DG Agri study on the ‘State of play of agricultural interbranch organisations (IBOs) in the EU’

DG Agriculture and Rural Development of the European Commission has just released a study on the ‘State of play of agricultural interbranch organisations (IBOs) in the EU’ in the context of the current Common Market Organisation under Regulation (EU) No 1308/2013.

Arcadia International together with Wageningen University and a network of national food lawyers (including me and my dear friend Francesco Montanari) performed this study for the Commission. The study provides a detailed overview of national legislation on IBOs as well as an analysis of the sectors in which IBOs have been established so far and their activities. This would not have been possible without the cooperation of all stakeholders surveyed and interviewed during the study to whom we are very grateful!

The full report and annexes can be downloaded HERE.

Some findings extracted from the executive summary:

Member States with legislation on IBOs – main features: As regards the definition of ‘IBOs’, several Member States have laid down national definitions for this purpose. Although national definitions largely coincide with the notion of IBOs provided by Regulation (EU) No 1308/2013, the legislation of each Member State has its own peculiarities.

The national legislation of most Member States provides for the possibility for IBOs to conclude agreements, decisions and concerted practices, provided that they do not breach the provisions of Regulation (EU) No 1308/2013.

Article 164 par. 1 of Regulation (EU) No 1308/2013 allows Member States to extend agreements concluded within an IBO to other operators that are not members of that organisation and that act within its economic area(s), as long as the IBO is considered to be representative of the production, the processing or the trade of a given product. Furthermore, in accordance with Article 165, when an IBO agreement has been extended, Member States may also decide that non-members, which benefit from that activity, are subject to the payment of all or part of the fees intended to cover the costs directly occasioned by the activities undertaken by the IBO in the general economic interest of the sector.

Member States with national legislation on IBOs but with no IBO recognised: Currently, IBOs are formally recognised only in France, Greece, Hungary, Italy, the Netherlands, Portugal, Romania and Spain. The reasons for the lack of recognitions in the remaining 11 Member States vary and include, for instance, the lack of awareness about IBOs, the preference for other organisational structures, the lack of funding opportunities, distrust towards vertical cooperation in the food supply chain, due to historical reasons, as well as the administrative burden associated with their establishment. Likewise, in certain Member States, the slow uptake and the relative weakness of producer organisations recognised under Regulation (EU) No 1308/2013 at national level is regarded as a factor that justifies the current lack of recognised IBOs.

Member States with no legislation on IBOs in place: 9 Member States, namely Denmark, Estonia, Finland, Ireland, Luxembourg, Lithuania, Sweden, Slovenia and the United Kingdom have currently no national legislation for IBOs. The reasons are similar to the above mentioned.

The number of IBOs in the European Union has increased from 56 IBOs in 1990 to 123 (119+4) in 2016. The recognition of additional ones is planned during the second semester of 2016 (fruits and vegetables and floriculture in the Netherlands, fruits and vegetables in Spain, banana in France, and 2-3 additional ones in Greece). In the 1980- 1995 period growth was mainly observed in France. Since then the growth occurred in 7 other Member States (Greece, Hungary, Italy, the Netherlands, Romania, Portugal, and Spain). More than half of the recognised IBOs are located in France (63) for 60 located in the other 7 Member States (7 in Greece, 6 in Hungary, 3 in Italy, 27 in Spain, 7 in the Netherlands, 5 in Romania, and 5 in Portugal). Most of the IBOs have a national scope (85 out of 123). Regional IBOs are present in only 2 MS (France with 36 regional IBOs in mainly the wine sector, and Spain with 2 regionally recognised IBOs in Andalusia). There are, at the moment, no transnational IBOs at EU level.

Representativeness rarely reaches 100%. It usually ranges between 80 and 95% at primary production level. In general, the level of representativeness seems to be higher in primary production than for the other stages of the supply chain.

The study shows that the main three objectives of IBOs are:

 First, improving knowledge and transparency of production and the market;

 Secondly, promoting consumption on internal and export markets; and

 Thirdly providing information and perform the necessary research to innovate and secure quality of the products.

