Technical and management conditions for an EU wide system of I&R for dogs Puppy Trade in Europe, Brussels, 26th of November 2013 Presented by Dr. med. vet. Sven Hüther Terminology, avoiding misunderstandings 1. Microchip = Silicon = Intelligence 2. Antenna = a) Ferrite core b) Air coil 3. Surrounding material: here BIOGLASS (class 8625) The antenna for ear tags is air coil, the surrounding material plastics. A transponder is a product, which is built by the 3 components microchip with antenna and surrounding material. 2 Actual situation EU legislation EC 998/2003 – passport regulation linked to transponder EC 576/2013, 577/2013 Conditions: Conform to ISO 11784 and ISO 11785 Much more important: conformity on ISO 24631-1 Facts: The risk of inappropriate, wrong, double or untraceable codes across the EC needs a structured monitoring For the political side the details for a well working regulation are very technical and usually it is intended to keep it very simple, but dealing with electronics means understanding it and that means also to look at details 3 Principle of ISO 11784 code structure 15 digits figure – guaranteed uniqueness 3 digits for country code according to ISO 3166 or for manufacturer code according to ICAR approval 12 digits animal or unique ID code Structure of the codification for ISO 11784 15 digits world wide unique Code 3 digits 12 digits MC or CC National ID or Animal ID POSITION 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 MC= manufacturer 9 X X 2 7 4 8 7 7 9 0 6 9 4 3 CC = ISO 3166 (HUN) 3 4 8 2 7 4 8 7 7 9 0 6 9 4 3 XX = from 86 to 34 or 00 total amount of codes = 2 38 Bit 986 to 934 are full manufacturer codes with 274.877.906.944 numbers 900 ist a shared manufacturer code with 1.000.000 numbers +3digit allocation code 9 0 0 Z 4Z Z 0 0 0 9 9 9 9 9 9 Actual use of 11784 in the EU Member States Different National regulations: Forbidden country code: UK and Belgium Country code + manufacturer code: CH, Slovenia, Serbia Country code + 1 digit + 2 digits (991-ICAR manufacturer code): NL, DK Country code structured but not monitored: Italy Country code use not structured at all: HU Full organised and monitored system: FR, JP No regulation: Germany, Poland, Spain, Greece, Portugal How can effective measures across borders be effective and how will control officers understand this system? 5 National regulation of the country code use (UK, BE, CH) England as well as Belgium: the use of the country code for pets is strictly forbidden by DEFRA, only transponders with manufacturer code (Department for Environment, Food and Rural Affairs) In Belgium the use of the country code is forbidden as well but with a lot of detailed regulation for the passport Switzerland, Slovakia, Slovenia: in the national code the first position is 0 and on the following 3 positions is the ICAR manufacturer code CC = ISO 3166 7 5 6 0 9 7 2 0 0 6 0 0 1 2 3 4 National regulation of the country code use (DK, NL, FR) Denmark and Netherlands (Wismans system): the first position in the national code is a 2* the figures 2 and 3 are the result of the subtract of 991 – the ICAR manufacturer code; for Planet ID i. E. 991 – 972 = 19, Planet ID Code for NL und DK = 219. CC = ISO 3166 5 2 8 2 1 9 0 0 0 0 0 1 2 3 4 2*= The responsibility for the uniqueness of the codes are given to the manufacturer In this structure it is not possible to built a country coded transponder with a shared manufacturer code France: NOR: AGRG0101247A, regulates, that all dogs, cats and ferrets born in France have to be identified by a 7 transponder with French country code. National regulation of the country code use (FR) Structure of the French country, species and homologation code POSITION 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Country code FRA 2 5 0 2 6 8 6 1 2 3 4 5 6 7 8 Country code FRA 2 5 0 2 5 8 6 1 2 3 4 5 6 7 8 Country code FRA 2 5 0 2 2 8 6 1 2 3 4 5 6 7 8 France: 250 (FR, FRA) The positions 4 and 5 of the total code, resp. 1 and 2 of the National Code represent the species, 26 = dogs, cats, ferrets; 25 = horses; 22 = wild animals. The positions 6 and 7, respective 3 and 4 stand for the French homologation code 8 Use of the country code (DE) Registered codes with country code in Germany Senseless Code 0 4 9 0 4 3 2 1 2 5 0 5 6 6 6 Pets with 2 7 6 0 9 8 1 1 2 3 4 5 6 7 8 manufacturer code 2 7 6 0 9 7 2 1 2 3 4 5 6 7 8 in the animal code 2 7 6 0 9 6 1 1 2 3 4 5 6 7 8 Problem with cattle 2 7 6 0 0 0 0 1 2 3 4 5 6 7 8 2 7 6 0 9 0 0 0 7 2 0 1 2 3 4 PID with BMVEL 2 7 6 1 0 0 0 1 2 3 4 5 6 7 8 Cattle ID 2 7 6 0 0 a c c o r d i n g Sheep ID 2 7 6 0 1 t o V V V O Horse ID 2 6 0 2 wrong Code 7 In Germany there is no regulation and no monitoring of the country code use for companion animals. The BMELV does not see a need for a regulation. The same status as Greece, Spain, Portugal, Poland and others. 