FROM FARM TO FORK

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

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PARTNERS

EUROPEAN INSTITUTE, Bulgaria 96, Rakovski str., Sofia 1000, Bulgaria Phone: +359 2 988 64 10, fax: 359 2 988 64 11 e-mail: [email protected] www.europeaninstitute.bg INSTITUTE FOR EUROPEAN POLICY - EUROPEUM, Czech Republic Rytirska 31, Praha 1, 110 00 Phone: +420 221 610 206 (207); fax: +420 221 610 204 e-mail: [email protected]; www.europeum.org INSTITUTE OF PUBLIC AFFAIRS, Poland ul. Szpitalna 5 lok. 22, 00-031 Warszawa Phone: (48-22) 55 64 260; fax: (48-22) 55 64 262 e-mail: [email protected]; www.isp.org.pl CENTRE FOR POLICY STUDIES, Hungary Central European University H-1051 Budapest, Nador Street 9-11 Phone: (36 1) 327 31 18; Fax: (36 1) 235 61 70 e-mail: [email protected]; www.ceu.hu CENTER FOR POLICY STUDIES - PRAXIS, Estonia Estonia pst. 5a, Tallinn 10143 Phone. 64 09 000; Fax 64 09 001 e-mail: [email protected]; www.praxis.ee ASSOCIATION OF DAIRY PROCESSORS, BULGARIA Bl. 44, Entr. A, Lagera Housing Estate, Sofia City, 1612 Phone: +359 2 953 27 23; Fax: +359 2 952 32 65 e-mail: [email protected] THE ASSOCIATION OF MEAT PROCESSORS, BULGARIA 1111 Sofia Post Box 61 Phone: +359 2 971 26 71; Fax: +359 2 973 30 69 e-mail: [email protected]; http://amb.dir.bg

Аll rights reserved © European Institute This book is published with the financial support of the European Commission. It doesn’t represent the official position of the EC but only of the experts involved in its preparation. ISDN 954-9506-31-2

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FROM FARM TO FORK: EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

REVIEW OF FOOD LAW AND SOME EXPERIENCES RELATED TO THE ACCESSION OF THE CZECH REPUBLIC TO THE EU Ms. Bibiána Janáčková /Czech republic/ - Deputy Headmaster, Ministry of Agriculture of the Czech republic Mr. Petr Doležal /Czech republic/ - Head of working group, Ministry of Agriculture of the Czech republic THE POLISH EXPERIENCE IN THE IMPLEMENTATION AND EXECUTION OF THE FOOD SAFETY REGULATIONS Dr. Aneta Herod /Poland/ - Chief Specialist, Agency for Restructuring and Modernisation of Agriculture EXPERIENCES OF THE MODERNIZATION AND REMOVAL OF INSUFFICIENCIES IN THE HUNGARIAN MEAT AND MILK PROCESSING PLANTS DURING THE PRE-ACCESSION PERIOD Dr. Zoltán Szabó /Hungary/ - Vice-president, European Association of Co-operatives (COGECA) IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS IN ESTONIA Ms. Tiina Saron /Estonia/ - Managing Director, Estonian Dairy Association STATE OF DAIRY PROCESSING INDUSTRY IN BULGARIA Mr. Michail Velkov /Bulgaria/ – Executive Director, Bulgarian Association of Milk Processors ENFORCING THE FOOD SAFETY REQUIREMENTS IN BULGARIAN MEAT PROCESSING INDUSTRY AND THE ROLE OF THE ASSOCIATION OF MEAT PROCESSORS (AMB) IN THIS PROCESS Dr. Svetla Chamova /Bulgaria/ - Executive Director, Association Of Meat Processors in Bulgaria

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TABLE OF CONTENTS

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TABLE OF CONTENTS REVIEW OF FOOD LAW AND SOME EXPERIENCES RELATED TO THE ACCESSION OF THE CZECH REPUBLIC TO THE EU LIST OF ACRONYMS AND ABBREVIATIONS EXECUTIVE SUMMARY SHORT REVIEW OF THE NATIONAL LEGISLATION IN THE AREA: INSPECTION AND CONTROL MECHANISM IN THE CZECH REPUBLIC THE LEVEL OF HACCP IMPLEMENTATION IN THE NATIONAL MEAT PROCESSING AND DAIRY POSSIBLE MODELS FOR UPGRADE OF FOOD PROCESSING PLANT POLICY OPTIONS CONCLUSIONS AND POLICY RECOMMENDATIONS SOURCE OF INFORMATION SHORT RESUME OF THE AUTHORS ANNEX I. GOVERNMENT REGULATORY AGENCY CONTACTS ANNEX II. OTHER IMPORT SPECIALIST CONTACTS

7 9 10 11 12 17 19 21 24 25 26 27 28

CONFERENCE PAPER OF ESTONIA “FROM FARM TO FORK: EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS” 29 LIST OF ACRONYMS AND ABBREVIATIONS INTRODUCTION FRAMEWORK ANALYSIS POLICY OPTIONS CONCLUSIONS AND RECOMMENDATIONS ANNEX 1 ANNEX 2 ANNEX 3 ANNEX 4 ANNEX 5 ANNEX 6 ANNEX 7 ANNEX 8 ANNEX 9

31 32 32 41 42 44 45 46 47 51 52 53 54 55

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EXPERIENCES OF THE MODERNIZATION AND REMOVAL OF INSUFFICIENCIES IN THE HUNGARIAN MEAT AND MILK PROCESSING PLANTS DURING THE PRE- ACCESSION PERIOD 57 EXECUTIVE SUMMARY INTRODUCTION FRAMEWORK ANALYSIS LEGAL HARMONISATION SPECIFIC MEASURES RELATED TO THE QUALITY CERTIFICATION SOURCES OF INFORMATION SHORT RESUME OF THE AUTHOR APPENDIX

59 59 60 61 65 67 67 68

THE POLISH EXPERIENCE IN THE IMPLEMENTATION AND EXECUTION OF THE FOOD SAFETY REGULATIONS 69 SUMMARY INTRODUCTION POLISH ADMINISTRATION EXPERIENCE IN THE NEGOTIATIONS PROCESS CONCLUSION AND RECOMMENDATION ANNEX 1 ABOUT THE AUTHOR

