2016 EU-Taiwan International Food Trade Seminar: For Safer and Better Food
Taipei, 9 March
Note: This is an abridged version. To read the full report, please click HERE.
The full-day seminar was organized by the European Economic and Trade Office (EETO), under the framework of the European Business and Regulatory Cooperation Programme (EBRC) in conjunction with several Taiwan government ministries and related agencies. The seminar brought together around 200 government officials and experts from the EU and Taiwan to share experience on international food trade issues. A keynote speech was presented on the importance of international sanitary and phytosanitary (SPS) trade rules after which experts from the EU and Taiwan gave presentations in four sessions on the following subjects: 1) The importance of audits in the food sector; 2) Regionalisation as an efficient tool of disease control; 3) Border and behind-the-border measures ensuring food safety and 4) Better food – modern organic product regulation. One Q&A session was held after the second session and a final panel discussion featured speakers from all of the sessions. In conjunction with the seminar, high quality food products from Taiwan and a number of the EU countries were on display outside the seminar venue. Participants were able to not only sample the products on display but also gain a greater understanding of the items, which included wine, jam, organic and other agricultural products.
Panel session moderator
In the EU, food safety is essential for the functioning of the internal market and there is no room for the compromise of safety. This requires a high level of protection and solid controls at all levels of the food chain, from farm to the fork. Like in Taiwan, consumer safety groups in the EU monitor regulators and demand high standards.
There is significant and rising bilateral trade in food products between the EU and Taiwan, which means that it is unavoidable that at certain times irritants occur. Ms Marojenko said that the two sides face similar problems and must constantly work together to keep these irritants to the minimum and eliminate them when they are without justification. Open exchanges with stakeholders, such as this seminar, contribute to a better mutual understanding and create an environment conducive to addressing irritants. She concluded by saying that she hoped that the discussions at the seminar would provide the necessary input to facilitate working out mutually-acceptable solutions, in line with the principles of the WTO and lead to concrete results on outstanding issues.
In his remarks Mr Francis Liang said that food safety is something we all deserve and therefore need to ensure the highest safety standards. He noted that the Taiwan government has developed a comprehensive set of measures to ensure healthy food and is committed to ensuring that food is of a high quality and, above all, safe. He expressed the view that the seminar is a valuable platform to share information. He pointed out that TAITRA organizes overseas delegations to promote Taiwan’s food products and two international trade shows in Taipei and Kaohsiung which attract overseas buyers. These, he said show that Taiwan offers good products and business opportunities. He also announced that this year TAITRA will send a delegation to showcase Taiwan’s food products at the food show to be held in Paris in October.
In her remarks Ms Chiang Su-San welcomed experts from DG Trade and Europe to share valuable knowledge and experience with government officials and industry players in Taiwan. She noted that EU exports to Taiwan continue to grow, citing a seven-fold increase in pork imports to Taiwan from certain European countries as well as large increases in imports of Italian kiwis, premium wines and other items from the EU in recent years. This, she said, indicated a high level of confidence in the safety and quality of European food products. Growing EU-Taiwan food trade means that more attention is being focused on sanitary and phytosanitary (SPS) issues. She noted that exchanges are frequent between EU and Taiwan authorities, in addition to annual consultations between the two sides in the SPS Working Group and that, through regular meetings, she expects to make further progress in resolving disputes, strengthening the basis of mutual trust and improving consumer confidence.
Topic: The importance of international SPS trade rules
The legal framework for organizing trade is really important. There are well established international rules that allow safe trade. Maintaining consumer confidence requires robust and transparent SPS management. Authorities need to ensure that they focus on the right priorities and devote time and energy to the right issues. Authorities need to be smart in their use of limited resources and make the most of the tools available to them. Close international cooperation between competent authorities and industry players creates a win-win of greater safety, greater trust, more choice and safer products.
A look at EU-Taiwan trade figures shows rising bilateral trade in all categories (imports and exports) over the past four years. While there is an overall trade surplus for Taiwan, in the category of agri-food, there is a small surplus for the EU.
What is remarkable is that the EU has become the largest exporter of agricultural products in 2015. Weigl attributes this to the EU’s reputation for having a safe and wide variety of food and because it has become competitive as a food producer after years of domestic reforms. This is good news for consumers everywhere because consumer confidence is the central element of success in the food trade.
The only way to provide reassurance of food safety is to provide full transparency. This includes transparency between importers, exporters, regulators and consumers.
