marco traceability

7/27/2019 Marco Traceability

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EU traceability requirements

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

Eurofish International Organisation


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Basic traceability definition and traceability

demands defined in REGULATION (EC) No178/2002 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


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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


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Information to be kept by food business operators

Required to document:

Name, addresses of supplier and identification ofproducts supplied,

Name, address of direct recipient and identification ofproducts 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 lessthan 3 months records could be kept for the period of 6months after date of manufacturing or delivery, (ii) for

products with a best before date records could be keptfor the period of the shelf-life plus 6 months


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The traceability provisions do not have an extra-territorial effectoutside the EU. This requirement covers all stages of

production, processing and distribution in the EU, namely fromthe EU importer up to retail level, including supply to the finalconsumer

If exporters from 3rd countries are required to fulfill thisrequirement, such requests are part of contractualarrangements with the trading partners and not requirementsestablished by the Food law

A guidance document to 178/2002 is available on the websiteof DG Health and Consumer Protection:

www.europa.eu/comm\food\food\foodlaw\guidance\index_en.htm


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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.


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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


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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 toensure the traceability of each lot.


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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 offisheries and aquaculture products and to whom these

products have been supplied. This information shall be made

available to the competent authorities on demand.

Mi i l b lli d i f i i


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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


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(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) inaddition.


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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


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Black box (Internal) and external traceability in a company

But internal traceability is a very good idea

From Jan 2012 (404/2011) art 67


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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 d 2015


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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.

F EU f d i


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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?


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Trace (back)

Fishing

vessel Auction Wholesaler Processor Wholesaler Distributor

Source: Maria Randrup, DTU

Simulation: time to identify the source


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Simulation: time to identify the source

first step: Recall -Trace

60 min.10 tonnes (one days

harvest)

A fish farmTrout fillets in

tomato sauce

Finland

60 min.39 tonnes (one days catch)Five vessels from oneharbour

Frozen, breaded,haddock fillets

Iceland

100 min.600 tonnes (two months

catch)

One fishing vesselsFrozen haddock

fillets

Faroe Islands

60 min.One days catch from 20

small fishing vessels

20 small fishing

vessels

Fresh cod filletsDenmark

23 min.3 tonnes (one days catch)A small fishing vesselFresh pollack filletsNorway

Estimated timeBatch size - at last stepLast traceable stepProductCountry


Average 60min to identify the source


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Track (forward)

Fishing

vessel Auction Wholesaler

Wholesaler

Wholesaler

Processor

Processor

Processor

Processor

Processor

Wholesaler Distributor

Retailer

Retailer

Distributor

Distributor

Retailer

Retailer

To illustrate the problem with large batch sizes



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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 performanceInformation for chain management

Possibility to use the information for the consumer


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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


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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


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Future

Countries outside EU should start to prepare to be

able to provide information for traceabilitysystems in EU

The EU traceability regulation will be harder in thefuture and it can be used as a trade barrier

Look for possible economic benefits by utilising the

information (internal/external)


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Thank you for your attention

E-mail: [email protected]

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