EU requirements concerning traceability of Fishery products

Traceability and Labelling of
Fishery products in the EU
Gerard Roessink
Food and Consumer Product
Safety Authority
The Netherlands
Traceability what is it
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.
Traceability – the requirements
and their understanding
Food Law – Regulation 178/2002
article 3 point 15 and article 18
Guidance on Implementation of art.
11,12, 16, 17, 18, 19, 20 in the
Food law (20. December 2004)
Trace ability
When something has gone wrong
we need to find who is responsible
To avoid the same mistake will be
made again
Product liability, histamine example
Trace ability is it new?
Should be a part of the food safety
Together with HACCP
Thinking ahead which problems
might occur and have a solution
ready before it happens
New interest in trace ability
After crisis in the food industry
Mad cow disease (BSE) 1996 in UK
Dioxin contamination in Belgium
Three basic principles :
1. Safe food from
Farm to fork – from Water to mouth
2. Producer is responsible
3. Supervision CA
through Trace ability HACCP
Apply to
All stages of production, processing
and distribution
Food, Feed, food producing animals,
and any other substances incorporated
in the food
Trace ability
Origin of food stuffs
Processing history
Distribution and location after
Storage circumstances
Food and Feed Business operators shall have
systems and procedures in place which allow
them to identify
immediate suppliers of substances to be
incorporated in a specific product
buyers related to a specific product.
Such information shall be made available to
competent authority at demand
This will often be required as part of
commercial contractual arrangements
Specific requirements which involves
traceability still apply, eg.
primary producers control and record keeping in
regard to feed, veterinary medicines and diseases still
apply (Reg. 852, Annex1): certificate of origin for
bivalves (Reg. 853, Annex x)
The application of identification marks (Reg. 853,
Annex I)
Internal Traceability ?
Food Law – article 14 part 6
If a part of a batch is considered unsafe
– the whole batch will be considered
Unless a detailed assessment show evidence that
this is not the case
Suspected unsafe: Withdrawal of a product, even if
in conformity, is possible
Internal Traceability ?
Food Law – article 14 part 6
If a part of a batch is considered unsafe
– the whole batch will be considered
Unless a detailed assessment show evidence that
this is not the case
Suspected unsafe: Withdrawal of a product, even if
in conformity, is possible
Health or Identification Marks
853/2004 Art. 5 and 6 and Annex 2)
Other Labeling
Directive 104/2000 on common organisation
of the Market
Article 4 on consumer information (specifically for
fishery products)
Directive 2000/13 on labelling, presentation
and advertising of foodstuffs
Specific requirements for bivalves
853 ch. VII section VII
Food Buisness Operators
Apply Identification Mark on all
products placed on the market –
also imported products
Health and Identification Marks
shall be applied only to products
produced in approved or registred
Traceability and Import to EU
The Scope of article 18
of Food Law (or Reg. 178/2002)
Only intra-territorial effect, i.e.
the article apply only from importer up to
retail level in EU.
the importer in EU must be able to identify
only the exporter in the 3. country
the importer do not need to require
tracebility beyond the exporter in the 3.
Identification Marks
Shall be placed on the product before it
leaves the company
Shall include information about country
in which the establishment is located
and approval number
If re-packing and re-processing takes
places the Health Mark shall be linked to
the operation where this takes place.
Commission Regulation 104/2000
Labelling requirements:
designation of species
physical appearence or specific treatment
fresh or frozen
Commission Regulations
2065/2001 and 104/2000
1. the commercial designation of species
list of local names
Examples of member states lists
Art. 4 and Regulation 104/2000 Annex I-IV
2. production method
wild catch
fresh water / sea
aquaculture fresh water / sea
catch area or country of production
(EG) 2065/2001
Catch areas:
wild catch at sea:
FAO areas
wild catch in fresh water
name country
aquaculture products:
name country end phase
Market stall
Other labelling requirements
General requirements for labelling,
presentation and advertising
(Directive 2000/13)
Applies to all products to be
delivered to the ultimate consumer
(retail packs and catering)
Always compulsary (article 3)
Name under which the product is sold
List of ingredients
The quantity of certain ingredients or “categories of
ingredients” (= also additives)
The net quantity
Minimum durability or “used by” date
Special storage conditions or conditions of use
Name or Business name and adress of manufacturer,
packager or seller established in EU
Particulars of the place of origin if lack of such may mislead
to consumer
Instructions for use, if otherwise impossible to use the
product appropriately.
The label says
Some requirements of specific
relevance to fishery products from
3. countries (article 5.3)
Specific information about the
treatment (frozen, smoked, dried…)
Information about ionising radiation if
such is used (in relevant member
state language)
Each link in the
chain from water
to mouth must be
able to know
where the fish
comes from and
where the fish will
Can be done with
But simple
are OK
What is a simple system
Paper record; paper trail
Could be the invoice
Health check document addition
Thank you for your attention