71 71 79 80 81 82

ENFORCING THE FOOD SAFETY REQUIREMENTS IN BULGARIAN MEAT PROCESSING INDUSTRY AND THE ROLE OF THE ASSOCIATION OF MEAT PROCESSORS (AMB) IN THIS PROCESS 83 LIST OF ACRONYMS AND ABBREVIATIONS THE ROLE OF AMB IN APPLICATION OF FOOD SAFETY REQUIREMENTS IN THE BULGARIAN MEAT PROCESSING INDUSTRY

STATE OF DAIRY PROCESSING INDUSTRY IN BULGARIA STATUS OF THE MILK-PRODUCING SECTOR

85 88

95 101

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CZECH REPUBLIC

REVIEW OF FOOD LAW AND SOME EXPERIENCES RELATED TO THE ACCESSION OF THE CZECH REPUBLIC TO THE EU

Authors BIBIÁNA JANÁČKOVÁ PETR DOLEŽAL

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CZECH REPUBLIC

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

LIST OF ACRONYMS AND ABBREVIATIONS

MA - Ministry of Agriculture MH - Ministry of Health SVA – State Veterinary Administration of the Czech Republic Coll. – Collection of Laws CAFIA – Czech Agriculture and food inspection authority CISTA - Central Institute for Supervision and Testing in Agriculture HACCP – Hazard Analysis Critical Control Point system SAPARD – The Structure Action Programme for Agriculture and Rural Development PHARE – Pologne-Hongrie: Assistance pour la Restructuration Economique SEUROP – System of Classification of Pig and Beef Carcasses SMEs – Small and Middle-sized Enterprises NGOs – Non- Governmental Organizations RVA – Regional Veterinary Administration MVA – Municipal Veterinary Administration IS SVA – The Information System of State Veterinary Administration VHC - Veterinary Hygienic Centres CVO - Chief Veterinary Officer DVI – District Veterinary Inspectorate

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EXECUTIVE SUMMARY This report provides summary information on the Czech food law (for example food laws, labelling requirements, packaging, container and food additive regulation, pesticide and other contamination etc.). On May 1 2004, the Czech Republic became a member of the European Union (EU), and all EU’s Regulations and Decisions apply directly; while Directives have to be transposed to the national legislation before the accession. Food industry area, not regulated by the EU, so called “non-harmonized area,” may be regulated by every member state; however, this regulation cannot restrict free movement of goods. At the time of the accession of the Czech Republic to the EU the Czech legislation was considered fully harmonized with the EU food law. There is shared competence between the Ministry of Agriculture and Ministry of Health for official controls on foodstuffs. Production, processing and placing on the market is in the competence of Ministry of Agriculture, catering and public health relating issues are in the responsibility of Ministry of Health. The competent authorities for official controls are subordinated to these ministries (mainly ŚVA and CAFIA). The requirement to introduce control system based on HACCP is mandatory since 2000 in the Czech Republic, except for retailers and catering. It is mandatory for retailers since 1. 5. 2004 and for catering since 1. 5. 2005. The main goal of the HACCP system is to guarantee food-safety. But these principals are useful as well in connection to food quality. The Czech Republic took part in OPTIMILK project in 2004 (together with Poland, Romania and Bosnia – Herzegovina). The Evaluation of the Czech Republic was very positive. The results were that more than 92% of total milk produced is up to EU quality requirements and milk production is very developed, effective and qualitative.

CZECH REPUBLIC

In the period 2002 – 2003 the Ministry of Agriculture of the Czech Republic set up programmes of subsidies. The main reason was to support the increase of hygiene conditions in companies of food industry. These programmes had direct connection to support the improving of self-control system (HACCP). Programmes of subsidies were utilised and appreciated especially in 2003. One of these subsidy tools was pre-accession program SAPARD. The result of this programme seems to be positive: the effectiveness of establishing HACCP was very satisfactory and reached 100% in dairy sector and 42% in meat processing sector. Before accession to the EU the Czech Republic did not have any special official models for upgrading of food processing plant. All requirements and measures for improvement of hygiene standards in meat and milk processing plants were worked out individually for the separate establishments. The Czech Republic had no doubt that preparation for accession to the EU will be difficult. There were lots of different problems such as harmonization of legislation, change of rules for health marks, approval and registration system, delay of application, necessity to close many of establishments etc. 991 establishments were closed in 2003 and some others in the beginning of 2004. Although the situation was painful for many of food business operators, there was some level of improvement of hygiene standards throughout the Czech Republic as a whole.

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

SHORT REVIEW OF THE NATIONAL LEGISLATION IN THE AREA: FOOD LAWS On May 1, 2004, the Czech Republic became a member of the European Union (EU). All of EU’s Regulations and Decisions apply directly; while Directives have to be transposed into the national legislation. A food industry area, not regulated by the EU, so called “non-harmonized area,” may be regulated by every member state; however, this regulation cannot restrict free movement of goods. This report provides summary information on the Czech food legislation. At the time of the accession of the Czech Republic to the EU, the Czech legislation was fully harmonized with the EU food law. According to EU legislation Act 110/1997 Coll. on foodstuffs was amended in 2004 (before accession the Czech Republic in to EU). This amendment took in to account especially regulation (EC) No. 178/2002 laying down the general principles and requirements of food law, establishing the European Food Safety Authority and laying down procedures in matters of food safety. The results were some significant changes of the Czech national legislation. For example the definition of food business operators is applicable the whole text of Act on Foodstuffs and thus retail is covered as well. The new term “food safety” was incorporated into Food law by the regulation (EC) No.178/2002. This term comprises health but also for example protection of consumers, protection of health of people against unbalanced consume of foodstuffs and finally also risk of infringement of general principles of safety of goods. Details of food safety are stipulated in regulation (EC) No.178/2002. Feed shall not be placed on the market or feed to any food–producing animal if it is unsafe.

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The main principal of the general food law of the EU is based on idea “from the stable to the table”. It means that food law covers all food chain – animals, food stuffs including provision on materials and articles in contact with food, animal feed and other agricultural inputs at the level of primary production. In order to ensure the safety of food, it is necessary to consider all aspects of the food production chain as a continuum from and including primary production and the production of animal feed up to and including sale or supply of food to the consumer because each element may have a potential impact on food safety. Regulation (EC) No. 178/2002 stipulates that food and feed business operators at all stages of production, processing and distribution within the businesses under their control shall ensure that foods or feeds satisfy the requirement s of food law which are relevant to their activities and shall verify that such requirements are met. The next of important changes was to establish the system of traceability (mandatory since 1.5. 2005). Food and feed business operators shall be able to identify any person from whom they have been supplied with a food, a feed, a foodproducing animal, or any substance intended to be, or expected to be, incorporated into a food or feed. To this end, such operators shall have in place systems and procedures, which allow for this information to be made available to the competent authorities on demand. Food and feed business operators shall have in place systems and procedures to identify the other businesses to which their products have been supplied. This information shall be made available to the competent authorities on demand Traceability systems are of interest to consumers, as part of systems which:

• Protect food safety by effective product recall, in the case of an emergency. •

Enable avoidance of specific foods and food ingredients easily, whether because

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of allergen city, food intolerance or lifestyle choice.

