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Marco Traceability

EU regulations require traceability of food products at all stages of production, processing, and distribution. Traceability involves documenting information such as supplier and recipient names and addresses, transaction dates, and product volumes. Food businesses must keep these records for 5 years. Recent regulations aim to improve traceability and transparency for fishery and aquaculture products specifically. They require unique lot numbers and minimum labeling of product origin, catch date, species, and quantities. While internal traceability is not mandated, it can help identify product sources quickly in the event of a recall. On average, the source of a product can be identified within 60 minutes using traceability systems.

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69 views24 pages

Marco Traceability

EU regulations require traceability of food products at all stages of production, processing, and distribution. Traceability involves documenting information such as supplier and recipient names and addresses, transaction dates, and product volumes. Food businesses must keep these records for 5 years. Recent regulations aim to improve traceability and transparency for fishery and aquaculture products specifically. They require unique lot numbers and minimum labeling of product origin, catch date, species, and quantities. While internal traceability is not mandated, it can help identify product sources quickly in the event of a recall. On average, the source of a product can be identified within 60 minutes using traceability systems.

Uploaded by

Bhatara Ayi Meata
Copyright
© Attribution Non-Commercial (BY-NC)
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
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EU traceability requirements

Marco Thorup Frederiksen M.Sc., Ph.D. Senior Project Manager

Eurofish International Organisation

Basic traceability definition and traceability demands defined in REGULATION (EC) No 178/2002 of 28 January 2002 General principles and requirements of food law, establishing the European Food Safety Authority and laying down procedures in matters of food safety

Regulation (EC) No 178/2002 Article 3: 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

Information to be kept by food business operators Required to document: Name, addresses of supplier and identification of products supplied, Name, address of direct recipient and identification of products delivered, Date and, where necessary, time of transaction/delivery, Volume, where appropriate, or quantity General rule for keeping records is 5 year period, however, (i) for products which have a use by date less than 3 months records could be kept for the period of 6 months after date of manufacturing or delivery, (ii) for products with a best before date records could be kept for the period of the shelf-life plus 6 months

The traceability provisions do not have an extra-territorial effect outside the EU. This requirement covers all stages of production, processing and distribution in the EU, namely from the EU importer up to retail level, including supply to the final consumer If exporters from 3rd countries are required to fulfill this requirement, such requests are part of contractual arrangements with the trading partners and not requirements established by the Food law A guidance document to 178/2002 is available on the website of DG Health and Consumer Protection: www.europa.eu/comm\food\food\foodlaw\guidance\index_en.htm

Resent rules for traceability and information for the consumers to be implemented COUNCIL REGULATION (EC) No 1224/2009 of 20 November 2009. Establishing a Community control system for ensuring compliance with the rules of the common fisheries policy. COMMISSION IMPLEMENTING REGULATION (EU) No 404/2011 of 8 April 2011. Laying down detailed rules for the implementation of Council Regulation (EC) No 1224/2009 establishing a Community control system.

Purpose of the most recent EU traceability regulation Document the origin of products Transparency in the chain from fishing vessel / farm to the end-consumer Counteract trade of illegal fish

For Fishery and Aquaculture products (1224) (Article 58)

In force since Jan 2010


1. All lots shall be traceable at all stages of production, processing and distribution, from catching or harvesting to retail stage.

2. Products placed on the market or likely to be placed on the market in the Community shall be adequately labelled to ensure the traceability of each lot.

3. Lots may be merged or split after first sale only if it is possible to trace them back to catching or harvesting stage.

4. Operators must have systems and procedures to identify any operator from whom they have been supplied with lots of fisheries and aquaculture products and to whom these products have been supplied. This information shall be made available to the competent authorities on demand.

Minimum labelling and information requirements (1224) (Article 58) cont.

(a) identification number of each lot (b) external identification number and name of the fishing vessel or the name of the aquaculture production unit (c) FAO alpha-3 code of each species (d) date of catch or the date of production (e) quantities of each species - net weight (kg) or number of individuals (f) name and address of the suppliers

(g) Information to consumers: (Article 8 in Regulation (EC) No 2065/2001) the commercial designation the scientific name the relevant geographical area (FAO sub area) the production method (caught at sea, freshwater, farmed) (h) whether the fisheries products have been previously frozen or not. Fish exporters into the EU market providing a EU catch certificate (Council regulation 1005/2008) are only required to provide the information from point g) and h) in addition.

For EU food companies

Traceability demands covers all EU food companies Information one step up, one step down in the chain Food companies needs to have the neccesary procedures and documentation No demand for internal traceability = black box

Black box (Internal) and external traceability in a company

But internal traceability is a very good idea

From Jan 2012 (404/2011) art 67 Chapter I


Information on lots: Lot number applied at first sale (at the latest) Update info on splitting and merging of lots Information on all lots origin (vessels/proc/aqua) Still no info about end consumers Lot information on the product by label or packaging or document with lot id number or code, barcode, elect. chip or alike Member states must help each other to access lot info Lots can contains several days of catch

2013 and 2015


(404/2011) article 66 point 6 and 7 Jan 2013: EU fisheries subject to a multiannual plan: Demand for unique lot number of fish batches by a identification tool for instance barcodes, microchip or similar methods. Jan 2015: Same for all fish/aquaculture products.

For EU food companies


Procedures and documentation are needed to carry out withdrawals. How long time does it take to carry out a withdrawal in practice?

Trace (back)

Fishing vessel Auction Wholesaler Processor Wholesaler Distributor

Source: Maria Randrup, DTU

Simulation: time to identify the source first step: Recall -Trace


Country Norway Denmark Faroe Islands Product Fresh pollack fillets Fresh cod fillets Frozen haddock fillets Frozen, breaded, haddock fillets Trout fillets in tomato sauce Last traceable step A small fishing vessel 20 small fishing vessels One fishing vessels Batch size - at last step 3 tonnes (one days catch) One days catch from 20 small fishing vessels 600 tonnes (two months catch) 39 tonnes (one days catch) 10 tonnes (one days harvest) Estimated time 23 min. 60 min. 100 min.

Iceland Finland

Five vessels from one harbour A fish farm

60 min. 60 min.

Source: Maria Randrup, DTU

Average 60min to identify the source

Track (forward)
Retailer Processor Processor Retailer Wholesaler Distributor

Fishing vessel Auction Wholesaler Processor Wholesaler Distributor

Wholesaler

Processor

Distributor Retailer

Processor Retailer

Source: Maria Randrup, DTU

To illustrate the problem with large batch sizes

Large batches: Low costs high economic loss if recalled Information maybe not useful

Small batches: Higher costs little economic loss if recalled Information to optimise internal performance Information for chain management Possibility to use the information for the consumer

How long time does traceability take? Traceability using barcodes -17 seconds per fish crate (35kg) per step -time can be neglected -investments are high Manual traceability?

Near future
Electronic traceability is implemented today RFID (Radio frequency identification) tags are now used in crates There are still stability problems Readability must be very close to 100% to be effective Several traceability systems are available today to handle the information in the whole chain

Future
Countries outside EU should start to prepare to be able to provide information for traceability systems in EU The EU traceability regulation will be harder in the future and it can be used as a trade barrier Look for possible economic benefits by utilising the information (internal/external)

Thank you for your attention

E-mail: [email protected]

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