The development and

implementation of

European regulations

for traceability

John Bostock

Institute of Aquaculture

University of Stirling, UK

Why regulate for traceability?

Traceability - “The ability to follow the

movement of a food through specified

stage(s) of production, processing and

distribution”

A series of major failures in food safety in the 1980s and 1990s was the

primary driver for the introduction of legislation on traceability

The BSE/nvCJD crisis in the UK

A series of crisis

struck the

European food

industry in the

1990s – the

worst being BSE

UK impacts and actions

• Cull of affected herds ordered – 1.3 million cattle slaughtered with compensation costs over GBP 2.7 billion

• Beef exports banned – loss of US$ 1 billion market

• Loss of market confidence - UK beef consumption fell by 30% and production by 40% with loss of 45,000 jobs

• New rules on acceptable feedstuffs• New rules on maximum age of cattle entering food chain • Banning use of “specified materials” – brain, spinal cord etc.• Introduction of traceability – animal passport system

http://news.bbc.co.uk/1/hi/world/europe/1143597.stm http://www.mad-cow.org/00/dec00_more.html

Sales of beef fell by

27% in the EU with

costs easily more

than Euro 3 billion.

Belgian dioxin & PCB crisis

http://www.iht.com/articles/1999/07/31/pork.2.t_1.php

Contamination

affected 10 feed

manufacterers;

505 poultry,

1625 pig and

411 cattle

farms, 2 million

poultry were

slaughtered and

many products

recalled

Cost of the crisis

• Cost to industry: US$ 1 billion

• Indirect costs: ~ US$ 3 billion

• Human costs: 40 –8000 additional cancer cases

Other dioxin scares followedhttp://www.makower.com/blogpix/cokebottle.jpg

E.g. milk due to

contaminated citrus

pellets, poultry and

mink due to

contaminated clay

used as anti-caking

agent in feed, but

most high profile was

Coca cola, which had

to recall 2.5 million

bottles of soft drink

There have been many other scares, such as with Sudan red in 2005 and the

less dangerous but still damaging discovery of unregulated horsemeat in beef

products in 2013, even though traceability was much better established by then

US public awareness materials

Fisheries and aquaculture products have also been

affected by contamination issues – e.g. heavy metals

such as mercury in some wild fish

Farmed salmon has also been affected by scares

about routine levels of PCBs and dioxins

There have also been concerns

over fish produced in Asia

Maintaining the trust of consumers is very important!

…and too many times the food industry has not proven sufficiently trustworthy

EU Policy response

A white Paper in 2000 set out a

framework for better controls and

assurance of food safety in the EU

including the establishment of a new

European Food Authority. And in 2002 Regulation EC/178/2002

(General Food Law) - was published

with Article 18 providing the basic

regulation on traceability

Guidelines for EU Food Policy and Regulations are on the Web at:

http://ec.europa.eu/food/safety/general_food_law/index_en.htm

Traceability is part of a wider package of regulations designed to ensure food

safety “From farm to fork” which includes requirements for HACCP

implementation and monitoring and control through competent authorities

Image Source: EC DG SANCO

The primary

responsibility for

ensuring food safety

rests with each

business involved in

the value chain

Each are expected to

act in the best

interests of protecting

the health and safety

of consumers and to

be ready to

cooperate fully with

government

authorities to achieve

that aim.

Regulations require chain

traceability (one up and one down)

Example for aquaculture producers: http://www.omafra.gov.on.ca/english/offs/facts/strat_appen15.gif

DEFINITION (Art. 3 EC/178/2002):

‘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’

“To this end, such operators

shall have in place systems and

procedures which allow for this

information to be made

available to the competent

authorities on demand.”

Supply chains for fish

Source: Marco Frederiksen, Danish Institute for Fisheries Research

Information to be kept by food

business operators

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

Records should normally be kept for 5 years, although exceptions exist for

short shelf-life items which is based on shelf-life + 6 months.

The EC Rapid Alert System for Food and Feed (RASFF)

rapidly disseminates information throughout Europe

Example – RASFF Alerts 2014

Fish – 53% heavy metals, 16% pathogens, 8% histamine, 4% veterinary

medicine residues

Crustaceans – 40% veterinary medicine residues

Bivalves – 56% pathogens, 35% biotoxins

Cephalopods – 100% heavy metals

Alert response

Fish

products

Crustacean

products

Bivalve

molluscs Cephalopods

Withdrawn from market 45 3 19 1

Informing authorities 15 0 2 1

Recall from customers 12 0 5 0

Informing recipients 10 0 2 0

Official detention 10 0 2 0

Destruction 6 1 1 0

Seizure 6 0 0 0

Detained by operator 5 0 0 0

Import not authorised 1 0 1 0

No action taken 1 0 1 0

Re-dispatch 1 0 0 0

TOTAL 118 5 34 2

Regulation EC/178/2002 also states the food products shall be

“adequately labelled or identified to facilitate its traceability” More

specific requirements are contained in other legislation:

Regulation 2065/2001 requires

recording of species name,

whether cultured or captured, area

of origin and whether or not the

fish have been previously frozen

(for communication to consumers)

Hygiene and GM rules add further items that

must be recorded

Regulation 852/2004 on the

hygiene of foodstuffs requires

monitoring of HACCP data and

use of medicines etc. which

must be made available to

competent authorities or

customers on demand.

Regulation (EC) 1830/2003 adds

further specific requirements for

the traceability of genetically

modified materials.