The EU’s trade policy paper, “Trade for All – Towards a more responsible trade and investment policy” was released on 14 October 2015 and outlines the EU’s new trade and investment strategy. According to the paper, trade must be based on European values. Since safety is one of those values, nothing should undermine this.
Modern audits are all about being smart and smart audits help us to get food safety right. Making systems work to ensure the right outcomes serves the interests of regulators, food business operators (FBOs) and consumers.
The EU system delivers a high level of food safety. There is only one food safety system in the EU even though there are 28 member states. The food safety system is the EU’s most integrated system because it serves the interests of all member states.
The single market is a source of competitiveness which only works if there is confidence across the EU. Peer pressure inside the EU also helps to make sure the system works. Transparency is crucial which is why audited reports are published and anyone can get instant access to information about events such as disease outbreaks. The system also works in favour of trading partners because it acts as a safety guarantee.
The EU’s SPS framework is unique and harmonized across the EU. There is a national layer of control and an EU layer of control under the European Commission. Every Member State has its own control system, which includes working with third party agencies. The Directorate-General of Health and Food Safety (DG SANTE) provides a second layer of controls, which is free of charge and open for all to use (including consumers and trading partners).
Europeans have learnt the importance of transparency although providing the appropriate information is a challenge. There are many tools in the SPS toolbox: The WTO’s SPS Agreement is based on risk assessments. Risk assessments conducted by any parties anywhere can be used. Many international standards have been developed. Using international standard helps to do things fast. Moreover, there are clear trade rules to allow for safe trade and avoid trade irritants (red tape and bureaucracy ties up real resources which could be better used to manage actual risks).
There is an international standard for audits (CAC/GL 26-1997). Audits can be used (although not necessarily) as part of an assessment for import and export accreditation/certification. Both the EU and Taiwan use this instrument. It can serve as a core bridge to achieve cooperation and reach a high level of safety.
The EU has experience in managing outbreaks like African swine fever, which has been kept under control because there are emergency plans in place to deal with outbreaks. It is essential to know how to respond to these types of outbreaks because it is inevitable that they will occur from time to time.
Traceability is an essential tool to enable action on the ground in the event of a food safety incident. The EU has advanced traceability systems in place. For example, beef can be traced back to the individual animal.
The EU’s trade policy paper refers to Taiwan saying that the EU will “explore launching negotiations on investment with Taiwan”. The paper also talks about achievements on the food safety system and EU values.
Weigl concluded that the EU and Taiwan have an important and growing trade relationship with a shared goal to achieve the best outcome for food safety, animal and plant health. There is an excellent opportunity to strengthen cooperation, making the best use of resources.
Session 1 – The importance of audits in the food sector
Topic: SPS audits and inspections: The European Union approach
The European Commission service for Health and Food Audits and Analysis is based in Ireland and has 90 auditors and around 200 staff in total. One of its main functions is to conduct audits of food safety, animal and plant health. Audits are performed on systems, unlike inspections. Inspections are conducted to check compliance with requirements while audits examine the system to see if it is meeting its objectives.
The EU has a common legal framework but Member States maintain authority. The advantage of having a common system is that once products are approved in one Member State, they can be sold anywhere. Some food items, such as meat, have higher risks and require stricter regulations and controls. The audit system aims to inspire trust.
The EU’s SPS policy is harmonized throughout the EU and covers every part of the food chain – from farm to fork. It is a comprehensive and elaborate system based on science that is well-enforced and transparent. For example, methods and standards for the testing of food and animals is clearly defined and implemented across a network of laboratories. All national reference labs follow same standards. Member States are obligated to apply proportionate yet dissuasive sanctions for violations.
To be sure that everything works as planned, controls are needed. A clear attribution of roles is set out in Regulation 882/2004.
FBOs, which are registered at a national level, have a primary responsibility to apply EU standards. National authorities carry out official controls to enforce EU standards through inspections. The Commission’s role is to verify how the competent authorities ensure enforcement of EU standards, and their functioning in practice through audits. Audits make sure that the national systems are working as intended.
The audit process follows a step-by-step process. The first step is to determine if all the necessary elements of the system are in place (Plan-Do-Check-Act or PDCA elements). Does it work in a dynamic way, achieve the right results and is it reliable over time? Moreover, does the competent authority have the resources and procedures in place to ensure that the system can be applied effectively and consistently? If not, why is this and what is the impact on the overall capacity to meet requirements?
