Transcript SPS TBT Barriers

SPS TBT Barriers
Export Inspection Agency - Delhi
SPS/TBT
SPS/TBT
Application
Protection of Human/animal/Plant Life
(indirect effect on environment/quality
control)
Additives, Contaminants, toxins or disease causing
organisms in their food, beverages, feedstuffs; plants
or animal carried diseases (zoonoses), pests, diseases
or disease causing organisms, effect/damage to
country by the entry , establishment or spread of
pests
Basis – Scientific risk Assessment
Doesn’t apply to SPS measures,
government procurement. Goods
National security requirements,
prevention of deceptive practices,
protection of human health (not
covered in SPS), environment.
Meeting quality standards & other
conformity assessment requirements
Basis: Legitimate objective
Residue Monitoring System
• Residues
• Substances having pharmacological action (both prohibited and
permitted substances) (SUBSTANCES HAVING ANABOLIC EFFECT AND UNAUTHORISED
SUBSTANCES, VETERINARY DRUGS (1) AND CONTAMINANTS)
• Metabolites of substances
• Substances transmitted to animal products (Heavy metals,
pesticides, toxins, PCBs, dioxins, etc.)
• Substances formed by biological action (bacterial toxins, aflatoxins,
etc.)
Residue Monitoring System
• Preventing prohibited substances getting into
the food chain, which are harmful or likely to
be harmful to human health.
• Monitoring of substances which are harmful
or likely to be harmful to human health to
ensure that the level is within the prescribed
limit (based on scientifically established risk
analysis) in the particular food.
Systems of Residue Control
NRCP :EIC is implementing through MPEDA
in aquaculture products
RMP : EIC’s Annual Residue Monitoring Plans
(RMP). Implemented by EIC in Egg
Products, Milk Products, poultry meat
products and honey
Why NRCP and RMP?
•
•
WTO Agreement:
1. SPS Agreement: Compliance of Sanitary and Phyto-Sanitary requirements of
importing country.
2. TBT Agreement: No importing country should impose Technical Barrier to
Trade.
The important requirement for global food trade is Food Safety (The food free from
health hazards). Consumer is entitled for safe, sound and wholesome food free
from any physical, chemical and microbiological hazards
Requirement of Harmonization
SPS and TBT agreements require National Standards to Harmonize with
International ones
NRCP and RMP
• Objective:
 Monitoring and insurance of the acceptable residue levels of drugs,
pesticides and contaminants in the food products.
 Detection of any illegal treatment (s)
 Establishing a system of corrective action in the event of detection of
residues higher that the prescribed limits by issuing alert information and
follow up visits
 To ensure that the food products exported from India meet the prescribed
regulatory requirements of the importing countries.
•
•
Scope:
Animals or animal origin products and processing meant for export by the
approved processing establishments having implemented HACCP based
own check system.
NRCP/RMP for EU
•
To fulfill the requirements of EU
– EC is responsible to ensure high level of human health protection
through Food & Feed regulations.
– EU food safety policy as 178/2002/EC for food and feed with
integrated "farm to fork" approach, aims to harmonise
existing national requirements in order to ensure the free
movement of food and feed in the EU.
– For import from third countries, - EC seeks guarantees equivalent
to EC requirements on residues of veterinary drugs, pesticides
and contaminants
Basis of animal origin products
 Council Directive 96/23/EC dated 29.04.1996 – requirements in relation to
the planning and execution of national residue control plans (NRCP) for live
animals and products of animal origin
 Commission Regulation (EC) No. 136/2004 – authorizes CAs of member
states of EU to test samples for residues at BIPs (Border Inspection Posts)
 Directive 97/78/EC - EU or the individual member state may reinforce
checks at the point of import on identification of residue problem
 As per the Council Directive 96/23/EC, residue monitoring requirements for
third countries wishing to export food of animal origin to the EU are met
including the requirements stipulated in the Council Directive 96/22/EC as
amended by Council Directive 2003/74/EC
NRCP/RMP for EU
 Council Directive 86/363/EEC and Commission Regulation (EC) 1881/2006
