COFI:FT/VIII/2002/7 |
| COFI:FT/VIII/2002/7 |
Item 8 of the Provisional Agenda |
COMMITTEE ON FISHERIES |
SUB-COMMITTEE ON FISH TRADE |
Eighth Session |
Bremen, Germany, 12-16 February 2002 |
TRACEABILITY OF PRODUCTS FROM
|
TRACEABILITY IN EUROPEAN LEGISLATION
TRACEABILITY AND LABELLING OF FISHERY PRODUCTS
AND INTERNATIONAL TRADE
1. In the past decade, various food crises severely affected many countries, especially in Europe. Following the outbreak of Bovine Spongiform Encephalopathy (BSE) and the dioxin case, the concept of traceability in food products became an issue of primary concern among European policy makers and scientists. Traceability is defined by the International Organisation for Standardisation (ISO 8402:1994) as the "ability to trace the history, application or location of an entity by means of recorded identification." The enforcement of traceability implies the development of systems giving information on the entire life cycle of food products, "from the farm -or the sea- to the fork".
2. The concept of traceability differs from that of certification. Traceability is a mechanical process documenting all the stages of production and distribution that food products go through. Certification is a statement ensuring that certain specifications, for example harvesting, processing and/or handling, have been undertaken in compliance with environmental, social or food safety and quality standards. Therefore, the concepts of traceability and certification are by no means synonymous.
3. Research and practical experience on fish traceability systems showed some bottlenecks for:
4. The setting up of mechanisms to overcome these bottlenecks would allow full-chain traceability to ensure that all fishery products are labelled with precise indications on origin and on each processing stage they have been going through.
5. The Eupean Union (EU) is currently finalising the regulatory framework on labelling, food hygiene requirements and traceability. Article 4 of EU regulation 104/2000, entering into force on 1 January 2002, allows marketing of fishery products only if proper marking or labels indicate:
6. EU member states are obliged to set up and publish lists indicating the scientific and common names of the commercial fish species enclosed in Annexes I to IV of the regulation.
7. The European Commission in its regulation 2065/2001 set detailed provisions for the application of EU regulation 104/2000 as regards informing consumers about fisheries and aquaculture products. According to regulation 2065/2001, chapter III "Traceability and control", information on the species concerned must appear on the labelling or packaging of the products or on a commercial document (including the invoice) accompanying them (art. 8). Art. 9 requires States to establish arrangements for checking the application of article 8. Member States shall notify by 31 March 2002 at latest both new and existing arrangements.
8. The proposal of EU directive COM (2001) 433 is due to enter into force on 1 January 2004. It will amend EU directive 2000/13 on food labelling by removing the rule1 which exempts from labelling those compound ingredients constituting less than 25% of the final product. Instead, it will introduce mandatory labelling for all compound ingredients of foodstuffs, and in particular for all food known for potentially creating allergies, including seafood.
9. In July 2000 the European Commission made four proposals to repeal 17 food hygiene regulations, with a view to creating a single, transparent and effective food hygiene policy. The four proposals concern:
10. The four regulations, due to enter into force on 1 January 2004, are based on three principles: the coverage of all food at all levels, the primary responsibility of food producers and the traceability of all food and food ingredients. In particular, the new regulation on hygiene of food products -Document 500PC0438(01)- contains the following traceability provisions:
11. Several public and private actors from the EU and other European countries are currently developing projects aimed at achieving full chain traceability of fishery products.
12. The European Commission-funded Concerted Action QLK1-2000-00164 "Traceability of Fish Products" (TRACEFISH) gathers 24 companies and research institutes from all over Europe to find common views on data which should follow fishery products from harvesting to the consumer. TRACEFISH seeks to achieve an electronic system of traceability where commercial partners transmit information on the fish they handle to a database through a unique electronic identifier applied to each package of fish.
13. The European Commission Joint Research Centre (JRC) database "Genetics for Identification of Fish Origin", currently under development, will contain information on the genetic differentiation of stocks of commercially important fish species. One of the principal aims of the database is to provide control authorities with a tool to trace marketed fish back to the sea.
14. The British Sea Fish Industry Authority has been developing a traceability project targeting vessels landing on the Shetland Islands. These vessels are electronically connected to the markets ashore through a PC transmitting information on, inter alia, weight, area and date of capture. A Norwegian company has developed a traceability system built on DNA which can be used for marketing and breeding purposes, but also for tracing and diagnostics of infections, and for vaccines. Furthermore, the positive impact of food traceability on consumers led European fish processors, retailers and supermarkets to launch marketing strategies based on the traceability of their products.
15. With the EU implementing its legislation on labelling and traceability, third countries will have to enforce equivalent rules prior to exporting their products into the Union.
16. As from 1 January 2002, according to regulation 104/2000, third countries will be obliged to export into the EU only those fishery products which are included in EU listings. Such products will have to be labelled with clear indications on the commercial designation, production methods and catch area of the fish. A restrictive approach in listing might result in a major non-tariff trade barrier.
17. In view of the entry into force of the EU regulation on the hygiene of foodstuffs, the EU and some third European countries are already launching traceability projects, e.g. the above mentioned TRACEFISH. Non-European countries such as New Zealand are developing their own software-based seafood traceability systems. However, other countries might consider their already existing control procedures reliable enough to ensurecompliance of their products and processes with international and national legislation governing fisheries.. Moreover, some developing countries would not be able to afford sophisticated software or DNA-based traceability systems. Thus, implementation of the above regulation might result in a non-tariff barrier to trade. The impact of this barrier is likely to be amplified by the implementation of the new EU directive on mandatory labelling, and therefore traceability, of all compound ingredients in foodstuffs.
18. The Sub-Committee is requested to comment on the experience of single countries with traceability and other commercial labelling and the viability of this type of measure. Members are requested to discuss the potential impact of such measures on international trade in fishery products.