• Enable real choice to be exercised between foods produced in different ways. Traceability systems are of interest to government as part of systems which:

• Protect public health through the withdrawal of food product from sale • Help to prevent fraud where analysis cannot be used for authenticity

• Control zoonotic disease e.g. tuberculosis, salmonellosis, bovine spongiform encephalopathy • Enable control with regards to human and animal health in emergencies e.g. contamination of land or raw material;

•

Control epizootic and enzootic livestock diseases through the rapid identification of disease sources and dangerous contacts;

• Monitor/control livestock number for subsidy claims; Traceability systems are part of systems, which enable industry:

• To comply with relevant legislation; • To be able to take prompt action to remove products from sale and protect brand reputation (through a failure in product quality or food safety incident).

INSPECTION AND CONTROL MECHANISM IN THE CZECH REPUBLIC Central Competent authorities

CZECH REPUBLIC

The special part of the Food Authority is the Executive Committee of competent authorities. This committee consists of statutory representatives of competent authorities (CISTA, SPSA, SVA CR, CAFIA) and the head of the Food Authority. The Executive Committee is a special tool to strengthen the relationship between Ministry of Agriculture and competent authorities. “Co-ordination Group for Food Safety” has been established according to “The Strategy to Assure Food Safety in the Czech Republic” approved by Government Resolution No. 1320, advisory and initiatory body of the Minister of Agriculture. This group co-ordinates activities of state administration central bodies (MA, Ministry of Health - MH) and supervisory bodies (CAFIA, Central Institute for Supervising and Testing in Agriculture – CISTA, State Phytosanitary Administration – SPA, State Veterinary Administration – SVA). It ensures contacts with the top management of the European Food Safety Authority (hereinafter referred to as “EFSA”) and co-ordinates activities of scientific committees and information centres. The co-ordination group meets regularly at working meetings the representatives of involved departments participate in. The Food Authority consists of: - Independent Division for Control over the Market with Food; - Food Production and Legislation Department; - Food Safety and Environmentally Friendly Technique Department; - Trade and international cooperation department.

MA Food Production Section – Food Authority

Independent Division for Control over the Market with Food – is responsible for coordination, management and giving direction to official controls over market with food.

Head of the Food Authority is the head of Food Production Section who is subordinated to the head of the commodities sections.

Food production and legislation department is responsible for the general conception of food

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

and tobacco industries, partial conceptions for food branches in the field of production and marketing (except diary sector, sugar industry and starch industry), food legislation – especially Act No. 110/1997 Coll. on foodstuffs and tobacco products, as amended, and its implementary regulations (decrees). Food production and legislation department is also the point for coordination of certification, State Quality Control, metrology and the whole area of standardization – including administration of archive and representation in the international organisations for standardization, especially Codex Alimentarius (within MA). In the area of risk analysis the department is responsible for risk management and it is the contact point for European Commission in the area of food law and food standards. FOOD SAFETY AND ENVIROMENTALLY FRIENDLY TECHNIQUE DEPARTMENT The department is responsible for risk assessment and risk communication according to the Regulation (EC) No 178/2002 of the European Parliament and of the Council. The department is the administrator of this regulation and the contact point for communication with EFSA as well. Ensures the activities of the Food Safety Co-ordination Unit and exchange of information between CR and EC/EU in the field of food and feed safety. Conducts the food and feed safety strategy in cooperation with Ministry of Health. It is also responsible for the administration approval process of Novel Food and genetically modified food and feed. Monitors the occurrence of the contaminants in the whole food chain. Elaborates the conceptions of the food safety in nationwide sphere of activity. Relevant competent authorities in responsibility of MA SVA SVA CR consists of headquarters in Prague and

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13 Regional Veterinary Administrations and one Municipal Veterinary Administration. Planned number of employees in the year 2005 is 1713 and about 50% of them are engaged in food safety activities. SVA CR methodically leads and manages staffs which perform the state veterinary supervision (it issues guidelines and organizes training courses), performs the third level of control (over RVAs). It monitors activities of the staff by means of the Information System of the SVA (IS SVA). RVAs directly lead VIs and Veterinary Hygienic Centres (VHCs) on the spot in establishments. Meetings of the Chief Veterinary Officer (CVO) with regional specialists (in food hygiene, epidemiology, welfare) are held. CAFIA The CAFIA comprises the Headquarters and its subordinate Inspectorates the territorial competence of which is provided for in Article 1 (2) of Act No. 146/2002 Coll., on the Czech Agriculture and Food Inspection Authority and on amendments to some related Acts, as subsequently amended (hereinafter referred to as the “Act on CAFIA”). The CAFIA comprises the Headquarters with its seat is in Brno and the subordinated Inspectorates. The Unit Control Department is involved in official control of the hygiene of foodstuffs at CAFIA’s central level, which comprises 11 senior officers and 1 head of the unit. At CAFIA’s regional level, it represents 241 employees. At each Inspectorate, there is a Control Department that is further divided into individual Units. The total number of the enforcement staff at regional level includes 207 inspectors, 27 heads of units, and 7 heads of control departments. At the headquarters of the CAFIA there is the Director General who, on behalf of the CAFIA,

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enters into legal acts, in accordance with the Act on CAFIA. At the head of each Inspectorate is a Director who is entitled to act on CAFIA’s behalf in matters concerning the activities of the Inspectorate, within powers given by the relevant legislation legal regulations, this organization code and other internal regulations. Inspections carried out by the CAFIA are regulated by CAFIA’s internal regulations;

districts. Administration is carried out through methodical instructions, control plans, sampling plans, consultations of heads of the departments and directors of the Public Health Offices. Local Health Offices are monitored by Regional Health Offices. In case of butcher’s shops the health inspectors carry on inspections on the catering section (if it is established there).

e. g. codes, orders of the Director General, standard practice procedures, guidelines, and records from meetings. Whilst codes, orders of the Director General, standard practice procedures and guidelines are issued by the Director General, the meeting system and binding effect of records ensure both horizontal and vertical communication among all CAFIA staff.