Subsequent consumer labelling

requirements • Food Information to

Consumers Regulation (EU)

No 1169/2011

– Clearer labelling for

consumers

– Information on allergens

– Information on added water &

added proteins

– Date of first freezing and

whether defrosted

– Information if product is

“formed fish”

Common Organisation of the Markets Regulation

(EU) No 1379/2013

• Requires labels for fish and shellfish that are whole,

gutted, minced, frozen, dried, salted or smoked to provide

the following information:

– The commercial designation of the species and its scientific name

– The production method

– The area where the product was caught or farmed

– The category of fishing gear used

– Whether the product has been defrosted

– The date of minimum durability, where appropriate

The problem of IUU fishing was addressed

with Council Regulation 1005/2008

• From January 2010, all fish materials

imported into the European Union (EU) have

to be accompanied by catch certificates.

The certificates have to be validated by the flag

State of the vessel that caught the fish.

• Complemented by Council Regulation

1006/2008 concerning authorisations for fishing

activities of Community fishing vessels outside

Community waters and the access of third

country vessels to Community waters,

Image source: http://www.celsias.co.nz/article/chinas-fisheries-must-adapt-meet-eu-regulations/

I – Illegal

U – Unreported

U - Unregulated

Implementation of traceability measures

• Council Regulation 1224/2009

establishing an updated Community

control system for ensuring

compliance with the rules of the

common fisheries policy

• Commission Implementing Regulation

404/2011 laying down detailed rules

for the implementation of Council

Regulation (EC) No 1224/2009

• Decision 623/2003 – TRACES

veterinary database for live animal

movements & byproducts

These regulations

set out in more

detail the measures

that need to be

taken including the

use of fishing boat

log books, the

definition of lots and

the use of barcodes

and other electronic

data recording

systems

http://ec.europa.eu/fisheries/cfp/control/index_en.htm

e.g. use of lot (or batch)

numbers• Lot number applied at first sale (at the

latest)

• Information on all lots origin – e.g.

vessels/processing/aquaculture

• Update information on splitting and merging

of lots during processing/distribution

• Lot information on the product by label or

packaging or document with lot id number

or code, barcode, RFID chip or similar

(based on international standards)

• Member states must help each other to

access lot information

Image from: http://www.quickembed.com/Tools/Shop/POS/201005/110.html

Batch sizes and coding systems• Large batches – Lower cost for record

keeping - high economic cost if recalled –data not so useful for management

• Small batches – Higher cost for record keeping – low economic cost if recalled –data more useful for management

• Largest batch size is usually the initial boat landing or aquaculture unit harvest unless these are subsequently aggregated during transport or processing

• Recording system needs to take account of splitting or joining batches for processing or distribution

• Transport containers (boxes, crates, pallets, vehicles) need to carry batch identification

• Full standardised coding system for managing traceability developed by GS1

no splitting or joining of the batch

joining of the batches

splitting of the batches

http://www.tracefood.org/http://www.gs1kr.org/ (or http://www.gs1.org/)

Although not strictly required by legislation, internal traceability is advisable

for minimizing losses in case any notifiable incidents occur and may be

required by certification schemes

Source: Frederiksen, Eurofish

Traceability drivers

Source: Rasmussen, 2012 (simplified from Olsen, 2009

The focus of this

talk has been on

food safety and

legislation as drivers

of traceability.

However, there are

other important

reasons why

traceability has

become essential in

the European

seafood market

chains as

summarised briefly

here

Reference Websites

• http://ec.europa.eu/food/safety/general_food_law/index_en.htm

• http://ec.europa.eu/fisheries/cfp/control/index_en.htm

• http://eur-lex.europa.eu

• http://www.seafish.org/industry-support/legislation/traceability-and-

labelling/fish-traceability-requirements

• http://ec.europa.eu/fisheries/cfp/illegal_fishing/info/index_en.htm

• http://www.tracefood.org

• https://www.gov.uk/government/publications/fishing-regulations-the-

blue-book

• http://www.gs1kr.org (or http://www.gs1.org/)

http://www.flickr.com/photo_zoom.gne?id=1809300553&size=l

Bibliography/References• EC 2009. Handbook on the practical application of Council Regulation (EC) No.

1005/2008 of 29 September 2008 establishing a Community system to prevent, deter

and eliminate illegal, unreported and unregulated fishing (The IUU Regulation)

http://ec.europa.eu/fisheries/cfp/illegal_fishing/info/handbook_original_en.pdf

• Eurofish/Sippo. A Guide to Traceability within the Fish Industry.

http://seafood.oregonstate.edu/.pdf%20Links/Guide%20to%20Traceability%20Within

%20the%20Fishery%20Industry.pdf

• Rasmussen, M-L.R. 2012. A study of traceability and quality assurance in fish supply

chains. PhD Thesis. DTU National Food Institute.

http://orbit.dtu.dk/ws/files/54035690/ph.d._afhandling_mariarandruprasmussen.pdf

• Olsen, P. (2009). Food traceability process mapping. Standard method for analyzing

material flow, information flow and information loss in food supply chains. In Donnelly,

K.A.- M. & Olsen, P. Harmonizing methods for food traceability process mapping and

cost/benefit calculations related to implementation of electronic traceability systems

(pp. 7-10). Workshop hosted by Nofima in association with the TRACE project 25-26

February 2009. Report 15/2009. Tromsø, Norway: Nofima.

• Seafish 2014. Consumer information under the EU Common Organisation of the

Markets Regulation.

http://www.seafish.org/media/Publications/CMO_Guide_Ver_2_17-10.pdf

• Schröder, U. 2007. Challenges in the Traceability of Seafood. J. Verbr. Lebensm. 3

(2008): 45 – 48. DOI 10.1007/s00003-007-0302-8

Thank You

John Bostock: j.c.bostock@stir.ac.uk

http://www.slideshare.net/jbostock/

http://rms.stir.ac.uk/converis-stirling/person/10729