- Maximum Residue Levels (MRLs) for a wide range of pesticides and
maximum levels (MLs) for certain environmental contaminants,
respectively.
 Annual submission – RMP for each food commodity
from third countries to EC, (plans + previous year
results by the 31st March every year)
 Approval of Plan by EC- listed in the Commission
Decision 2004/432/EC, (updated).
 According to the last update India is eligible for export
the products of aquaculture, eggs to EU.
Basis for plant products
• In the EU, as from 1 September 2008, a new legislative
framework (Regulation (EC) No 396/2005 of the European
Parliament and of the Council) on pesticide residues is
applicable, covering approximately 1100 pesticides
currently or formerly used in agriculture in or outside the
EU. It lists MRLs for 315 agricultural products. These MRLs
also apply to processed products, adjusted to take account
of dilution or concentration during processing.
• To
access
the
database,
http://ec.europa.eu/sanco_pesticides/public/index.cfm
• EFSA is responsible for the safety assessment, which is
based on the properties of the pesticide, on the maximum
levels expected on food and on the different diets of
European consumers
Benefits of implementation of RMP
Food products of animal origin
•
Supplier / farmer - food safety measures - safe food products
•
Establishment - controls / monitoring over farmer / supplier at primary
production, storage and transportation levels.
•
All the stakeholders in the food chain - safe food products for human
consumption
•
FP meant for export - free from prohibited substances.
•
Permitted level of Veterinary drugs / pharmacologically active substances,
Pesticide residues, Heavy metals, etc. would be monitored.
•
Increase in Demand of safe food products – Increase in Export earning
•
Farmers - benefited from safe production - employment and earnings
NRCP – Salient features
Implemented by MPEDA
• EIC - CCA
• Sampling from aquaculture farms and testing, as per schedule - by
MPEDA
• Test results compiled and submitted to EIC.
• In case of failure of sample, if any, EIA concerned will initiate
appropriate action to find root cause and prevent recurrence.
• EIA furnishes action taken report to EIC
RMP – Salient features
Implemented by EIC
•
EIC – CCA, EIA- CA
Responsibilities of processors
 Responsibility - The processor ensure that the registered feed mills supplying
feed to the producers / farmers and farms / producers supplying animal products)
– records – EIA M.O
Sampling Procedure:
•
•
•
•
•
Multiple sampling of same matrix from same source - avoided
The Representative samples - traceable to source of farm / producer
Samples - collected and secured in clean and inert containers & labelled
Details of samples should be recorded.
Samples should be sent to designated EIA lab/ EIC approved lab under
controlled conditions.
RMP – Salient features
Analysis and handling of samples:
• The sample - secured storage at appropriate storage
condition.
• Analysis - as per the protocol given in the RMP by EIC.
• Remaining samples - stored securely at appropriate
condition.
• Initial test - positive, the remaining sample shall be
analysed for confirmation of results.
• The test results shall be reported in the prescribed format
• In case of failure, the results communicated immediately to
the EIA concerned
RMP – Salient features
• Corrective Action in case of failure of samples:
• Processor to be kept on ‘Internal On-Alert’ and advisory issued to
exporters, for;
• Identification of the exact source
• Stop procurement of raw material from the source.
• Refrain from exporting the products processed from the identified
source
• Find the root cause for the failure of the samples from the
identified source
• Take corrective actions to prevent recurrence
• Review the HACCP and revise if necessary
• Conduct regular training for farmers / producers / suppliers to
prevent recurrence
RMP – Salient features
• Corrective Action in case of failure of
samples: (Contd.)
• Assessment by the EIA official to find out the source
and root cause of the contamination including
backward linkages and assists in identifying
preventative measure to stop the recurrence
• The live stock concerned and the product is kept under
official control
• The source producer/farm is subjected to more checks
RMP – Salient features
• Provision for re-testing of positive samples

