FVO report – India – Fishery products

This report describes the outcome of a Food and Veterinary Office audit in India carried out from 3 to 14 March 2014, as part of its programme of audits in third countries.

The primary objective of the audit was to evaluate the public health conditions for the production of fishery products intended for export to the European Union. The audit covered the relevant EU legislation for the public health sector.

The report concludes that the competent authority has implemented an official control system for fishery products intended for export to the EU which adequately covers processing activities.

However, official controls in relation to primary production, landing and first sale have only started very recently and are at a very early stage of implementation. To date, very few aquacultures farms and fishing vessels have been approved and only a small percentage of those approved have been subject to official inspection. Furthermore, the two recently approved landing and first sale facilities visited were not fully in line with EU requirements. Consequently, the situation has not significantly changed since the fish sector was first audited in 2005.

From a general point of view, processing establishments visited during the audit were found to be in good condition regarding structure, equipment, maintenance and hygiene. In general, own-check programmes reviewed during the audit were in line with EU requirements and were adequately implemented by food business operators at landing and first sale site.

Official controls of fishery products intended for EU export are implemented in line with EU requirements, except for organoleptic checks.

The laboratories responsible for official analyses on fishery products have put in place measures aimed at ensuring a satisfactory level of analytical performance. However, with regard to cadmium, dioxins and polychlorinated biphenyls, some shortcomings have been identified, which undermine the ability of the competent authority to ensure that fishery products with contaminant levels exceeding EU maximum levels are not exported to the EU.

Finally, the lack of official controls over primary production also undermines the ability of the competent authority to guarantee that non-eligible fishery products are excluded from export to the EU.

FVO Report – Organic production and labelling in France

This report describes the outcome of an audit which took place in France from 9 to 20 September 2013 in order to evaluate the control systems for organic production and labelling of organic products; a previous audit to France on the same topic was carried out in 1999.

There is an overall effective system for controls of organic production and labelling of organic products in France, while national provisions provide a clear legal framework for the implementation of organic production rules although some of them differ from the requirements as laid down in the European Union (EU) legislation.

Control Bodies (CBs) are not always accredited before being approved by the National Institute of Origin and Quality (INAO). This is not in accordance with EU requirements, as accreditation according to norm EN 45011 may sometimes occur a long time after their approval. Although CBs have in general a sufficient number of suitably qualified and experienced staff, deficiencies in the performance of newly recruited staff without appropriate tutoring were noted.  Some controls carried out by the CBs were found to be ineffective. Differences in interpretation of analytical results for residues of pesticides and contaminants were noted between the CBs visited.

In some cases, the threshold for initiation of an investigation was not in accordance with EU legislation. In some cases, CBs did not immediately notify the Central Competent Authority (CCA) when deficiencies, affecting the organic status of the products, had been detected. In a limited number of cases enforcement was weak or missing.

Documentation, issued to operators, setting out their approval status is not published, which is contrary to the requirements of Article 92(a) of Regulation (EC) No 889/2008. As a consequence, those receiving product along the supply chain, those performing controls and consumers, cannot readily verify that suppliers and products have been appropriately certified.

In general, controls on labelling of organic and in-conversion products were effective. Traceability from retailer to the producer was satisfactory (in one case, identifying an ingredient erroneously declared as organic).

The French instructions delegate to CBs the administration of certain exceptions to organic production standards, which is not in compliance with EU requirements, whilst in other cases (e.g. mutilations) derogations have been granted countrywide without any effective control or verification.

Procedures for communication, co-ordination and co-operation between the CBs and the CCA, and among the different Competent Authorities (CAs), are in place, with the only exception being the French Paying Agency (ASP); with the effect that important information concerning controls carried out by the ASP are not being used to target or prioritise the controls operated by other
CAs.

(Source DG Sanco – FVO website)