There are 340 inspectors in The Ministry of Health section located at 79 Local Health Offices.

MH

The obligation of food establishment operators is to establish critical points in all stages of production, to perform their control, to perform corrective actions and to keep records is laid down in Act No. 166/1999 Coll. on veterinary care, Act No. 110/1997 Coll. on foodstuffs and tobacco products and in Decree No. 147/1998 Coll. on the method of establishing critical points in production technology. Generally we can say that this duty is performed in all above mentioned establishments but in some cases (especially in small establishments) it has rather formal character. Only minor deficiencies in keeping records are found in other cases.

Ministry of health is responsible for the area of catering and for the articles intended to come into contact with foodstuffs. Furthermore, in relation to the production and consumption of food, it is responsible for the establishment of requirements concerning microbiological characteristics, additives, aromatic substance, contaminants, residues of pesticides and veterinary medicines in foodstuffs and conditions for irradiation of foodstuffs. It has a general responsibility for the assessment of health risks deriving from exposure to hazardous agents from food. It establishes the cause of threats to or harm of health, also in the area of food production and marketing. It makes an assessment of possible health risks within the approval of novel food and genetically modified food. It conducts controls over the market and services in these areas through competent authorities performing official control. MH controls The Regional Health Office, which carry out inspections in catering establishments. MH (central level) administers Regional Health Offices, which ensure the function of Local Health Office. An activity range of these Local Health Offices corresponds with

The level of implementation of food safety systems based on HACCP principles by food establishments SVA

CAFIA One of the basic targets of inspections carried out in the production of foodstuffs in 2004 was to assess compliance with requirements of the relevant legislation concerning HACCP and personal and operational hygiene. The CAFIA evaluated 70 features in establishments, the level of which served as a base for classifying the establishments into a particular category (A, B, C) according to the risk level. The assessment of the impact of mentioned legislation on food pro-

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

ducers is described in the overview of evaluated establishments for the period monitored and their classification into the relevant category according to the risk level on the basis of their final evaluation. MH Until 1.5.2004 there was a legal obligation to implement a system based on HACCP principles in only large catering establishments. From 1.5.2004 the obligation of implementation is applicable for all catering establishments. D. Procedures, which are in place at local level for the preparation, conduct, and follow-up of inspections SVA Depending on type of plant, supervision is performed permanently continuously (e.g. in slaughterhouses) or permanently randomly (e.g. in butcher’s shops). Frequency of random inspections is set by regional veterinary administrations in plans based on range and risk assessment of production and on previous inspection findings. Result of any inspection is recorded in Protocol on inspection findings and in IS SVA. Binding instructions containing deadlines are issued for remedy of shortcomings found. The remedy process and deadlines are continuously checked and results of the checks are recorded in Protocol on Inspection Findings and IS of SVA. CAFIA The basic framework of inspections is given by legislation, in particular by the Act on official control, the Act on CAFIA, and the Act on foodstuffs, and by EU legislation. The CAFIA is competent to inspect foodstuffs of animal origin only at trade level. Within the fulfilment of these duties, thematic inspections are established within the framework of the plan. Basic procedures for inspections were incorporated into CAFIA’s internal regulations, particularly into the

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Inspections Code and other internal regulations that are based on this Code (standard practice procedures). These internal regulations describe, among others, how inspectors initiate the inspection, how the inspection should be carried out, and which documents should be processed during the inspection. An integral part of every inspection is preparation for inspection. The aim of this preparation is to acquaint everybody who was designated to perform the inspection with supposed facts that can be expected at persons inspected. In particular: a) with the sphere of activities of person inspected; b) whether information on person inspected has already been saved in the relevant IS sub-systems; c) with results from previous inspections and imposed measures; d) whether person inspected possibly fulfilled obligations to report, laid down by legislation; e) to verify the current ness of information on person inspected according to the extract from the Companies Register, trade certificate, and other information obtained for example from the Internet. If other deficiencies are identified during the inspection, the person inspected is ordered to remove them. A written record is made of this measure. Internal regulation orders inspectors to check such measures. This check is governed by the same principles as standard inspections. MH In connection with information system implementation the standard operating procedures are being modified to make a link with this system. The Information system involves database consists of number of catering establishments, inspections, taken samples, imposed sanctions, results of laboratory analysis etc.

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The qualifications of enforcement staff SVA Veterinary inspectors (§ 59 (1) of Act No. 166/1999 Coll. on veterinary care) = persons qualified to perform veterinary activities or graduates of the university or of higher education institution of equivalent status who have acquired required qualifications. Veterinary assistants (auxiliaries) (§ 59 (5) of Act No. 166/1999 Coll. on veterinary care) = persons with complete secondary education who successfully passed a specialized professional training in appropriate branch organized by SVA, and university graduates who have acquired their qualifications in a study program for a bachelor’s degree in veterinary medicine and hygiene. Veterinary technicians (§ 59 (2) (b) and (d) of Act No. 166/1999 Coll. on veterinary care) = leavers of vocational secondary or higher schools who have acquired their qualifications in the veterinary field or leavers of vocational secondary or higher schools who have acquired their qualifications in the other field corresponding to the type and scope of activity. CAFIA The CAFIA enforcement staff has the following qualifications:

• 58% university education; • 5% higher professional education or bachelor education;

• 37% high school education. MH University educated inspectors are either physicians or other graduates, who pass further medical aimed courses in hygiene and epidemiology area. Secondary school educated staff involve assistants with hygiene specialisation as well.