If system does not fully deliver, root causes are evaluated because if the reasons are not found, it is not possible to make proper recommendations for improvements. Conversely, if the real problems are identified, it is possible to determine and recommend the appropriate remedial measures.
There are clearly-defined principles for auditors and for conducting audits. Independence is important. To ensure there is no undue influence, funding for audits is paid for by the FVO, rather than the Member State concerned. Audits use an evidence-based approach and are conducted according to set international standards.
Auditors are required to act ethically, that is, treat auditees (who are likely to be stressed) with respect. Once audits have been completed, findings must be presented in a fair and balanced way. This means not only focusing on areas of non-compliance but giving a fair assessment of the overall picture that weighs what is positive (and working) against the problematic areas. There is also a duty of professional care. Auditors are not infallible and need to exercise careful due diligence and professional care. Finally, the audit must be done in a transparent manner.
Audits are done based on international standards. While the Codex Alimentarius - CAC/GL 26-1997 is not referred to on a daily basis, exactly the same principles are applied, as they match perfectly with the EU system.
System audits evaluate official inspection and certification systems rather than specific commodities or establishments. The EU audits also include inspections of a sample of the establishments involved. Inspections are planned, open to scrutiny and performed on the basis of internationally-recognised audit methodologies (in line with ISO 19011). The costs of audits are fully paid for by the European Union (including travel/accommodation expenses of the auditors) to guarantee objective and unbiased results.
There is a strictly-defined procedure to report the results. Auditors just need to follow procedures to ensure quality and timeliness. Draft reports can be finished within 20 days if sufficient preparations are done prior to the audit.
After the audit, draft reports are sent to competent authorities for comments. Final reports are published on the website including comments from the auditee.
Follow-up action is important. Competent authorities draw up action plans to address report recommendations, which are assessed and followed up on by the auditors. Audits are only closed after proof of action by competent authorities.
Topic: Risk-based management measures for imported animals and animal products
Progress on the personal information protection of ecommerce in Taiwan
Topic: Risk-based management measures for imported plants and plant products in Taiwan
Topic: Regulations and implementation of the inspection of imported food according to the Act Governing Food Safety and Sanitation in Taiwan
Session 2: Regionalisation as an efficient tool of disease control
Topic: Animal disease control in Taiwan - 2015 control and preparedness for HPAI
Topic: Animal disease control and regionalisation in the EU
Speakers: Benoît SAUVEROCHE, Head of Sector, Directorate for Health and Food Audits and Analysis, DG SANTE
The EU’s animal health policy aims to protect and raise the health status of animals whilst permitting trade and imports. Animal health legislation is harmonized throughout the EU. It covers identification and registration, prevention (through biosecurity, import conditions, animal food and feed controls), monitoring and surveillance, control and eradication of major diseases and emergency preparedness in the case of outbreaks.
Biosecurity is an essential tool that will be required in new legislation. The EU has strict standards on pathogens and there is a ban on using catering waste for animal feed. The EU has a mandatory registration, identification and traceability system and harmonized control measures.
Contingency plans are defined in EU legislation. Emergency exercises and alert drills need to be ready to use and contingency plans must be tested with complete mock exercises, including cross-border drills.
EU and national reference laboratories and diagnostic manuals provide uniform procedures to diagnose disease. It is compulsory for Member States to immediately report incidents, restrict movements and exports in zones around the outbreak, depopulate, clean and disinfect affected areas and conduct surveillance.
FBOs are required to keep records of all births, deaths and movement of livestock on farms and report the information to national authorities, which are required to keep databases of the information.
Monthly meetings are held between Member State authorities. They present in detail evaluation of disease and control measures which anyone can access. Experts can be sent for assistance in any outbreak and they can also be used by third countries. If an emergency spreads, the EU can take emergency action. There is an animal disease notification system which provides details of outbreaks.
Member States are responsible for the safety of the animals and products that originate in their territories. There are no internal border controls. Prior notification (EU database TRACES) and official certificates for animals and germplasm can be controlled at the destination. Emergency vaccinations can be provided under certain conditions. In case of outbreak of a major disease, automatic restrictions and control in zones applied as per OIE rules. In addition, specific legislation can be adopted to put further controls and restrictions on bigger areas, if considered necessary to maintain a robust protection of the single market operations in the rest of the EU. Restrictions can remain in place for up to a year or more after eradication of the disease.
