FVO report – India – Microbiological contamination in seeds for human consumption

This report describes the outcome of an audit carried out by the Food and Veterinary Office (FVO) in India from 9 to 17 December 2014. The objectives of the audit were to evaluate the control systems in place to control microbiological contamination in seeds for human consumption (in particular Salmonella contamination of sesame seeds as well as seeds for sprouting e.g mung beans and other seeds for sprouting) intended for export to the European Union (EU) in the framework of Regulations (EC) No 178/2002 and No 852/2004. The evaluation of procedures in place for certification for imports into the EU of seeds for the production of sprouts as required by Regulation (EU) No 211/2013 was also assessed.

This FVO audit to India on the microbiological controls of sesame seeds was undertaken as part of the 2014 FVO audit programme due to the number of Rapid Alert System for Food and Feed (RASFF) notifications linked to this issue.

There is no requirement for exporters of sesame seeds to the EU to be registered with the Shellac and Forest Products Export Promotion Council (SHEFEXIL), the competent authority responsible for sesame seeds. A number of exporters who were mentioned in RASFF notifications were not members of SHEFEXIL and could not be followed up by SHEFEXIL.

A number of consignments that were tested and found to be Salmonella and E. coli free prior to shipment from India were found to be Salmonella positive in the EU.

Overall, there are a number of significant gaps in existence which cannot assure that sesame seeds exported to the EU are safe. The CA responsible for sesame seeds, SHEFEXIL, does not carry out any controls on growers, processors or exporters of sesame seed. In addition, there is a failure to follow up RASFF notifications relating to sesame seeds in India. This is mainly due to a lack of coordination between the Ministry of Commerce and Industry which is the national contact point for RASFF in India and SHEFEXIL, which is responsible for following up on RASFF notifications relating to sesame seeds. Laboratories visited were capable of undertaking the relevant testing for Salmonella detection. However, the approach to sampling of consignments for microbiological testing prior to export could not ensure statistical representativeness.

The Agricultural and Processed Food Products Export Development Authority (APEDA) confirmed that they are the CA for sprouted seeds and seeds for sprouting. APEDA is aware of the certification requirements for imports into the EU of sprouts and seeds intended for the production of sprouts as required by Regulation (EU) No 211/2013. APEDA has received no requests from exporters for such certification to date, thus no certificates have been issued.

FVO audit in China – Good news about mung beans and sprouting seed exported to EU

Not everything is coming from China is definitely bad. Following an audit in 2013 (DG(SANCO)/2013-6680), which revealed several profiles of non-compliance with the EU rules, the Chinese Competent Authorities put in place a really effective system to chekk exporting seeds for sprouting and direct human consumption. 

This report describes the outcome of an audit carried out by the Food and Veterinary Office (FVO) in China from 15 September to 22 September 2014.

The first objective of the audit was to assess the official control systems in place for seeds for human consumption (in particular, mung beans and other seeds for sprouting and direct human consumption) for export to the EU in order to prevent microbiological contamination (Articles 11 and 14 of Regulation (EC) No 178/2002) and to assess whether these systems offer adequate assurance that the produce concerned is within the limits laid down in EU legislation.

The second objective was to follow-up the previous audit DG (SANCO)/2013-6680. The audit focused on controls at primary production level. The objectives of the audit were met. Significant progress was made by the Chinese Competent Authorities (CAs) since the last audit in 2013 and all six recommendations made in the report of that audit were fully addressed. The CAs have implemented the requirements of the EU legislation on hygiene for exports of mung beans for sprouting. A new control system has been devised explicitly for seeds for sprouting for export to the EU. This is based on registration and approval of farms by regional CAs and the introduction of specific official controls of farms and processors/exporters. The processing facilities visited by the audit team followed Good Hygiene Practices. The laboratory visited was accredited and suitable for the purpose of official microbiological analysis including Shiga Toxin Producing Escherichia coli(STEC).

At the time of the audit there were no export certificates being issued by the CAs of China for seeds for sprouting to be exported to the EU. However, the system of official food safety controls currently in place can assure that the mung beans for sprouting were produced under conditions which comply with the general hygiene provisions for primary production and associated operations set out in Part A of Annex I to Regulation (EC) No 852/2004 as required by Article 3 of Regulation (EU) 211/2013. The system in place enables the CAs of China to issue the required
export certificates. This applies already for the 2014 harvest.