Implementation of system based on HACCP principles in catering establishments is legal obligation stated in Act No. 258/2000Coll., F. The status of the legal enforcement for food safety systems based on HACCP principles SYSTEM OF APPROVAL AND/OR REGISTRAION In general legal basis for registration of establishments is laid down in Act No. 110/1997 Coll., on foodstuffs. According to this act food business operator shall notify commencement and end of his activity to the relevant competent authority (CAFIA, SVA). This notification has to be done in the day of commencement or end at the latest. SVA Special procedure of approval and registration is mandatory for food business operators who produce, manufacture or place on the market products of animal origin. This obligation and its conditions are laid down in the Act. No. 166/1999 Coll. Veterinary Act. Establishments are (on condition of fulfilled requirements) approved for marketing within EU or marketing only within the Czech Republic. Special conditions were stipulated for establishment in transitional period. CAFIA Food business operators who deal with manufacturing of foodstuffs of plant origin, raw material for its production or deal with tobacco products are obliged to notify commencement and end of activity to CAFIA. Food business operators who place on the market of export fresh fruit, vegetable or potatoes for human consumption are obliged to notify this activity in written form to CAFIA SVA+CAFIA The compliance with obligation concerning food safety systems based on HACCP principles is controlled by relevant competent authority

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

according to its competence. The competent authorities (§16 of the Act No 110/1997 Coll., on foodstuffs and tobacco products) for official controls in this area are the CAFIA and SVA. In the case of infringement of legal regulations the competent authorities proceed case by case taking into account all related conditions. Penalties can be also imposed. The maximum penalties for the failure to comply with obligation concerning food safety systems based on HACCP principles are stated in § 17 (2) of the Act No 110/1997 Coll., on foodstuffs and tobacco products and in § 17 letter b) of the Act No 166/1999 Coll., on veterinary care. The obligation of food business operators to determine the (critical control points) at all stages of production and placing on the market, where there is the highest risk of infringement of food safety, is governed by Article 3(1)(j) of Act No. 110/1997 Coll., on foodstuffs and tobacco products and on amendments to some related Acts, as subsequently amended. The competent authorities inspects whether the requirements laid down by Czech legislation (e. g. the Act on foodstuffs), directly applicable EU legislation or international treaties are complied within the production and placing on the market. This competence is based on the provisions of Article 16 (1)(c)(1) of the Act on foodstuffs, according to which the CAFIA is entitled to perform state supervision in the production and placing on the market of foodstuffs, unless this supervision is carried out by SVA.

THE LEVEL OF HACCP IMPLEMENTATION IN THE NATIONAL MEAT PROCESSING AND DAIRY GENERAL Act No. 110/1997 Coll. as amended laid down obligation to introduce systems of self-control based on determination of critical control points

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(HACCP - Hazard analysis of critical control points). This requirement is mandatory since 2000 in the Czech Republic, except for retailers and catering. It is mandatory for retailers since 1. 5. 2004 and for catering since 1. 5. 2005. Details for implementation and documentation are laid down by national decree 147/1998 Coll. as amended. On the level of EU legislation is mandatory to set up HACCP system, which is differentiated in 5 steps (according to directive 93/43/EHS on food hygiene). The HACCP system is based on Guide of Codex Alimentarius and there is 7 steps system, which has been laid down by legal regulation in the Czech Republic. Such system will be mandatory in the EU since 1. 1. 2006 (according to regulation 852/2004), so that is asset for food-business operators in the Czech Republic. The main goal of the HACCP system is to guarantee food-safety. But these principals are useful as well in connection to improving of food quality. Guides to good hygiene practices are elaborated by NGOs. The Ministry of Agriculture of the Czech Republic supported by guides to good hygiene practise were published and are available on the web sides of the Ministry of Agriculture- www. mze.cz and web sides of Federation of the Food and Drink Industries of the Czech Republic www. foodnet.cz. Our food business operators can use more than 20 Guides, which are different for the specific areas. At the present time are revised and updated in order to reflect changes of European food-law. EDUCATION The Ministry of Agriculture of the Czech Republic arranges regularly seminars and courses about valid and new food legislation. Part of these seminars is of course issue of HACCP. Centre of education in HACCP was established by the Ministry of Agriculture of the Czech Repub-

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lic in 1996. Seminars and educational courses on HACCP and related issues for food business operators and other interested bodies are organized there. MAIN TASK As well as other member states of the EU, the Czech Republic has some problems with implementation and enforcement of HACCP system requirements. The main task for the Czech Republic is to improve the system of official control including stress on education, knowledge, competence and skills of inspectors. OPTIMILK The OPTIMILK project and acronym for “Quality Safety and Value Optimization of the Milk Supply Chain in Rapidly Evolving Central and Eastern European Markets” is a project run by Wageningen University in the Netherlands (coordinator). The OPTIMILK project is funded by the Commission of the European Union under the Sixth Framework programme as a Specific Support Action. Partners from EU countries for this project are University College Cork in Ireland and Ecole Nationale Superieure de Genie des Systemes Industrielles in Nancy in France. Partners in Central and Eastern European Countries are Institute of Chemical Technology in Prague in the Czech Republic, Warsaw Agricultural University in Poland, Universitatea de Stiinte Agronomice si Medicina Veterinara in Bucharest in Romania and Edinburgh Direct Aid in Bihac in Bosnia and Herzegovina. In 2004 there were missions to 4 European countries to collect all relevant data and subsequently carry out detailed analysis. These analyses resulted in further reports. One of these missions was held in the Czech Republic. The special evaluation of Quality systems and HACCP implementation in dairy sector results from this report. This information has some informative value about the status of HACCP system. Short part from report:

CZECH REPUBLIC

“Law concerning HACCP was laid down in 1997. It became obligatory by the legislation of 1st of January 2000 for all the supply chain except for retailers, primary production and smaller food services. Two levels of HACCP exist; first level is indicated by basic legislation, second level is still not obligatory and is stricter. Certification is needed since 31st of Oct 2003 in order for the food producer to gain government subsidies (second level is close to Dutch HACCP principle). ISO systems have started to be spread in food production companies since 1997. Primary production quality systems are fully dependent on the purchasing dairy. Normally HACCP is indicated in the larger and newer farms. Normal evolution of the ISO systems was that HACCP was described and implemented for the production in 2000 as it became legal requirement, then the overall ISO system (9001 normally) for the whole company functions was build up on that. This was due to the fact that old quality requirement systems, even though similar to HACCP, needed to be revised and ISO system build up was not prioritized at that point. So generally: in countries such as the Netherlands, 1st step was the creation of GMP followed by 2nd step the creation of HACCP. In Czech Republic it has evolved the other way around; this was due to fast requirement by the legislation and thus fast need for implementation. Overall most of the dairy companies are ready for ISO audits (and direct certifications) during the year 2004, if they see certification needed, Most of the SMEs have ISO based systems coming up. However as certification will not bring competitive advantage, they are not certifying the systems at this stage. There is a new move towards new ISO standard 22000 in the retail part of the chain. All in all, the standards before ISO and HACCP implementation were at high level according to the detailed Czech legislation laid down since the revolution, but structures were not totally identical. Also some inconvenience has come about when legislation has been quite descriptive for some of the safety procedures and thus has restricted the actors from taking a more practical approach whilst dealing with the safety procedures. GMP has been an issue of interest also for the workers’ unions, as common procedures for all workers were seen as

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

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a positive thing (although not in every case). GMP build up for the dairies was expected to be done by the workers’ union by 2002 and subsidies were given by the government to do this. Some still continue. ISO 14000 environmental systems is not yet so common in the dairy industries in Czech, but meat industries have moved forward with it.

models for upgrade of food processing plant. All requirements for improvement of hygiene and measures to deal with hygiene standards in meat and milk processing plants were worked out individually for the separate establishments.