The Commission supports Member States through a common financial framework for the food chain, financial support for emergency measures and for eradication/control/monitoring programmes, programmes peer-reviewed and approved by the Commission, tailored technical assistance by experts and financial and technical audits.
Topic: Animal disease control and regionalisation in the EU - Case study of Highly Pathogenic Avian Influenza outbreak in Hungary (February 2015)
Speaker: Ms Anna Luca VECSEI, Veterinary Officer, National Food Chain Safety Office, Directorate of Animal Health and Animal Welfare, Department of Epidemiology, Hungary
Two audits on avian influenza have been conducted since an outbreak in Hungary in February 2015 (a financial on Avian Influenza surveillance programs of 2012 and 2013, and a technical one on contingancy planning in focus with Avian Influenza and African Swine Fever).
Avian influenza is a (potential) zoonotic disease which can cause high mortality in poultry. Very strict control measures are needed to minimize human risk and spread from holding to holding. Socioeconomic losses can be substantial in industrial chains as well as small farms.
Most strains are not dangerous to humans but there are two forms of risk : infection by the native form of the avian influenza virus or emergence of new pandemic strains, either directly from avian viruses, or from their recombination with human or other animal viruses.
Since 2014, cases of HPAI H5N8, H5N1, H5N2, H5N9, and LPAI H5N2, H5N3 have been detected but so far there have been no human infections from these viruses reported in the EU.
Migratory birds have nine main global flight routes that can spread disease. Animal Health authorities follow and analyse the global and European epidemiological situation, conduct surveillance programmes and investigate suspicions. Rapid response is supported by contingency plans (which are obligatory and audited by EU).
There is a clear legal framework for avian influenza with detailed control measures. EC Council Directive 2005/94 sets out measures for the prevention and control of avian influenza. Commission Decision 2006/437/EC approves a Diagnostic Manual for avian influenza while Council Regulation 1099/2009/EC covers the protection of animals at the time of killing.
National laws (including those of Hungary) are harmonized with EU law either directly or indirectly. Surveillance of avian influenza is compulsory according to the Directive 2005/94/EC. Harmonised guidelines are laid down in Commission Decision 2010/367/EU Monitoring programmes have been carried out in poultry since 2003 and in wild birds since 2005.
In Europe 16 HPAI outbreaks have occurred between November 2014 and February 2015. The first response was an extra monitoring of live wild birds by collecting swab samples. Awareness campaign was ordered as well. In genereal, suspicion can arise upon a rise in the mortality rate, a decrease in water/feed consumption data; or clinical signsor laboratory results suggesting viral infection; or positive serological results in monitoring, or upon discovery of an epidemiologcal link. In this case clinical signs were observed such as silence of the animals and neurological symptoms (neck twisting).
When there is suspicion, authorities always inspect the facilities. When an official veterinarian receives a notification, s/he places the holding under official surveillance, implements movement bans (on animals, products and by-products), carries out immediate investigations and takes samples for virological and serological testing. Details of cases are then reported to county authorities. The chief veterinarian of the affected county then notifies the Chief Veterinary Officer (CVO) of the suspicion, identifies the risk period, identifies the movements/transports in the risk period, tracks down the consignments and informs CVOs of possibly affected counties and defines the possible restriction zones in advance.
Once infection is confirmed by lab tests, the CVO sets up a National Disease Control Centre, communicates the outbreak to the European Union, and on the same day to the OIE, trading partner countries’ CVOs, neighbouring countries’ CVOs and at the national level to animal health authorities of counties not affected, partner authorities, partner organisations, animal keepers and the public.
After confirmation of the outbreak in Füzesgyarmat, for example, a protection zone covering a 3 km radius around the outbreak holding plus the administrative territory of Füzesgyarmat was set up. In addition, a surveillance zone within a 10 km radius around the outbreak holding was established. In the affected area, birds are to bring inside a building on their holding and kept there to minimize contact with wild birds. In this case the birds were kept in closed technology. A general movement ban was put in place on poultry and other captive birds, carcasses, meat, poultry, eggs, feed, materials, vehicles, equipment and utensils, waste, droppings, manure, slurry and used litter. All affected areas were then disinfected including entrances and exits. All birds in the affected holdings and those kept in holdings in critical distance were destroyed and facilities were given a preliminary cleansing and disinfection (C&D), followed by a thorough C&D, which took about a week to complete.