IBOs are confronted with several challenges: The first main challenge is linked to the concerted management of interests of the different actors in the supply chain. The organisation of dialogue has to be preceded by a pre-condition, which is the clarification of the interests of the different categories of supply chain actors involved and the construction of a common position. In addition, analysis of the history of IBOs shows that the success of dialogue between supply chain actors within the IBOs is partly determined by the role that public authorities play. Another challenge is related to the demand of more transparency in the IBOs governance and procedures.

Benefits of IBOs

The assessment of success and consequently the benefits arising from IBOs have to be considered carefully as the realisation of benefits is not shown in all cases due to the variability of organisations and governing principles. Complexity is added by the very nature of mostly intangible or soft benefits that can neither be measured nor quantified explicitly.

IBOs offer a platform for discussion between supply chain actors that are members of these organisations and create the conditions for collective communication with other actors of the same supply chain but also leads to improve communication between IBOs members.

Additionally, this platform creates a focal point for policy dialogue with government and public authorities. Public authorities also benefit from the presence of IBOs in the supply chain in emergency and crisis situations. IBOs have therefore a specific role for the supply chain as an entry point for Competent Authorities. When an IBO represents all the stages of the chain it covers (because extension is systematically applied), authorities can use it as an entry point for implementing dedicated measures, proposing the delegation of tasks, and therefore the transfer of costs to the private sector.

In some cases, the possibility to extend food safety or plant health mandatory measures to all actors of a given agri-food sector provides a robust and immediate response to food safety emergencies and crisis.

Supply chains benefit from IBOs activities as regards the collection and dissemination of technical and economic knowledge. IBOs are centres of expertise which collect technical and economic data, discuss the findings and then make available this knowledge to their members (and often also to non-members). The presence of an IBO in the supply chain allows for a fairer distribution of risks and profitability.

IBO: tools for the development of supply chain?

IBOs may play a key role in the functioning of the supply chain, and therefore in developing the food supply chain for the benefit of all actors. However, the vertical cooperation model cannot ensure such developments by itself alone. It is in fact only one amongst the tools that could be implemented in the supply chain. In several MS in which no IBOs are recognised, other types of vertical cooperation exist, according to the description of the current landscape. There is quite a diversity of situations, which might be seen as a sign of adaptation to national situations.

To obtain the benefits of interbranch organisations, components of the legislation (especially possibility of extension of rules and financing) and the conditions of success presented above must be implemented, even if these prerequisites do not provide guarantees of effectiveness. Effective participation of members and real commitment to collaborating must be present. Moderation by public authorities in stakeholders’ discussions and disputes could also be seen as a factor of sustainability.

Even if the number of IBOs continues to grow at a regular pace, the full implementation of the “IBO concept” – i.e. the full use of legislative provisions, including extensions of rules and financing to non-members, and the establishment and establishment of close relationship between all actors being economic actors, other stakeholders and public authorities – is still under development. A majority of Spanish and Romanian IBOs have benefitted from national funding via subsidies at recognition. However, they currently suffer from lack of funding as subsidies have been stopped and no extension of rules is in place to date.

 

MoniQA Conference Report: Food Fraud Prevention and Effective Food Allergen Management (Bari, 26 – 27 Jan 2017)

Notes of meeting by Michael Walker, LGC, UK (see bio at the end of the article).

This was a two part meeting with day one on food fraud and day two on food allergen management.

Food Fraud

In the opening lecture of the conference Michael Walker in a talk ‘Food detectives: what it takes to trace food fraud’ described the historical cycle of meat species fraud and as an expert member of Professor Chris Elliott’s UK review, the spectrum from ‘cutting corners’ to food crime. Michael summarised the Elliott Review findings – the ‘8 pillars of food integrity’, dealing particularly with the National Food crime Unit, NFCU, the Virtual Authenticity Network and intelligence sharing. Michael concluded with case studies based on referee cases and conclusions. These included advice on curation of datasets, intelligence sharing and adequate levels of analytical surveillance for food fraud.

Cesare Varallo, a food lawyer and regulatory specialist, gave a persuasive talk on how food companies should handle a food recall – starting with planning for what you hope will never happen. Decide (in advance) who will do what if a recall needs to happen and have an effective communication strategy. Consumer safety, avoidance of panic, and brand protection can be achieved, Cesare noted especially not to neglect social media.

