Food safety

Better Training for Safer FoodInitiative

Steven Boven, Krzysztof Bednarczyk, Márton Lázár

IMPORT & TRANSIT CONTROLS

ON ANIMAL BY-PRODUCTS

Food safety

LEGISLATIVE

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HOW ARE IMPORT CONTROLS ORGANISED?= procedures of veterinary checks

• Directive 97/78/EC• Regulation (EC)136/2004• Regulation (EC)882/2004 (FEED)• Decision 2007/275/EC

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WHAT ARE THE IMPORT CONDITIONS?

• ABP Regulations (EC)1069/2009 & (EU)142/2011• TSE Regulation (EC) 999/2001

FRAMEWORK

Food safety

LEGISLATIVE

H

O

W

HOW ARE IMPORT CONTROLS ORGANISED?= procedures of veterinary checks

• Directive 97/78/EC• Regulation (EC) 136/2004• Regulation (EC) 882/2004 (FEED)• Decision 2007/275/EC

W

H

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WHAT ARE THE IMPORT CONDITIONS?

• ABP Regulations (EC)1069/2009 & EU)142/2011• TSE Regulation (EC) 999/2001

FRAMEWORK

To be replaced from 14/12/2019 by OCR (Regulation (EU) 2017/625) &

implementing regulations

Food safety

Directive 97/78/EC +Regulation (EC)136/2004

Each consignment is

notified before arrival

to the BIP by means of a

CVED in TRACES

HOW ORGANISED?

Food safety

Directive 97/78/EC + Regulation (EC)136/2004

Documentary check

Identity check

(Physical check)

in the BIP prior to customs clearance

HOW ORGANISED?

Food safetyFood safety

Directive 97/78/EC +Regulation (EC)136/2004

After veterinary checks:

Part II of CVED completed

CVED accompanies consignment to destination

HOW ORGANISED?

Food safety

Directive 97/78/EC, article 11 - TRANSIT

HOW ORGANISED?

3rd country

3rd countryEU

• Documentary + Identity check in entry BIPunless transhipped <7days/port, <12hours/airport

• Transit conditions = import conditions (Regulation (EU) 142/2011 – art 25 + annex XIV)

• Passage by road, rail, waterway: T1 customs procedure + CVED, sealed, within 30 days

• Entry BIP notifies exit BIP via Traces• Exit BIP informs entry BIP of the exit via Traces

within 30 days

Food safety

Which products should be subjected to veterinary checks?

= Annex I to Decision 2007/275/EC

HOW ORGANISED?

REMARK:Endpoint (art 3 R142/2011) is not valid at moment of import – only after compliant veterinary checks the endpoint is reached

Food safety

LEGISLATIVE

H

O

W

HOW ARE IMPORT CONTROLS ORGANISED?= procedures of veterinary checks

• Directive 97/78/EC• Regulation (EC)136/2004• Regulation (EC) 882/2004 (FEED)• Decision 2007/275/EC

W

H

A

T

WHAT ARE THE IMPORT CONDITIONS?

• ABP-regulations (EC)1069/2009 & (EU)142/2011• TSE regulation (EC)999/2001

FRAMEWORK

Food safety

• import conditions as stringent as & equivalent to EU conditions

• Art 33, 35 & 36 products – imported according to these articles

• Cat 3 ABP & derived products:

3rd country lists

establishment lists

health certificates

or national rules if not harmonised

• Cat 1 & 2 (other than art 33, 35, 36): import only if import rules in Reg (EU) no 142/2011 are fixed

• Exceptions:

o SRM – Reg (EC) no 999/2001

o ABP mixed with hazardous waste – Reg (EC) no 1013/2006

o Samples – rules fixed in Reg (EU) 142/2011

IMPORT CONDITIONS

Regulation (EC)1069/2009, art 41 = BASIC PRINCIPLES

= “harmonised” products

Food safetyFood safety

IMPORT CONDITIONS

Regulation (EU)142/2011, art 25

• Import prohibitions:

o unprocessed manure

o untreated feathers

o beeswax in honeycomb

• Possibilities to import certain treated wool, hair, fur without any animal health conditions

• Reference to import conditions of annex XIV

Food safety

Import conditions for most common ABP and derived products in a uniformly structured lay-out in 2 chapters:

• CHAPTER I: Category 3 material and derived products for uses in the feed chain, other than for petfood or feed to fur animals

• CHAPTER II: animal by-products and derived products for uses outside the feed chain for farmed animals

Regulation (EU)142/2011, Annex XIV

IMPORT CONDITIONS

Food safety

Remark:

• if import conditions are fixed in CHAPTER I for feed-grade category 3 commodities

• and no conditions are fixed for these commodities in CHAPTER II:

CHAPTER I conditions apply also to these commodities not intended for feed use

Regulation (EU)142/2011, Annex XIV

IMPORT CONDITIONS

Food safety

General requirement in section 1 of CHAPTER I & II:

• Consignments must come from an establishment or plant which is registered or approved by the competent authority of the third country, as applicable, and which is on the list of such establishments and plants referred to in Article 30.