The next step was to try to find source of infection through a thorough epidemiological inquiry. In this case the origin of infection could not be found.
This was followed by a period of monitoring to make sure the infection had been eradicated and had not spread. Restrictions on movement were kept in place. Official veterinary visits and a census was conducted on all large-scale holdings in restricted zones and all small scale holdings within the 3 km protection zone were visited. Census of all backyard farms were performed in the surveillance zone. When no problems were found after 30 days to C&D, restrictions were lifted and a repopulation programme began. New flocks were later tested and found to be free of infection.
A question was asked as to how the EU defines compensation rules. Ms Vecsei said that Hungary has national rules based on value estimation but also gets financial help from EU. The EU contribution depends on the disease.
A question was asked as to where one can check Taiwan’s audit reports. An official replied that after they receive documents, risk analysis takes about three months. Then they can ask countries for supporting documents and can extend the period. The official said that sometimes applicants do not supply the correct supplementary documents, which delays the process further.
Session 3 – Border and behind-the-border measures ensuring food safety
Topic: Traceability for livestock, food and feed in the EU
Speaker: Liisa RANTAMÄKI, Head of Sector, Directorate for Health and Food Audits and Analysis, DG SANTE
The EU requires identification and registration for farm animals for their entire lives, including movement controls. Traceability of food and feed throughout the food chain is mandatory. Traceability provides an important tool for the management of disease surveillance, outbreaks, eradication programmes, vaccination campaigns, regionalisation/zoning and husbandry.
Feed and food traceability helps to facilitate targeted withdrawals and recalls of feed and food, to trace back to the source when a risk has been identified, to maintain consumer confidence, to facilitate verification by control authorities and to ensure fair trading amongst operators.
Tracebility of bovine animals
Regulations (EC) No 1760/2000 and 1825/2000 reinforced the rules for bovine traceability in response to the BSE crisis in 1997. The regulations require specific individual cattle traceability and registration systems (from birth to death) and labelling of beef. The system for the identification and registration of bovine animals comprises double ear tags to identify animals individually, cattle passports (no longer compulsory), computerised databases and holding registers. In cases of non-compliance authorities must issue sanctions.
All bovine animals have two ear tags (one in each ear), given shortly after birth, with unique individual identification number on specific tamper proof ear tags. The specific requirements for the production and numbering systems of the tags, inscriptions and logos are given in the implementing Commission Regulation 911/2004. Specific information on Member States requirements in relation to cattle identification and registration is available on the following link:
New rules, will take effect in 2019, which will include the use of an electronic identifier as the second means of identification (injectable transponder, electronic ear tag or ruminal bolus).
Each animal keeper, with the exception of transporters, is required to have a holding register, with up-to date accounts of all cattle births, movements (in and out of holdings) and deaths.
Member States are required to have a national computerized database to keep track of the movements of animals (to and from holdings), births, deaths and dates of these events within set deadlines. The database must be in accordance with Articles 14 and 18 of Council Directive 64/432/EEC. The databases of all Member States are recognized as fully operational.
Information in the database is cross-checked with on-the spot checks. The obligatory data must be recorded and national authorities carry out regular checks in line with Article 22 of Regulation 1760/2000 as well as Regulation 1082/2003.
Legislation provides for sanctions for non-compliances identified. These vary from financial sanctions, movement restrictions to destruction of the animal(s), depending on the severity of the violation. Animals without identification cannot be accepted for slaughter. The carcasses of such animals must be destroyed. For example, in one case, the official slaughterhouse veterinarian detected these animals at the slaughterhouse as the age of the animals in the passports did not match with the carcass weight. An investigation found the animal had been stolen. DNA samples were then taken to proof their origin and the culprit was fined.
Traceability for sheep and goats, pigs and equidae
The system for identification and registration of sheep and goats is similar to cattle as (individual identification) is required. However, young sheep and goats can be transported directly to slaughter from their holding of birth with group identification. For pigs group identification is required (usually a slap mark). The identification system for horses is based on identification documents (passports) and microchips.
Traceability of food and feed
Regulations for the traceability of food and feed are laid down in Regulation 178/2002, Article 18. Food business operators (FBOs) are required to trace one step forwards and one step backwards for all ingredients in the food and feed at all stages of production. Details on information to be kept are laid down in Regulation 931/2011 such as: the names and addresses of suppliers, details of the products supplied description and quantities) and date of deliveries. The duration for keeping records is not specified but should not be shorter than the shelf life of the products.
