freshfel –areflh food safety wg - 13 september 2007 freshfel-areflh food safety and logistics wg

Freshfel –Areflh Food Safety WG - 13 September 2007

Freshfel-Areflh Food Safety And Logistics WG


Opening remarks

• Welcome from – Areflh – Freshfel – Supplier Forum

• Roll of call of delegates

• Background information to the meeting

• Approval of the Agenda


AGENDA

Morning Session (FRESHFEL-AREFLH)• Opening remarks• Regulatory developments

– Implementation Regulation 396/2005– Directive 91/414: revision process and registration of AS– Draft Regulation on sustainable use– EP and Council Regulation on food additives– Implementation of Reg 178/2002 and 882/2004

• Non regulatory and supply chain developments– Discounters requirements ( non regulatory mrl, max nb of AS,..)– Relationship with NGO ( Greenpeace)– Report and discussion on the item on the agenda of the CPWG of

GlobalGAP ( formerly EurepGAP)– Matters arising from the JFCRT ( communications,..)

• Other issues– ICM– Preparation of the pm meeting with FEFCO on packaging

Afternoon session (with FEFCO)• Food Miles• Hygiene and food safety• Wrap up and conclusions


Freshfel-Areflh Regulatory Developments


Regulatory Developments Implementation Reg 396/2005

• Background to Regulation 396/2005 on MRL on food– Timing

• Adopted but not yet implemented• Will apply 6 months after adoption by COM of annex I, II, III and

IV• Application date foreseen – mid 2008 –difficulties linked to

changing product grouping between annexes– Transparency

• In future, comprehensive list of MRL ( directly applicable) and if not explicitly mentioned , default residue at 0.01 mg/kg

• Data base will be available• Name and shame principle to be applied• Compulsory publication of results

– Consequence of delay• Until then, existing EU mrl if available and national MRL apply

=> on-going distortion of single market principle• Risk of proliferation of non regulatory level which will become

the norm , de facto devaluating the benefit of the harmonisation



Annex I List of commodities - DONE

Annex II EU MRLs

Annex III Temporary MRLs

Annex IV List of active substances for which no MRLs are required

Annex V Substances for which a default MRL applies

Annex VI Processing factors

Annex VII Fumigants

Annexes in Bold: Conditions for Applicability of the Regulation



List with highest MRL – comparison by MS



1 st draft annex III – sent to WTO



• Discussion – Actions to be taken regarding MRL Harmonisation– Importance to stick Timetable– Fair mrl– TMR based on national MRL valid up to 2005– Inclusion of MRL at 0.01 for comprehensive views– Transparency to avoid undesirable effects of unexpected change– MRL reduction v csq of withdrawn AS authorisation


Regulatory Developments Revision AS and Reform Directive 91/414

• Reform Directive 91/414 - COM(2006) 388 final – Main points/concerns related to the reform

• Zonal authorisation • Comparative Assessment & substitution ( csq on IPM and

resistance management)• Cut off criteria ( out without impact assessment) • Data protection/minor use• Information to neighbours• IPM v. favour non-chemical methods • Illegal imports

– Regulation codecision EP-Council • Vote by Committee Envi at EP- 1st reading plenary Oct 2007• Council Common Position June 2008• Publication 2009 • Entry into force Q1 2011


Regulatory Developments Revision AS and Reform Directive 91/414

• Revision list of active substances

– Review of ca 1120 AS– Proposed fast track procedure for list 3b and 4 => lack of

motivation and increased non inclusion?– What action in case of non registration

• paraquat• carbaryl• 1-3 dichloropropene • metobromuron


Regulatory Developments AS and Directive 91/414

3295941561079Total

-51769127New

200813419103254

20087403b

200863252

0389

3a

9/20077113281482

12/200603159901

DeadlinePendingOUTINNo. ASsList

3295941561079Total

-51769127New

200813419103254

20087403b

200863252

0389

3a

9/20077113281482

12/200603159901

DeadlinePendingOUTINNo. ASsList



Discussion –Actions to be taken regarding

• Revision process 91/414• Re-registration process AS and non inclusion in Annex I


Regulatory Developments Draft Regulation on sustainable use

Draft Regulation on sustainable use

Key points/concerns• Setting reduction targets ( 25% - 5 years ; 50%- 10 years)• Tax on PPP• Protection of special public areas• Informing neighbours on spraying• Aerial spray• Buffer zone water• IPM annex on non chemical methods

Agenda• EP plenary October• Council WG 20 September• Adopted under Portuguese presidency?