Quality standards were also good before the revolution, but we learned during our interviews that a lot of structures which were perceived as good were destroyed in the revolution “reorganization”. This was for example the case with veterinary controls and the limits have loosened up even more with implementation of the EU legislation. This was not seen as a positive development. Hygiene requirements were similar before 1994 to the current requirements, but lack of money to implement them resulted in compromises.

The State Veterinary Administration elaborated an internal system for “upgrading” of food processing plants in 1999. This system has been called “passportization” and was a part of the official control system. Originally SVA recognized 7 categories of food processing plants. Last 2 categories from this scale included food-processing plants, which either did not fulfill EU requirements or did not plan any investments and were closed. The method of passportization was changed later on. The main change was in the number of categories, but a main principal has been maintained.

Part of the Summary: On the dairy level, HACCP systems have been implemented and ISO systems are either existing or ready to be audited during 2004. Also on the dairy level the cooperation could be supported as it is at somewhat low level due to the fierce competition upon the EU accession. This would benefit the entire dairy sector of Czech Republic and bring competitive advantage in the opening of international markets.” It is necessary to add that this is the part if the report evaluating situation before accession of the Czech Republic to the EU. The Evaluation of the Czech Republic was very positive. The result for milk quality was that more than 92% of total milk produced is up to EU quality requirements. And the evaluation related to milk supply chain was that the Czech Republic is not a high milk production country, but very developed, effective and qualitative.

POSSIBLE MODELS FOR UPGRADE OF FOOD PROCESSING PLANT Before the accession of the Czech Republic to the EU we did not have any special official

PASSPORTIZATION

ESTABLISHMENTS IN TRANSITIONAL PERIOD In the framework of pre-accession negotiations the Czech Republic requested a three year transitional period as of the date of accession to the European Communities in order to achieve full compliance with the hygienic requirements for some undertakings processing raw materials and/or manufacturing foodstuffs of animal origin. The initial number of these establishment was 41 (23 slaughterhouses, 6 meat processing and manufacturing of meat products establishments, 4 poultry slaughterhouses, 2 poultry meat products and eggs and 6 dairies). On the basis of mutual agreement the „List of establishments including shortcomings and deadlines for the correction of these shortcomings“ were included in the Accession Treaty. In 2003 from the initial number of 41 items in the Treaty 27 establishments have already met the requirements of EC legislation or discontinued operations. It means that the number of establishments has decreased to 14. The further process was done in 2004 and at present we have only 10 establishments in transitional period. Each of these establishments should

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meet the requirements of EC in fixed date, some of them sooner. The last date for full compliance of the rest of the establishments in the transitional period is 31.12. 2006. We suppose that this deadline is not a problem. PROBLEMS WITH IMPROVEMENT OF HYGIENE STANDARDS Food business operators were informed about their obligation to comply with EU legislation a long time in advance. The Czech Republic had no doubt that the preparation to the accession to the EU will be difficult. One of the new realities was to establish a system of approval and registration of all food business operators who deal with products of animal origin (including meat and dairy sector). The deadline to fulfill this obligation in the Czech Republic was set up on 31. 12 2003. After this date only approved establishments were allowed to carry on business. In June 2003 there were 14 905 establishments in 10 047 plants. It was probable that 3871 establishments in 2 268 plants would fully comply with EU legislation at the latest till the end of 2003. It was clear that 760 establishments in 433 plants would no have any problems. They had very well elaborated schedules of activities for improvement, building projects which were judged by the competent authorities and accepted as realistic in connection to time (deadline) and investments. Only 61 establishments in 27 plants had to be closed because of shortcomings. In August 2003 it was quite clear that many of plants failed in timing of works and a lot of them had to be closed at the end of the year 2003. Problems had, for example, establishments in the border line between large and small capacity. The goals of these establishments were to reach EU standards. But they failed in timing with subsidies from SAPARD programme. There was some delay with applications for approval and registration in autumn 2003. In spite of the announcement made by regional veterinary

CZECH REPUBLIC

administrations and inspectorates and also by the press, the amount of applications was inadequate. SVA had to announce warnings in connection to possibility to receive all the application in December 2003. With regard to the number of employees and limited time there was a risk of failure in the approval and registration procedure. The official controls of all establishments were in any case necessary. During the monitored period – 30.6. 2001 – 30. 11. 2003 - nearly 500 (494) establishments were closed in the Czech Republic. The precise outcomes were known in June 2004. There was an estimation made that about 320 establishments would be closed. The reality was that 543 establishment were closed during December (455 from 16.12. – 31.12.2003) 991 establishments were closed in 2003. But all of these establishments had the opportunity to eliminate their shortcoming and after that be approved. In 31st March 2004 the list of establishments approved for EU market was sent to the European Commission. There were 585 plants with 912 establishments. From the end of January till the end of March 2004 SVA carried out about 7000 official controls in nearly 3500 establishments. Further 81 establishments were closed. Although the situation was painful for many of food business operators, the reality was in some level improvement on hygiene standards throughout the Czech Republic as a whole. SEVERAL SPECIAL ISSUES It was interesting that before the accession, some companies which had problem to meet the EU requirements asked for upgrading from large size capacity to small size capacity. The main goal of this change was to avoid the strict require-

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

ments of the EU, because these companies have approval to market only within the Czech Republic. For the local market we have special national rules. Starting from 1 January 2006 four EU Parliament and Council Regulations will come into force in the EU (hygienic package). These legal regulations do not include differentiation into small and large size capacity plants. Upgrading of food processing plants will depend on risk-analysis according to Regulation (EC) No. 178/2002 of the European Parliament and of the Council laying down the general principles and requirements of food law, establishing the European Food Safety Authority, and laying down procedures in matters of food safety. Further special requirements are laid down by “the hygienic package”. This system of upgrading is in competence of member states (except of some special measures of the European Commission) and so the Food Office of Ministry of Agriculture is responsible in the Czech Republic.