Specific rules on labeling
The EU has also established specific rules on traceability. Those for bovine meat are laid down in Regulation 1760/2000 and 1825/2000 and include the labelling requirements. Beef labelling requires a comprehensive registration system by the FBOs involved to ensure the link at each step back to the group of individual animals. There are specific rules covering both compulsory (for safety reasons) and voluntary labelling (for quality reasons) for bovine meat. The requirements are very detailed and there are some possibilities for derogations for certain characteristics and products. The FBOs need to apply for voluntary labelling systems, such as for example Angus beef logos. If there are problems with the way products are labelled, they are removed from the market and must be re-labeled correctly. Official controls are carried out both on compulsory and voluntary labelling requirements.
Since 2015, the EU has introduced compulsory systems regarding country of origin labelling for meat from other species thus ensuring better traceability.
Audit series on post-slaughter traceability
A series of audits on post slaughter traceability were carried out in in 13 Member States from 2014-2015. The series of audits was partly triggered by recent events, for example the horse meat scandal in 2013. The objectives of the audits were to evaluate the operation of official controls over the traceability of meat, minced meat, meat preparations, meat products and composite products containing meat and products thereof and other ingredients and to evaluate the implementation of, and official control over, EU legislation on the labelling and identification systems of meat and products thereof.
The audits covered the production chain of fresh meat and meat products thereof, including composite products, storage, retail and distribution chains (samples were taken from several shops), labelling (to verify the accuracy of labels) and the use of additives in meat and products thereof. Samples were taken from retail shops during the first week and the competent authorities were asked to gather the documentation for traceability for all ingredients. The second week the audit team visited establishments that had produced the products picked up at retail. Level and verified the traceability, including quantitative traceability.
It was concluded following the exercises that some Member States had specialized teams on traceability, Member State controls on traceability are time-consuming and shortcomings were found related to labelling, the use additives and traceability of meat and meat products. An overview report on controls over traceability will be published on the website of DG SANTE.
Ms Rantamäki concluded that traceability is essential for a reliable food safety system. Moreover, a number of crises have triggered a number of initiatives to enhance and facilitate the practical application and work is ongoing on tools to further facilitate traceability.
Topic: Introduction to Taiwan’s food traceability system
Speaker: Mr WU Tsung-Hsi (吳宗熹), Section Chief of Food Imports Management, TFDA
Topic: EU business best practice sharing
Speaker: Mr Rami BAITIEH, CEO, Carrefour Taiwan
Taiwan takes food safety very seriously and so do retailers, which have a responsibility to provide good quality and safe items. Carrefour’s “Origin management” scheme aims to reduce steps in the supply chain by dealing directly with farmers. This shortens the time from farm to shop and thereby reduces waste, which is a problem for perishable items. Also, cutting out intermediaries reduces the costs for the retailer, which is reflected in cheaper prices for consumers.
Since 2013, the number of items in the scheme has risen 67% and the number of farmers participating has risen by 33%. Baitieh noted that with this scheme, even a typhoon does not necessarily result in an increase in prices.
Carrefour is also increasing the number of traceability items in its stores using the CoA’s Traceable Agricultural Product (TAP) system. The number of TAP items in the company’s stores is up 95% since 2013 and sales of these products have risen by almost 200% over the same period. Carrefour aims to double these numbers in 2016.
Baitieh made the point that farmers don’t want complicated contracts, which is why its standard contract with farmers has been simplified to just one page in length. In addition, the company pays farmers in cash promptly for their produce. In return, farmers are asked to respect the company’s food safety criteria. The company also provides training to farmers.
A good system is in place but not enough customers are aware of it, which is why the company is seeking to improve the way it communicates with customers to explain to customers what it is doing and why.
Carrefour has improved its internal hygiene standards with hygiene audits covering environmental hygiene inspections, staff and utensil cleanliness tests, fresh home-made product tests and food tests in external testing labs of fruit, vegetables and meat on a monthly basis. Moreover, all stores have monitors to show what is happening in butchery and bakeries.
