Quality Management

Legislation and private requirements

SGC: Introducción

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Prepararation for present and Prepararation for present and future demandsfuture demands

Legal requirements

Commercial reasons

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Legal requirementsLegal requirements

EU General Food Law (GFL)

US BioTerrorism Act

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Legal requirementsLegal requirementsGeneral Food LawGeneral Food Law

EC/178/2002 GFL applicable since 1/1/05

Establishes the basic principle that the primary responsibility for ensuring compliance with food law, and in particular the safety of the food, rests with the food business.

SGC: Introducción

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GFL Article 18GFL Article 18Traceability =Traceability =

Traceability is defined as the ability to follow or reconstruct the logistic route of a product through all stages of production, processing and distribution.

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One step back

GFLGFL artart. . 18: traceability18: traceability

One step forward

Companies should at least be able to identify the immediate supplier of the product and the immediate subsequent recipient

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GFL art. 18: traceabilityGFL art. 18: traceability

Food business operators should have systems and procedures in place that:

allow for traceability information to be made available to the competent upon their request.

enables them to respond immediately or within a maximum of 4 hours to the competent authority about the origin and destination of a product.

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GFL art. 18: traceabilityGFL art. 18: traceabilityGFL does not specify what types of information should be kept. However, the registration of the following information is considered

necessary:

Information that shall be made available to the competent authorities in all cases:– Name, address of supplier, nature of products– Name, address of customer, nature of products– Date of transaction/delivery

Information which is highly recommended to be kept:– Volume or quantity– Batch or lot number, if any– More detailed description of the products (pre-packed or bulk, variety, raw or

processed).

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Third country complianceThird country compliance

GFL´s traceability provisions do not have an extra-territorial effect outside the EU.

It requires that food/feed imported in the Community complies with the relevant requirements of EU food law.

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Legal requirements:Legal requirements:BioTerrorism Act of the USBioTerrorism Act of the US

One step up one step down approach:

US based processors, packers or manufacturers must maintain records that identify immediate previous source of all food received as well ass the immediate subsequent recipient.

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Legal requirements:Legal requirements:BioTerrorism Act of the USBioTerrorism Act of the US

The reporting window is 24 hours. In the future, this could be reduced.

Lot numbers are not required if unavailable. This rule could be changed in the future to require lot numbers.

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Traceability compulsory?Traceability compulsory?

EU GFL and USA BioTerrrism act are NOT compulsory by law outside the EU and the USA.

Can you therefore waive the effort to comply with requirements?

NOLegislation may change

Private standards do copy requirementsCustomers constantly raise requirements

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Quality managementQuality managementCommercial reasonsCommercial reasons

Ensure fast and targeted survey to the origin of a default product and the reasons for the default;

Create a feed back loop to improve product quality, condition and delivery;

Improve internal quality management.

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Private Traceability StandardsPrivate Traceability Standards• Traceability is being demanded more

and more by traders, the sector and retail trading.

• The more obvious examples are the organic certifications, EurepGap and Utz Kapeh requiring documented traceability systems.

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Private Traceability StandardsPrivate Traceability Standards

• FLO proposes to adapt its standards to EurepGap and is asking 100% traceability by 2008. 2008: deadline for small producers to have a ICS for environmental issues according to the new standards.

• Starbucks Coffee Practices, even though it does not have an explicit traceability demand, asks for– a supply chain map and– 100% transparency on supply payment to

everyone along the chain