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connection to support the improving of self-control system (HACCP). These programmes of subsidies were utilised and appreciated especially in 2003. One of these subsidies tools was the pre-accession program SAPARD. The main goal was to support the implementation of the systems SAPARD and HACCP in approximately 100 companies, which had to use SEUROP system, 26 milk products producers, 190 meat processing plants and 16 poultry slaughterhouses. Total number of projects was 272. 227 (83%) of this number was accepted (11 - SEUROP, 216 – HACCP). Total programme amount was 365 222 808 CZK. The effectiveness of establishing HACCP was very satisfactory and reached 100% in dairy sector and 42% in meat processing sector. The results of applicants’ inquiry are:

• 54,7% of recipients were highly depended on SAPARD; •

30% of recipients were only marginal depended on SAPARD;

PROGRAMMES OF SUBSIDIES

• 7,5% of recipients were intended to invest

In the period 2002 – 2003 the Ministry of Agriculture of the Czech Republic set up programmes of subsidies. The main reason was to support the increase of hygiene conditions in the companies of food industry. These programmes had direct

in any case;

•

66% of companies fulfil EU standards in food quality in dependence on SAPARD in general the quality of products increased.

Table – Number of projects Classification

Total number of projects

Number of approval projects

A meat

94

80

Aa improvement of hygiene conditions of employees

7

6

B milk

42

35

Ba improvement of hygiene conditions of employees

5

3

C other

69

58

D no classification

40

34

257

216

Total

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The introduction of SEUROP classification of carcasses and of the HACCP system within the measure on improving the quality control and consumer protection was also highly relevant as it aimed to strengthen and competitiveness and thus the sustainable development of the foodstuff sector. The sub-measure concerning HACCP was very effective, in particular concerning the milk sector, whereas the sub-measure introducing the SEUROP system failed completely (effectiveness 5%). The lack of interest in the latter resulted on one hand in a non-optimal timing of the Programme launch regarding the national effective legislation and on the other hand in an existence of national funding scheme covering 100% of cost for purchase of the SEUROP system whereas the SAPARD programme offered solely 50% of co-financing from public funds. Thus the majority of producers during the implementation of the SAPARD Programme the SEUROP system had already established and only a small number of producers who intended to replace the current established system for a SEUROP system entered into the SAPARD Programme. Therefore the low participation in this sub measure had no consequences on the preparedness of the Czech producers for the EU membership.

POLICY OPTIONS FROM THE SIDE OF FOOD BUSSINES OPERATORS

•HACCP system was mandatory established. There are some deficiencies especially in HACCP system in different establishments. The reality is that some small establishments „have“HACCP system but a question is how it is functional. The situation is difficult especially in small establishments (for example retail). It is possible to say that small establishments have only regional effect and thus relatively low risk of adverse effect on public health. This resulted in lower frequency of official controls and low possibility

CZECH REPUBLIC

to improve HACCP system. One of the possible reasons is misunderstanding by food business operators. Food business operators do not see HACCP system as one useful tool for improving hygiene and safety of food. They consider it as further bureaucracy tool and excessive work. This is the situation which has to be changed. The future is probably „hygiene package“ and its „flexibility approach“. There is as well a long way of training and education before us.

•Application on last possible date is one possible point of view of some food business operators on the new situation – mandatory approval and registration. Most probably the reason of such situation was to gain utmost time for improvement of hygiene conditions in establishments. The other reason could be to wait for other establishments and do not call the attention on theirselves. Last but not least there is possibility to gain some advantage from the lack of time of the competent authority (most of the establishments applied for approval in December – DVI were overloaded by work). •SAPARD - and other subsidies. There was a great interest in the possibility to gain subsidies, and thus possibility to improve hygiene conditions in the establishments. Many of the subsidies (SAPARD, subsidies from the MA) provided money for the establishment of HACCP system. The reality was that the establishments had their HACCP systems (it was mandatory). But the subsidies were a very good tool to improve hygiene conditions and the improve HACCP systems (not to introduce). Improvement of hygiene conditions in establishment and improvement of HACCP system which can be more useful and more accurate is a continual process.

•Reclassification of HC to LC Reclassification of high capacity to low capacity was one of the policies of some establishments before the accession to the EU. It was clear that to fulfill the EU requirements was more difficult and expensive than to fulfill national requirements.

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

The policy of reclassification is still in mind of some of our food business operators. Some of food business operators who applied for transitional period and are listed as establishments in transitional period in the Accession Treaty wanted to change their intent. They subsequently decided to operate only within the Czech market and wanted to be removed from the list of establishments in transitional period. The European Commission did not approve such actions. The point of view of the European Commission was to grant a longer transitional period. Approval of reclassification is a not acceptable model especially with the date of 1.1. 2006 - From this date the „hygiene package“ is applicable, and this regulation do not mention high or low capacity establishments. FROM THE SIDE OF PUBLIC ADMINISTRATION

•Reorganization of SVA - The structure of the SVA was changed in July 2003 and now has 14 RVA. There is a direct line of command from the CCA through the RVA to the 73 District Veterinary Inspectorates. District Veterinary Inspectorates are responsible for inspections and monitoring of Health Protection and Food Hygiene. •Binding declaration As early as one year before accession to the EU there were lots of questions about the establishments and their mandatory approval. It was clear that the establishment have to be in compliance with EU legislation. The problem was that some of the food business operators were not able (and did not want) to affirm that their establishments will be in compliance with the EU legislation before accession (SVA have informed about this obligation since 1999). Thus the SVA elaborated „Binding declaration“for food business operators. The object of this declaration were three questions: 1. Deadline of establishment for compliance with the EU legislation, 2. If there is no intent to comply with the EU legislation, what is the date of end the activity of the establishment, 3. Intent to trade within the EU market or only within the

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Czech Republic. If there is an intent to reclassify from high capacity to low capacity – what is the date of this change. But the reclassification of high capacity establishments to low capacity has constituted a serious economical problem for establishments.

•Three-stage control system The three-stage control system was put in place by the SVA since January 2004. The three-stage come from the organization chart of SVA (SVA - RVA - DVI). The main aim was to supervise the regions control activities. The result is a system well leading to a more harmonized approach and ensuring that the data received at central level from the regions is more accurate. At the beginning there was a recommendation from the European Commission to improve system of internal control within the SVA. The main goal was also to re-evaluate all the establishments prior the accession to the EU. In the framework of the three-stage control the SVA carried out supervision of the regions control activities. The controls took place on the spot together with a local veterinary inspector form the DVI in charge of the establishment and a regional inspection team headed by the chief public health inspector from the relevant RVA. The three-stage control system was subsequently audited (a fourth level of inspections) by the Ministry of Agriculture of the Czech Republic. The main aim was to further ensure the compliance with the relevant EU requirements and that a harmonized approach is indeed being followed by SVA and the various RVAs. There were some minor deficiencies in this system but in general the three-stage system was considered to be in place and to be useful. As one of its special functions we can consider the responsibility - three-stage responsibility.