Topic: Food safety practice in Taiwan
Session 4 – Better food – modern organic product regulation
Topic: Direction of Taiwan’s new organic regulation
Speaker: Mr WANG Wen-Liang (王文良), Section Chief, Agriculture and Food Agency, CoA
Topic: Taiwan organic green bamboo shoot production and export experience sharing
Topic: EU regulation on organic productio
In the EU there is no difference between regulations governing ordinary and organic produce in terms of food safety. There has been a large increase in the amount of land devoted to organics in the EU which has increased to over 10 million hectares in 2014. While the majority of land is in the 15 Member States that joined the EU before 2004, the rate of growth in newer Member States is faster, rising by around about 10% per year from 2005-2014. The top organic crops are olives, grapes, fruit and nuts and the EU organic market in terms of retail sales has more than doubled to €23 billion in 2014. However, the area devoted to organic crops still accounted for only 5.8% of total agricultural land at the end of 2014 in a context where the demand for organic products is fast increasing.
Legislation on organic food is found in Regulation 834/2007. EU legslation on organics dates from 1991 and was taken as a model for the Codex Alimentarius. The newest organic Regulation (nr 834/2007) is complemented by detailed implementing regulations on production, controls and labelling (Regulation 889/2008) and import rules (Regulation 1235/2008).
In principle, to be defined as organic, the farm management system must use the best environmental practices, protect biodiversity, preserve natural resources and animal welfare.
Organic practices have to cover all stages of production from farm to fork including agricultural and processed products and aquaculture (controls at retail level on pre-packed products can be excluded). Imputs such as feed will have to be organic in future.
Production rules for organic food specify no genetically-modified organisms (GMOs), no ionising radiation, no hydroponic production, the use of natural resources, crop rotation, respect of production cycles and the use of organic fertilisers, to name a few. There is a positive list of approved fertilisers and a positive list for processing aids, while for organic animal production the principle is disease prevention.
For a product to be labelled organic 95% of the ingredients must be organic. There is also a positive list of permitted flavourings and additives. Control legislation covers every operator in the food chain and is two layered: Member States set up a competent authority to implement rules on organic, which are set at EU level and apply horizontally in all EU Member States.. In addition, the Commission checks how national authorities carry out their activity as well as the activity of Control Bodies recognized for equivalence which certify third country exporters for organic exports towards the EU. Each Member State may delegate control functions to specific authorities.
The EU can recognize a country system as equivalent (meaning that the country has production rules and controls equivalent to EU rules) it can recognize for equivalence control bodies/control authorities, which certify that the products to be exported to the EU providing equivalent guarantees. There is a list of recognized third countries for equivalence (12) as well as a list of recognized control bodies/authorities which can certify third country exporters for organic exports to the EU (60 control bodies which function in 140 countries).
There are plans to make some changes to the current legislation to clarify and simplify rules and further enhance access of small producers, given the increase in the organic market and the large costs for certification, especially for small producers. Among the proposed changes is a streamlining of rules, more animal welfare measures and the option for group certification of small farmers. This would allow one certificate for a group of farmers. The group would have to set up their own control methods and would be submitted to random checks each year. If problems are found, the group certificate would be withdrawn.
Other changes proposed include replacing the unilateral recognition of a third country for equivalence by the EU with bilateral recognition. Under the proposal, the current system of control bodies would be maintained but the intention is to harmonise the standards of these bodies with EU rules.
The Commission submitted proposed changes in 2014, which are now being reviewed by the European Parliament and the European Council. The process is not expected to be completed before 2017.
Topic: Production and exporting high quality organic oils: Best practices and challenges
Speaker: Mr Corentin JOYEUX, Asia Area Manager, Bio Planète
Mr Joyeux began with an overview of his company. Bio Planète is a producer of organic cooking oils based in France with its regional Asian office located in Taiwan.
The company uses a cold extraction and filtration process to preserve the natural nutritional elements in its oils. Hygiene standards are strict and careful analysis is done to ensure safety and taste. More than 20 cycles of tests are done before products are put on market, including for plasticisers and 350 types of pesticides.
The company follows both mandatory standards required under the EU’s General Food Law as well as voluntary standards for quality and labelling requirements to make sure products meet the highest level of quality as well as ethics (the company is committed to fair trade).
The use of the organic logo in the EU is very strictly regulated and there are specific rules for different products which are very detailed. This gives real meaning to the use of the organic label but rules are also practical to follow.
To get certified as organic, the company has to use raw materials that are certified as organic under EU rules. They need to follow traceabilty rules and rules on how to use the organic logo.
The first step is to choose an accredited certifier. Not all companies are the same. Some are more expensive than others and some only specialize in certain areas.
