Marco Traceability
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Transcript of 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
Source: Maria Randrup, DTU
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
Source: Maria Randrup, DTU
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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]