Jeff Moore, Director, Science-Food Standards, United States Pharmacopeia, USP, explained the background to USP’s involvement in food. Jeff explained the USP’s current (free to download and comment on) validation of Non-Targeted Methods for Food Fraud Detection. Non-targeted methods work by, instead of looking for what should not be there but by defining carefully what should be there. Any deviation in the expected analytical signal flags up suspicions that can be further investigated. This is a powerful approach to check for the ‘unknown unknowns’ but so far has been difficult to validate to accepted chemistry standards so this USP advice is very welcome. The USP food fraud mitigation strategy and food fraud database are key resources. Its impossible for every food firm to investigate every ingredient – USP guidance shows how to funnel down risky ingredients so as to prioritise vulnerability assessments. The Food Fraud Database can give real time information on designated ingredients and record types of food fraud, incidence records, inference records, surveillance records, and methods. Find out more here.

Jingyi Li Blank, Director, Mintz Group, Hong Kong gave a fascinating glimpse into the highly restricted world of private investigations in food. Her examples included background checks on people, information related to acquisitions, disputes, IP violation, post-fraud internal investigations, and corruption and bribery investigations. All these are handled in a highly restricted and confidential manner. The information is derived by wholly legal means from public records, (which can be broad, e.g. personal attendance at court hearings), and human intelligence inquiries. For example, in China, understanding the true ownership and management structure, the local government dynamics, or whether the company or its principals have ever been subject to corruption or litigation issues, have been key to helping clients understand the profile of an important partner.

Alain Maquet, of the Joint Research Centre (JRC), European Commission, gave an overview of targeted single/multiple marker approaches (IRMS) and fingerprint type of methods,( -omics and IR). Alain showed organic wheat can be differentiated from conventionally grown wheat by transcriptomics although more samples will be needed to enhance the predictive ability of the technique. Untargeted metabolomics were successful in classifying organic v’s conventionally grown carrots.

Marco Arlorio, Università del Piemonte Orientale “A. Avogadro”, Italy, made the point in a talk on post-analysis data processing of untargeted methods that untargeted = big data – so what post analytical steps need taken? His solutions included data fusion by mathematical algorithms better to describe the phenomenon, along with ‘deep analytics’, and artificial intelligence – artificial neural networks, although these must be trained by large numbers of samples. Once again the problems of lack of reference standards raised its head.

Bert Popping, formerly Eurofins, now teamed with Carmen Diaz-Amigo in their own consultancy firm compared the food frauds uncovered by Fredrick Accum (‘Death in the pot’) 200 years ago with modern frauds, many in the same product categories such as olive oil. He emphasised considerations of mass balance in detecting fraud and looked at the information to be derived from consumer product buying patterns and, without using the term, discussed ‘the consumer as analyst’ affirming the findings of our own horizon scanning in this regard.

Richard Cantrill, Chief Science Officer, American Oil Chemists’ Society (AOCS), gave a good generic answer to the question ‘What is your favourite olive oil? – “one I can taste before I buy”. If you can’t rely on that, exacting olive oil specifications have been developed together with elaborate analytical approaches. The International Olive Council has devised approaches to verify authenticity by relying on multiple approaches to oil chemistry designed to limit the possibilities of adulteration with other common seed oils.

Professor Tullia Gallina Toschi, University of Bologna, Coordinator of the OLEUM Project described its aims to better guarantee olive oil quality and authenticity by empowering the detection and fostering the prevention of olive oil fraud. Over four years, the project will develop, with the widest range of stakeholders, new methods and carefully revise existing analytical methods for detection of frauds in different categories of olive oil. It will establish a wide community of laboratories and institutions involved in quality control (OLEUM Network) and by storing and sharing relevant data and results (OLEUM Databank). OLEUM has identified gaps – in legislation and regulatory, analytical approaches, harmonisation and coordination, and consumer and market confidence – and wants to address these and enhance competitiveness of European olive oil sector. But there are many global control labs using all the existing methods so it is best to adapt what we have and improve it to make existing methods more effective and efficient. OLEUM is still in its first few months.

Michal Godula, Thermo Fisher, Italy, described resolving food authenticity challenges using advanced isotopic ratio analysis using Orbitrap high resolution mass spectrometry.

David Psomiadis, Imprint Analytics, Austria, described developments in food authenticity testing by stable isotope analysis, a service provided by Imprint Analytics.