Producing good products starts with buying well. This is difficult given the rising demand for high quality organic products and climate change, which is affecting the consistency of harvests. The company has invested in suppliers, for example of sunflower seeds, as well as storage facilities. It has adopted the practice of paying farmers in advance to secure future supplies.
Fair trade practices include a commitment to pay more for products to support communities, which the company does in Africa. It has a partnership with a supplier of avocado oil in Kenya.
On the challenges of exporting to Asia, food safety is a big issue and cooking oil is under scrutiny given recent scandals. On the one hand, this is positive for business as there has been a spike in demand for
organic oils. On the other hand, regulations are sometimes onerous in Asia. For example, the EU’s organic standards are not recognized in China. This means that importers need to get full certification of their products by Chinese authorities. This certification covers the whole supply chain, which is a problem when you have hundreds of suppliers that need to be certified.
In South Korea customs authorities asked importers to remove cyanide using high temperature, which is impossible using cold-pressed extraction method and which the company did not wish to do because it would destroy the nutritional value of the oils. The company eventually overcame the obstacle by proving that cyanide does not stick to oil.
In Taiwan, regulations have become more complicated recently. According to Mr Joyeux, regulations specify that there can no (zero) pesticide residues detected in organic oils, rather than setting a maximum level as is the standard international practice. Absolutely zero is virtually impossible because of cross-contamination from neighbouring non-organic farms. He therefore hopes that authorities will set a realistic maximum level in future.
Final Q&A session
Moderator: Mr Hans Joostens, Policy Officer, Agriculture, Fisheries, SPS Market Access, Biotechnology, DG TRADE
The final Q&A session invited speakers from the final session as well as previous sessions to attend. A number of questions were raised by members of the audience and answered by officials from the EU and Taiwan.
On a question as to how to trace pigs from the slaughterhouse if they come from 50 different farms, EU officials replied that each carcass gets a number to identify which holding it comes from so it can be traced back directly.
EU officials noted that tracing has improved since 2003. It is usually no longer necessary to destroy production from an entire day in the event of a problem. Some countries have crates and microchips in different parts of the carcass to trace back to the source and FBOs now have better systems to isolate problems to smaller batches.
On a question to Taiwan officials about the excessive length of time it takes to inspect organic produce in Taiwan (the questioner said that it takes up to a month because every batch has to be inspected), Taiwan officials replied that it is in principle possible to send samples by air to be tested in advance. However, experience has shown that some FBOs will provide samples that differ from actual shipments. Another problem is that certificates are submitted from certification bodies that are not recognized.
On the subject of why Taiwan has a zero tolerance level for contaminants in organic oil, Taiwan officials countered that Taiwan does not have a zero tolerance policy but rather a “Limit of Quantification” (LoQ) standard, which is above zero. They added that high standards have been set in response to consumer demand for very high standards on organic products. According to officials, authorities have held three public hearings on the subject to hear opinions from consumers and producers and gauge their views on residues. They found that 80% of consumers do not agree with changing the rules. Moreover, according to officials, retailers agree with the LoQ.
It was countered that so far all organic olive oils have failed the tests, which implies that the LoQ level is not realistic. If it is enforced there may soon be no more olive oil on store shelves. An official replied that the main issue is not pesticides but contamination from plasticisers, which may be due to using plastic caps. Using different materials for caps may solve the problem. The moderator, Mr Hans Joostens said that this was a good example of positive dialogue and an attempt to find a solution.
On a question as to why some certification bodies have been put on the CoA’s watch list, a CoA official replied that in cases where imported products certified by certain bodies had been inspected and found to have residues in violation of the law, then they are put on the watch list. Products are recalled and destroyed, traced back to producer and certification body. The certification bodies are alerted and asked to respond as to why the products in question are in violation of rules. If they do not respond with valid reasons within 3 months they will remain on the watch list. If they provide reasonable explanations or propose solutions and they pass a document review process to verify this, they will be removed from the watch list. Therefore, removal from the watch list depends on the certification body providing a satisfactory response.
Mr Joostens wrapped up the discussion by saying that dialogue between the EU and Taiwan will be ongoing. While challenges and irritants remain, the seminar demonstrated a willingness to continue to discuss and try to find solutions. He concluded that transparency and maintaining confidence is important and that realistic rules harmonized with international standards and best practices is the best way to ensure trade predictability.