• Lists to be found on http://ec.europa.eu/food/safety/animal-by-products/approved-establishments_en

• Determine correct section based on health certificateslinked to each section in technical specifications

Regulation (EU)142/2011, Annex XIV

IMPORT CONDITIONS

Food safety

Table 1 & 2 give specific conditions/product type:

Regulation (EU)142/2011, Annex XIV

IMPORT CONDITIONS

Product RawMaterial

CertificateSpecificconditions

ThirdCountries

Food safety

Reg (EU) 142/2011, Annex XIV

IMPORT CONDITIONS

Sampling PAP for analysis on Salmonella/Enterobactericeae

• Bulk: initial 6 consignments / 3rd country of origin + afterwards random sampling, unless non-compliance

• Packaged: random sampling

Food safety

Table 1 & 2 give specific conditions/product type:

Regulation (EU)142/2011, Annex XIV

IMPORT CONDITIONS

Product RawMaterial

CertificateSpecificconditions

ThirdCountries

Food safety

Regulation (EU)142/2011, Annex XIV

IMPORT CONDITIONS

ABP/derived products to be channelled to destination:• Certain untreated blood products• Bones and bone products, horns and horn products, hooves and

hoof products (not feed or OFSI)• Hooves and hoof products, horns and horn products for OFSI• Rendered fats (technical use) & fat derivatives • Photogelatine• ABP for use in feed for fur animals, for the manufacture of

petfood (other than raw petfood), for use as raw petfood and for the manufacture of derived products for uses outside the feed chain

• Trade samples

Food safety

Regulation (EU)142/2011, Annex XIV

IMPORT CONDITIONS

Cat 1, 2 and 3 possible for biodiesel production

GTH marking even for cat 3 rendered fats

Food safety

Table 1 & 2 give specific conditions/product type:

Regulation (EU) 142/2011, Annex XIV

IMPORT CONDITIONS

Product RawMaterial

CertificateSpecificconditions

ThirdCountries

Any third country listed

Food safety

Regulation (EU)142/2011, Annex XIV

IMPORT CONDITIONS

Product RawMaterial

CertificateSpecificconditions

ThirdCountries

third country listed + import fresh poultrymeat

authorised / includingrestrictions for freshmeat of ungulates

Food safety

Food safety

Shakespeak question

22

Which document, available in the establishment of destination, proofs that a consignment of PAP is imported correctly?

1. A health certificate of annex XV, chapter1 of Regulation (EU) 142/2011

2. A common veterinary entry document (CVED)

3. A commercial document established bythe BIP in TRACES

Food safety

• Intermediate products (annex XII)

• Category 1 hides & skins (illegal treatment), ruminant intestines, bones & bone products containing vertebral column/skull (article 26 +

annex XIV, chapter IV, section 1)

Not from TSE related animals

Not for feed, fertiliser, art 33-products

Labelling ‘Prohibited in food, feed, fertilisers, cosmetics, medicinal products and medical devices’

Health certificate according to national legislation

Direct transport to approved/registered plant

Specific products – Reg (EU) no 142/2011

IMPORT CONDITIONS

Food safety

• Materials for purposes other than feeding to farmed land animals from

Aquatic animals

Aquatic & terrestrial invertebrates

Products generated by those animals

Cat 3 material from Rodentia & Lagomorpha

e.g. fishing bait, mice for snakes

Health certificates according to national rules

(annex XIV, chapter IV, section 2)

• Samples (articles 27 & 28 + annex XIV, chapter III)

Research & diagnostic samples

Trade samples

Display items

Specific products – Reg (EU) no 142/2011

IMPORT CONDITIONS

Food safety

Regulation (EU)142/2011, Annex VIII chapter II:

• Category indicated + specific required wording as in annex VIII, chapter II or in health certificate

• Colour coding in case of transport to other member state when leaving BIP

Identification rules

IMPORT CONDITIONS

Category 1 Category 2 Category 3

Food safety

Specified Risk Material – article 8

“It shall not be imported into the Community”

Remark: 3rd countries with negligible BSE risk status do NOT have SRM, in contrast with EU member states (annex V, points 1&2 – definition SRM)

Regulation (EC) 999/2001 – TSE

IMPORT CONDITIONS

Food safety

• Specific health attestations (annex IX, chapter D) required for following ABP and derived products from bovine, ovine and caprine animal origin :

rendered fats (cat 2 and 3) for OF/SI

bones & bone products of cat 2 and cat 3

pet food / dog chews

blood products

PAP

gelatin/collagen not from hides & skins

other cat 3 materials/derived products, except hides & skins, gelatin/collagen from hides & skins, fat derivatives

Regulation (EC) 999/2001 – TSE

IMPORT CONDITIONS

Food safety

• These specific health attestations (annex IX, chapter D)

concern:

the BSE status of the country of origin (negligible risk), OR absence of SRM and absence of MSM from bones and killing method

if containing caprine/ovine milk or milk products + intended for feed, additional declarations for scrapie/TSE

these attestations are integrated in health

certificates of annex XV of Reg (EU)142/2011

Regulation (EC) 999/2001 – TSE

IMPORT CONDITIONS

Food safety

Feed Ban – requirement (annex IV, chapter III, section C):

+ PAP & blood products of non-ruminants & compound feed containing those PAP or BP

+ intended for feeding non-ruminant farmed animals:

analytical report for unauthorised constituents of animal origin according to annex VI of Regulation (EC)152/2009 presented for documentary check

Idem for milk replacers containing fish meal (annex

IV, chapter IV, section E)

Regulation (EC) 999/2001 – TSE

IMPORT CONDITIONS

Food safety

Shakespeak question

30

Should imported big bags of horsemeal, which are labeled as “for petfood manufacture only”, be analysed for unauthorised animal constituent?

1. No, because not intended for feedingnon-ruminant farmed animals

2. Yes, except if send directly to a pet food manufacturer

Food safety

Thank you for listening

Questions?

Food safety

Better Training for Safer Food

BTSF

JVL Consulting s.a.

Rue Matagne 15

B-5020 Vedrin

Belgium

Website: http://btsf.euroconsultants.be/

European CommissionConsumers, Health, Agriculture and Food Executive Agency

DRB A3/042L-2920 Luxembourg