptable control programmes

Programme implementation is verified by regular monitoring inspection visits (DG-SANCO Food and Veterinary Office)

©2007 Waters Corporation 14

Inspection reports publishedInspection reports published

Mission results and recommendations published

1. To further improve the design of the NRCP and its implementation, taking into account the deficiencies made in the report

5. To ensure the development and validation of analytical methods which are capable of meeting the community requirements……

©2007 Waters Corporation 15

RASFF notifications issued weeklyRASFF notifications issued weekly

Detailed statistical breakdown published annually

Import testing carried out for verification of control programmes

©2007 Waters Corporation 16

Consequences of violationConsequences of violation

If product has reach the market a recall is issued

Frequent violation may result in protective measures1. Increased testing frequency2. Complete ban on importation

Thai aquaculture and poultry products undergo mandatory testing at importers expense

Prohibition on import of Chinese aquaculture products

2002

©2007 Waters Corporation 17

Controls extended to food of nonControls extended to food of non--animal originanimal origin

Regulation 882/2004 extended the rules to cover additional foods

Cost recoveryAll costs resulting from the official controls at the designated points of introduction and entry should be borne by the feed and food business operator responsible for the consignment or its representative.

©2007 Waters Corporation 18

Japan Food Safety legislationJapan Food Safety legislation

Japan is one of the least self-sufficient developed countries in the world, importing more than 60 % of its food

In 2002, the domestic consumer organization identified that high concentrations of some agricultural chemicals were found in some imported crops

Many of these agricultural chemicals found in imported crops were unauthorized for use in Japan

There was therefore not an effective system to monitor and make decisions on the safety of this produce

©2007 Waters Corporation 19

Japanese responseJapanese response

Establishment of Food Safety Commission

Revision for food and food additive standards to create “Positive List System” of 799 substances which must be controlled in all imported foodstuffs

©2007 Waters Corporation 20

How do Japanese procedures differ How do Japanese procedures differ from Europefrom Europe

Regulations place onus on importer to ensure imported food is compliant

Japan does not demand equivalence

Compliance is ensured through very high level of import testing (laboratory tests > 10 % of imports)

For substances not permitted to be present in food at any concentration, MHLW have prescribed analytical methods for use in Japanese control labs

©2007 Waters Corporation 21

Consequences of violationConsequences of violation

Details of violations published quarterly

At first import, products must be subject to voluntary tests

Violations result in inspection orders – increased testing

Repeat violation may result in a ban on importation

In practice, importers demand test certificates from exporters

©2007 Waters Corporation 22

ConclusionsConclusions

Consumers are focused on food safetyFood safety scares have high profile in the mediaRapid growth in sales of premium priced organic produce

Regulatory food safety analysis serves 2 main purposes1. Protects consumer health2. Protects agricultural export markets

An effective programme must be comprehensiveRelying on 3rd country assurances alone is riskyRelying on testing of imports alone is expensive

An effective programme requires collaborationCollaboration between governmentsCollaboration between government, industry and technology leaders

©2007 Waters Corporation 23

Contact detailsContact details

Paul Young – [email protected]

Jeff Tarmy – [email protected]