Valeria Terzi, Genomics Research Centre, CREA-GPG, Fiorenzuola d’Adda, Italy, discussed DNA markers, digital PCR and NGS to secure authenticity (e.g. Durum wheat) and safety (e.g. mycotoxins) in the small grain cereals sector.

Kezban Candogan, Department of Food Engineering, Ankara University, Turkey, spoke on the species identification of raw meat mixtures Using Fourier Transform Infrared Spectroscopy.

Food Allergen Management

Professor Clare Mills, University of Manchester, Coordinator of the iFAAM Project, UK opened the second day of the MoniQA International Symposium in Bari. In Clare’s wide ranging review of the development of risk assessment in food allergy the highlight for me was the new data generated in iFAAM broadening the evidence base to support threshold doses and evidence-based action levels for allergens in foods. This has the potential to yield a risk assessment. Secondly Clare re-emphasised the need for better analytical methods and reference materials for food allergens.

Professor Samuel Godefroy, (Laval University, Canada, and Queen’s University Belfast) spoke on risk assessment and the regulatory perspective, echoing calls for better analysis. Prof. Godefroy welcomed application of deterministic risk assessments for incident evaluation but also the moves within iFAAM towards a more probabilistic risk assessment which will be of wider application in better management (and reduction of) precautionary allergen labelling. But he cautioned that harmonised international guidance is needed to make a level playing field for regulators and a more predictable environment for industry.

Professor Luigi Macchia, University of Bari, gave a fascinating talk on the local clinical food allergy prevalence in the Puglia region.

Prof Clare Mills presented data from Dr Audrey Dunn Galvin of Cork on the iFAAM labelling survey to help us to understand more about how those living with food allergy assess risk when making decisions based on precautionary allergen (“may contain”) labelling. These data will be key in creating conditions in which food labelling is truly useful for, and more importantly, used by consumers with food allergies.

Luca Bucchini, Hylobates, Italy, gave a detailed analysis of the iFAAM database of food allergen recalls, calling for more harmonisation of how regulators deal with and report recalls.

Robin Sherlock, DTS FACTA, Australia, walked us through the Allergen Bureau VITAL 2.0, showing how industry benefits from food allergen management support tools. Robin, who was an Allergen Bureau Board member from the start of this excellent programme noted that analysis plays only a small part of the spectrum of Allergen Bureau allergen management and risk assessment tools. But the benefits of good analysis include monitoring incoming ingredients, investigating, validating and verifying cleaning and problem solving and troubleshooting, especially with any problematic equipment on the manufacturing line.

Daniel Imhof, Head Official Food Control Authority Brunnen, Switzerland explained how Switzerland set a value of 1 g/kg (0.1 %) which triggers allergen labelling, even if the allergen is not intentionally added but has inadvertently entered the finished product. The legislation has not set a limit, but a ‘mark’ by which the food industry should be aware of unintentional contamination in the context of their own product control and allergen management. In 2006 Allergie Suisse SA also defined a maximum value (50 mg/kg) for allergens, as an analytical detection limit and assess and publish complying products. Of the approximately 400 certified products so far, this value was not been exceeded. Hence the 1 g/kg (0.1 %), set up 20 years ago, is in effect superseded since the food industry seems to be operating at in-house limits much below this and below the 50 mg/kg Allergie Suisse limit.

My own talk, immediately after lunch seemed to go down well, and I hope my recommendations on how to report allergen results are well received and put into practice. The take away message was:

Reporting the results of allergen analysis;

A report should state:

• Method of analysis

• Result: [X] mg/kg as Y, – where [X] is the best estimate of the concentration of allergen found by analysis of the sample received after in-laboratory homogenisation, extraction and analysis by a validated method, and – Y is EITHER the allergen protein OR the name of the food.

• But if the whole food is the reporting basis the conversion factor from allergen protein to whole food must be given.

• Conversion factors should be agreed with literature references to the typical protein contents of (at least) Annex II allergens. Adding the N to protein factor would be useful.

• As a matter of routine the basis of data as allergen or (preferably) allergen protein should be specified every time a datum is given in a method or report. ….. Until it appears to be ad nauseam Walker M & Rogers A, Romer Academy 2016

I also put in a slide asking for expressions of interest about a Marie Curie fellowship at LGC on allergen protein measurement by exact matching IDMS.