9 Comparing 5 systems actually in use 11784 24631-1 manufacturer traceability double code guaranteed passport conform conform code possibility check uniqueness storing French System yes yes yes yes yes no no Wismans System yes yes yes yes yes/no no no Swiss System yes yes yes yes Yes/no no no Country Code without rules yes/no no yes/no no no no no only manufacturer code yes/no yes/no yes/no no no no no 11784 conform: is the code readable with an ISO 11785 reader? 24631-1 conform: is the transponder approved and the code conform? Manufacturer code: can the manufacturer be verified in the code? Traceability possibility: is it possible to trace the animal? Double code check: will double codes be verified in the system? Guaranteed uniqueness: is it required that the approved manufacturer is running a database to store chip UID and ISO 11784 code? Passport number storing: is the passport number registered together with the animal transponder number? 10 Summary of the implementation in the EC The identification code is based on ISO 11784. The EU directives leave any other regulation to the National Authorities. There is no common regulation for country or manufacturer code to be used. There is no mandatory registration. To establish traceability and traces, mandatory country code as well as mandatory registration are the essential basics. The regulations in the Member States have been put in place in a way that this is not understandable for the control officers. The newest organisational and technical changes have not been taken into consideration The process to get an understandable system is by far too slow Important decisions and measures have to be taken 11 Future law and regulation The actual regulation for the use of ISO 11784, the code structure, is not sufficient, more regulation is needed so that control officers will be able to take the right action. 1. Responsibilities on the political side on EC level: • EC develops guidelines and directives • EC gives clear instructions to the member States about the details how to use the system (nominating minimum conditions and education program for the members) 2. Responsibilities on the political side on National level • Responsible Ministry coordinates the code structure for the country • Responsible Ministry nominates the Competent Authority also for pets • The Competent Authority coordinates the use of the country code and the guarantee for traceability with the manufacturers • The Competent Authority allocates the manufacturer to be allowed to sell in the country including a contract with penalties and consequences for nonrespecting the rules 12 Needs for I & R including traceability 1. Mandatory use of country code according to ISO 3166 2. Mandatory unique passport (no second passport without official approval) 3. Mandatory registration of owner and pet including the passport in a National data-base 4. Mandatory, regular transfer of data from the National data base into a European centralised data base 5. Ban of reuse of the transponder and the passport 6. One Ministry on National level shall be responsible for the official identification scheme of all animal species 7. All Competent Authorities need the same education level, a special training to have the same Know-how 13 Definition of Traceability A lot of people speak about traceability, but do we all think the same? 1. Competent Authority for the passport as well as for the transponder manufacturer approval gets nominated by the Ministry 2. Competent Authority authorizes companies or organisations to produce the passport or transponders with their allocated code 3. Authorised company or organisation decides upon a passport manufacturer, for the transponders the approved manufacturer needs to follow the ISO and National rules 4. Approved manufacturers keep a record of all issued passport numbers and/or transponder numbers and keeps a record whom the passport and/or transponders have been handed over 5. Veterinary or allowed person who has received the passports keeps a record which passport number is linked to which animal, which means to the animal transponder 14 Thank you for your attention You are welcome to ask your questions Planet ID GmbH Dr. med vet. Sven Hüther President CEO Hauptstr.5-9 D - 45219 Essen Tel.- +49 (0) 2054 939 65 - 0 Fax.- +49 (0) 2054 939 65 -19 www.planet-id.com 15 16