Regulatory Developments Draft Regulation on sustainable use

Draft Regulation on sustainable use – Discussion


Regulatory Developments EP AND Council Regulation on Food Additives

EP and Council Regulation on Food Additives• Current rules on labelling

– No labelling of pesticides– General rules of food additives labelling but derogation for fresh

produce– Exception for citrus fruit for post harvest treatment – quality

standards• Art 2 §2 draft regulation – EP Committee proposals to include post

harvest applicants used as conserving agents on fruit and vegetables• New compromise Commission –Council –rationale to be found out• Position paper


Regulatory Developments EP AND Council Regulation on Food Additives

Discussion


Regulatory Developments Implementation Reg 178/2002 and 882/2004

• European Regulation on General Food Law and on Official controls• Practical experience show discrepancies among members states in the

implementation of the legislation • Discrepancies on

– What and when to report– What kind of record keeping– What obligations regarding laboratory testings ( frequency,

certification, equipment, location of lab, scope of the analysis,..)– When to recall– What kind of conformity measures– What sanctions in case of exceedence– When are result of official testing made available– Which ARFD method used– What monitoring plan is imposed by MS

• Need of further actions?


Regulatory Developments Implementation Reg 178/2002 and 882/2004

• Round table on official control and General Food Law Implementation• Recent development

– Certificazione Nella Osta–

• Discussion and further actions


Freshfel-AreflhNon Regulatory Developments


Non Regulatory DevelopmentsDiscounters requirements

• On-going pressure from discounters and more relevant development from Lidl– Producer to be EurepGAP certified and indication of the certificate

number– 1/3 of legal German MRL– Max 3-4 As

• UK development on prescribed list of pesticides • Discounters requirements causal relationship with NGO actions



• CSO letter to Bellafrut• Discussion and comment action


Non Regulatory DevelopmentsRelationship with NGO

Report of the Freshfel Board meeting with Greenpeace• Greenpeace perspective

– Germany is the cheapest EU fruit market –concerns of low prices for Greenpeace of food safety and quality => producing quality has a cost and require a fair price

– Greenpeace targeted retailers with first supermarket ranking in 2005 and was back with several report on illegal uses, report on acute toxicity, guide how to buy without pesticides, multiple residues

– Greenpeace plan to internationalized campaign– Greenpeace main concerns in f&v

• Pesticides– Mrl exceedences ( 2% acceptable?)– Arfd exceedences– Pesticides toxicity– Increasing multiples residues– Illegal pesticides– Unsafe limits

• Destroyed landscapes• Precarious situation of farm workers• Illegal waste disposal


Non Regulatory DevelopmentsRelationship with NGO

Report of the Freshfel Board meeting with Greenpeace• Freshfel position

– Downward pressure on consumption and erosion of efforts to counter obesity

– Consequence of non-regulatory limits• De facto privatization food policy• Confusion for producers and traders• Undermining confidence in regulatory process• Confusion among consumers• Reduction consumer choice• Potential problems for small scale growers and developing

countries• Follow up action

– Political and technical follow up– Identified list of mrl of concenrs – Action of communication on joint interest namely increased

consumption of safe f&v and speed up process for mrl– Early warning scheme



*Source: Eurobarometer ‘Risk issues’ February 2006

Who do you trust in regard to communication?


Non Regulatory DevelopmentsGlobalGAP CPWG

• Agenda of the CPWG of EurepGAP/GlobalGAP– Non compliance

• Mrl exceedence• Unauthorised use• COP/COD• Illegal use/counterfeited products

– Confidence• Ever decreasing analytical level• NGO communication• Non regulatory mrl• Inconsistencies in monitoring • Perceived lack of support

– Revision process• Harmonisation MRL• Withdrawal active substances• Reduction MRL• Transitional periods• Reporting limits


Non Regulatory DevelopmentsMatters arising from the JFCRTP

• Sustainable use of PPP– Association of Freshfel to ECPA Parliamentary campaign

• Authorisation of Active Substances

• Maximum residues Limits

• Common Communication Strategy – Annual report Commission– Webpage JFRTP– Key statement paper for member use


Other issuesICM

Presentation by Areflh


Other issuesPreparation Meeting with FEFCO

• S3 corrugated packaging initiative (Safe anf hygienic, Sustainable and environmental friendly, Supply chain savings )

• Benefit of using corrugated packaging ( environment, costs, stackability, footprint, hygiene,)

• Check perception of f&v sector vis-à-vis packaging ( major constraints , major assets,…eg regarding transport, hygiene, food safety, standardisation, traceability, waste control, water usage, image&marketing, cross perception


Closing

freshfel –areflh food safety wg - 13 september 2007 freshfel-areflh food safety and logistics wg

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