Top 10 articles in 2017 – Review

Dear readers and friends,

another year passed and I have to thank you everyone for the time spent reading this blog, sharing articles and commenting.

As usual, I recap the most interesting topics of 2017 in the first article of 2018. Here below the top 10 articles of 2017, according to the number of clicks received:

  1. Dual quality food products guidance of the EU Commission – Now what?

A brief exam of the Commission guidance released in September 2017 on this most controversial topic.

2. Food Supplement Regulation of China – Vitamins and Minerals list compared to EU

A special thank you to my guest writer KUN HOU (kunhou2016@gmail.com) for this very appreciated comparative table.

3. 1st Food Law in Asia International Conference – Export, Labelling and Countering Fraud

The event was organised on 12th June 2017 in Amsterdam, in cooperation with Lexxion and HFG law firm and it was a great success.  For those who enjoyed the event or are interested a 2nd edition is planned for 16th April 2018 in Rome (see link to provisional program) and will be followed the day after by the twin conference “Food Law in US” (see link to provisional program, to be updated soon).

4. Food defense requirements in EU?

Will we see food defense requirements in EU, like in US, in a near future? Nothing changed on the EU Commission side, since the publication of this article.

5. FDA Releases Compliance Guide for Small Businesses under FSMA Intentional Adulteration Rule (Food defense)

Another article that confirms the interest for the above mentioned topic.

6. FDA Extended Compliance Dates for Nutrition Facts Label Final Rules to 2020 and 2021

The FDA proposed this extension for the application of the new Nutrition Facts requirements, from mid-2018 to 1st January 2020 and 2021 (depending on the business size). Formally the extension has not been finalized yet, but it is more than sure that it will be confirmed soon.

7. ‘Natural’ claim in China: an overview and comparison with EU and US

The article provides useful links to my publications on the topic.

8. FDA Recognizes Australia as Having a Comparable Food Safety System to the U.S.

The FDA recognized Australian food safety system as equivalent to the US one under FSMA (Food Safety Modernization Act).

9. Summer Academy in Global Food Law and Policy 2017

This one of a kind event attracts always a lot of interest. This year there will be the 10th edition.

10. EU audits – Vietnam not compliant for pesticide residues

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FDA Releases Compliance Guide for Small Businesses under FSMA Intentional Adulteration Rule (Food defense)

Small Entity Compliance Guides (SECGs) are designed to help small businesses meet federal standards. They are among the resources that the FDA is providing to support compliance with the new FDA Food Safety Modernization Act (FSMA) standards.

The FDA announced today the availability of an SECG to help small businesses comply with the Final Rule on Mitigation Strategies to Protect Food Against Intentional Adulteration (or Intentional Adulteration Rule), mandated by FSMA.

The SECG was prepared in accordance with the Small Business Regulatory Enforcement and Fairness Act. It provides nonbinding recommendations on such topics as developing a food defense plan and records management.

The compliance date for small businesses under the Intentional Adulteration Rule is July 27, 2020. Very small businesses are exempt from the rule, except for a documentation requirement described in the SECG, which has a compliance date of July 26, 2021.

Here you can find also an FDA fact sheet on the final rule on food defense.

The FDA Food Safety Modernization Act (FSMA) final rule is aimed at preventing intentional adulteration from acts intended to cause wide-scale harm to public health, including acts of terrorism targeting the food supply. Such acts, while not likely to occur, could cause illness, death, economic disruption of the food supply absent mitigation strategies.

Rather than targeting specific foods or hazards, this rule requires mitigation (risk-reducing) strategies for processes in certain registered food facilities.

The proposed rule was issued in December 2013. The changes in the final rule are largely designed to provide either more information, where stakeholders requested it, or greater flexibility for food facilities in determining how they will assess their facilities, implement mitigation strategies, and ensure that the mitigation strategies are working as intended.

In developing the rule, FDA interacted with the intelligence community and considered vulnerability assessments conducted in collaboration with the food industry.
While acts of intentional adulteration may many other forms, including acts of disgruntled employees or economically motivated adulteration, the goal of this rule is to prevent acts intended to cause wide-scale harm. Economic adulteration, on the contrary,  is addressed in the final preventive controls rules for human and animal foods.

We already treated food defense topic in a previous post regarding EU situation.