Re-testing of the positive samples - on request from the unit for re-confirmation.

The control sample shall be tested in two different EIA labs./ EIC approved labs other
than one tested earlier.

The result shall be treated as positive even if one of the two samples is found to be
positive on re-testing.

In case both the samples pass the MRL requirement on re-testing, the concerned EIA
shall withdraw internal alert , which shall take effect from that date.
–Recording and reporting:

All records relevant to planning, sampling and testing shll be maintained at EIAs.

monthly / quarterly summary in the prescribed format shall be submitted by the
Sub-office to the EIA concerned

The EIA concerned shall submit the compiled monthly summary
prescribed format.
to EIC in the
Issuance of Health Certificates
•
•
•
•
•
•
•
•
•
What is HC? - a document for a consignment of food product certifying that the
consignment has been processed under proper sanitary and hygienic conditions
and that the food product is safe for human consumption. issued by a competent
authority, acceptable to the health authority of the importing country,
Who demands? – Importing countries insist on Health / Veterinary / Sanitary /
Phytosanitary
Why ? - provides confidence to the health authorities of the importing country
Issuing authority: Competent authority specified by the importing country.
For F&FP meant for export to EU, the CA is Export Inspection Council of India.
For F&FP meant for countries other than EU, EIA issues HC
Some countries accept HC issued by official veterinary authorities
EIAs issue HC for F&FP consignments meant for EU on behalf of EIC using the
official rubber stamp (seal) of EIC
If an EU approved establishment obtains HC from any body other than EIC/EIA, its
approval is liable to be withdrawn
Requisites to issue HC
• On the basis of controls carried out, - on or
before the date of shipment
• EU does not accept HC issued after the date of
shipment indicated in the Bill of Lading
• On request from approved processor/exporter
Note: HC is issued only for F&FP processed in
establishments/factory vessels/freezer vessels
approved by EIC/EIA
• HC for consignments of F&FP meant for export
to non-EU countries shall be issued by the EIA
concerned in the prescribed format given at
Annexure XXII(A) of EI
• If any country has prescribed format of HC,
the specific format will be used as required by
the importing country.
• HC for Australia will be in the format
prescribed for the purpose
Formats of HC
• COMMISSION REGULATION (EC) No 1664/2006 – for HONEY AND OTHER
APICULTURE PRODUCTS
• COMMISSION REGULATION (EC) No 1250/2008 - FISHERY PRODUCTS
INTENDED FOR HUMAN CONSUMPTION
• COMMISSION REGULATION (EU) No 364/2011- for egg products (EP)
1.
Multilingual HC format is used for EU
A.
B.
C.
D.
English/French/Italian
for UK/France/Italy/Luxembourg/Belgium/Ireland
English/Swedish/Danish/Finnish
for UK/Sweden/Denmark/Finland
English/German/Dutch
for UK/Germany/Netherlands/Austria
English/Spanish/Greek/Portuguese
for UK/Spain/Greece/Portugal
HC is prepared in triplicate: Original (White) for importer; Duplicate (Pink) for
HO; Triplicate (Blue) for office record
Certificate of Analysis for Aquaculture
Shrimps meant for export to Japan
• If processor/exporter approach EIA for testing
consignments of Aquaculture Shrimps meant
for export to Japan for Antibiotic Residues
including Nitrofuran Metabolites, the samples
shall be drawn by an authorised EIA officer
and the same shall be tested in EIA lab under
its jurisdiction. However, the parameters
which cannot be tested in EIA lab, may be got
tested in EIC approved labs. The cost of testing
to be borne by the processor.
• Format of Certificate of Analysis to be issued is
given at Annexure XXVIII of Ex. Instructions.
Best Agriculture Practices in export
• Reforming agriculture and making the
produce internationally competitive in quality
& food safety.
• Green revolution – uncontrolled usage of
chemical fertilizers, irrigation water & pest
control products – adverse environment
impact, degradation & increased salinity in
soil, deforestation and depletion of water
resources.
GAP- role in export
• Structured methodology, innovative
technology without its adverse impact on
environment, health & safety of people.
• GAP – collection of principles – on farm
production, post production processes –
• - integrated pest management
• - integrated fertilizer management &
• - conservation agriculture
Basic elements of GAP
•
•
•
•
•
•
•
•
•
Farm selection & Farm management
Rational use & application of pesticides
Judicious use of fertilizers
Soil conservation & soil management
Irrigation & water conservation
Integrated pest management
Produce storage & handling
Pre – harvest application of pesticides
Harvesting practices
Basic elements of GAP
Contd….
• Post harvest treatment
• Workers health, safety & welfare
• Traceability – from farm to fork/back tracking
from fork to farm, batch/lot recall
• Protection of environment
Standardization of good agricultural
Practices
• GlobalGAP - key reference for GAP in global
market place- GLOBALGAP Secretariat
• GlobalGAP standards cover entire range of
agriculture including animal husbandry &
fisheries – (next slide)
• Consists of set of normative documents
covering GLOBALGAP general regulations, the
GLOBALGAP control points & Compliance
criteria and the GLOBALGAP checklist.
GLOBALGAP Standard Structure