Prof. Melanie Downs, – Food Allergy Research & Resource Program, FARRP University of Nebraska-Lincoln, walked us through the FARRP development and validation of effective food allergen control plans.

Dr. Linda Monaci, ISPA-CNR, Italy, gave a comprehensive and technically thorough review of the current literature and advances made in methods for food allergen analysis. Linda especially focused on tandem MS methods capable of detecting multiple allergens at the same time within a single run.

Ronald Niemeijer, R-Biopharm, Germany reviewed rapid methods in food allergen management.

Dr. Roland Poms, Secretary General/CEO, MoniQA discussed food allergen reference materials and their impact on more reliable analytical results. MoniQA has liaised with the EU funded project iFAAM, the Prolamin Working Group and Australia’s Vital concept group. The first validated Reference Materials for Food Allergen Analysis were presented at the latest AOAC Annual Meeting 2016 in Dallas, Texas, USA. The first set of materials includes testing materials for milk allergen analysis comprising a Positive Control (SMP-MQA 092014, characterized dried skim milk powder), Negative Control (BLANK-MQA 082015, based on a gluten free cookie), and two Incurred Materials: LOW-MQA 092016 (SMP incurred in gluten free cookies, milled, concentration approx. 5 ppm) and HIGH-MQA 082016 (SMP incurred in gluten free cookies, milled, concentration approx. 50 ppm). A new gluten material is in preparation which is based on an extensively characterized wheat flour able to be employed for protein, peptide, DNA, and potentially other markers to be analysed. The reference material for gluten-free analysis will be available as incurred materials at concentrations of 0, 5, 10 and 100 mg/kg gluten in a baked product. Other food allergen reference materials (egg and soy) are in preparation.

Dr Katharina Scherf, German Research Centre for Food Chemistry, Leibniz Institute, Germany gave an overview of methods for gluten analysis, including the benefits of current methods and remaining challenges for this very complex analyte. There is as yet no certified reference material for gluten, although there is the Prolamine Working Group material. Differing ELISA platforms can yield differing results probably owing to variable prolamin/glutelin ratios. A GP-LC-FLD was developed that appeared to perform well and a stable isotope dilution method was used to quantify the immunodominant 33-mer gluten peptide.

The talk by Dr Maria De Angelis, University of Bari, Italy, on meeting the needs of celiac and gluten sensitive consumers was delivered by Dr Fabio Minervini. Sourdough fermentation, a traditional biotechnology for making leavened baked goods, was recently rediscovered by the scientific community, consumers and producers. In sourdough bread acidification, proteolysis, activation of endogenous enzymes and fermentation takes place. Based on this De Angelis’ research group work included fungal proteases and selected lactic acid bacteria in a strategy for spray dried wheat subject to sourdough fermentation could meet the needs of celiac and gluten-sensitive consumers. It could also improve the intestinal microbiota and host immunity increasing the resilience to CD.

Lastly Kathryn Miller, Coeliac UK, talked us through the crossed grain symbol and the certification of gluten free products.

By Michael Walker, Referee Analyst in the Laboratory of the Government Chemist LGC United Kingdom

A published scientist Michael is also comfortable in strategy and policy. His current portfolio includes several strands:

o Referee Analyst in the Laboratory of the Government Chemist, LGC, where he also manages research on allergen measurement, o Chair of the FSA NI Strategic Committee on Food Surveillance,

o A thriving chemico-legal practice,

o Member of the IFST Science Committee

o Training officer for the Association of Public Analysts.

Michael was a subject matter expert to the UK DH/Defra Elliott Review in the aftermath of the horse meat scandal and continues to advise government on aspects of the Review. Michael formed his own consultancy in 2006 following extensive experience as a partner in a private laboratory practice, Public Analyst, non-executive Director and in Forensic Science Northern Ireland. Michael is a member of the European Academy of Allergy & Clinical Immunology and facilitated a Food Allergy & Food Intolerance Knowledge Network for 5 years to 2015. His non-executive director experience includes as a founder board member of the FSA. He is a Chartered Chemist and Fellow of both IFST and RSC, and holds the MChemA, the statutory qualification to act as a Public Analyst in the UK.