•Comprehensive

national training programme Visits of FVO to the Czech Republic before accession have identified some deficiencies and called for an improvement of the system of training of SVA inspectors (including principles of HACCP system and official controls of this

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24

system). In spite of the existing plan of education and training, the European Commission recommended to elaborate a new conception for system of education and training of veterinary inspectors. SVA took it into account very seriously. The new centre for training and education was built in Prague. Considerable amount of money come from PHARE projects (for example money for improvement of informatics and technical equipment for laboratory testing – it was more than 50 mil. CZK). The regular training of veterinary inspectors and other staff of SVA were planned in advance (as early as the new centre was under construction). At present the education and training programmes are in full stream. There were also number of training sessions at different locations involving TAIEX experts and on-site visits.

CONCLUSIONS AND POLICY RECOMMENDATIONS

•Do not try to hide any shortcomings. If the visit of the European Commission reveals such action, you will be the side who will act much more. The FVO visit held in January 2004 to the Czech Republic prior to accession had revealed severe shortcomings in the upgrading, but many establishments were approved without being fully in compliance with all the relevant EU requirements. The results for the Czech Republic were as follows - three-stage control system, more extensive use of standardized checklists, re-evaluation of establishments (after their initial approval in December 2003) and the action taken to correct outstanding deficiencies prior to the date of accession. The result was already mentioned: 7000 official controls in nearly 3500 establishments, and 81 establishments closed (after their previous approval).

•To have an unified approach An FVO visit to the Czech Republic identified a significant variation between the approaches taken by the different RVA to the upgrading procedure. Due to the serious shortcomings there was recommendation of the FVO to re-evaluate all establishments and consider establishing an improved system of on-the-spot controls. This was the basis for introducing the three-stage control within the SVA and comprehensive national training programme.

•Do not underestimate details Visit of the FVO (subsequent to January 2004)found out our establishments satisfactory or less satisfactory - most of the establishments visited were in compliance with the EU requirements with only minor shortcomings identified. However, in one of the six establishments visited, some of the previously identified deficiencies had still not been rectified and full compliance had therefore not been reached.

•To have a comprehensive national training programme

•To have a flexible approach

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

SOURCE OF INFORMATION Comprehensive monitoring report on the Czech Republic’s preparations for membership Annual report of activity SVA to the MA 2003, 2004 Annual report of activity CAFIA to the MA 2003, 2004 National review on the SAPARD Programme in the Czech Republic, 2004 Summary report of the Ministry of Agriculture of the Czech Republic, 2003 The strategy to assure food safety in the Czech Republic, 2005

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Reports of the missions carried out in the Czech Republic by the European Commission (DG SANCO) 2003-2004 www.svscr.cz www.szpi.gov.cz www.mze.cz www.mzcr.cz www.ukzuz.cz www.bezpecnostpotravin.cz www.uzpi.cz www.foodnet.cz

Panorama Potravinarskeho prumyslu, 2003

www.milcom.cz

Situační a výhledová zpráva MZe (Mléko a mléčné výrobky + hovězí a vepřové maso), 2003, 2004

www.vuze.cz

Report on upgrading establishment processing raw material or producing products of animal origin 2003, 2004 Organization chart of the Ministry of Agriculture (updated) Historie Mlekarenstvi a Cechach, na Morave a ve Slezku, 2001 All relevant legal regulations Working documents for comminication between the Ministry of Agriculture and competent authorities The Act of Accession of the Czech Republic to the EU, 2003 Collection of the Czech law Official Journal of the EU Agricultural Import Regulations and Standards Country Report, 2004

www.vupp.cz www.agroweb.cz www.mvcr.cz http://europa.eu.int www.europeum.cz www.ciaa.com

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SHORT RESUME OF THE AUTHORS BIBIÁNA JANÁČKOVÁ Date of Birth: 15. 10. 1974 Education and Examinations: - University of Veterinary and Pharmaceutical Sciences Brno, Faculty of Veterinary Hygiene and Ecology - the degree of MVDr. In 1999 - Masaryk University, Faculty of Education the degree of Bc. (bachelor of social pedagogy) in 2003 - Since 2000 post-graduate study in etology (uncompleted) - Since 2005 post-graduate study in food legislation area Employment Record: - SVA CR - District Veterinary Administration in Ústí nad Orlicí: from 1999 till 2003 (inspector on food hygiene) - Ministry of Agriculture of the Czech republic - Food production department – since October 2003 (head of unit of food legislation and standardisation within food production department since January 2004, deputy headmaster since April 2004) Special Seminars and Trainings f.e.: Keystone seminars by the American Chamber of Commerce (2004), Food Safety Service Benchmarking Project – 2005 (conference in Brussels and workshop in the UK), Internal auditor of HACCP system, quality and environmental management system

PETR DOLEŽAL Date of Birth: 24. 1. 1974 Education and Examinations: - The Czech University of Agriculture, Faculty of Agronomy, Prague - the degree of Ing. In 1998 - The Czech University of Agriculture, the European Agrarian Diplomacy (19982001). - International Agricultural and Horticultural Intern Program, The Ohio State University, Ohio, USA (1999-2000) - Since 2000 post-gradual study in animal nutrition sciences (uncompleted) Employment Record: - Institute Tropical and Subtropical Agriculture, Animal Department, Prague (19981999) - Ministry of Agriculture of the Czech republic, European Integration Department (head of the working group for beefmeat, sheepmeat and goatmeat- 2001), Animal production department –since April 2001 Special Seminars and Trainings SEUROP carcase classification certificate for control body (2004) in CZ

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

ANNEX I. GOVERNMENT REGULATORY AGENCY CONTACTS Czech Government Contacts: Trade Policy: Ministry of Agriculture Trade and 3rd Countries Relations Department Ms. Marta Tepla Head of Department Tesnov 17 117 05 Praha 1 Tel: +420-221-812-736 Fax: +420-221-812-965 E-mail: [email protected] www.mze.cz Food Safety: Ministry of Agriculture Food Safety and Living Environment Department Dr. Milena Vicenova Head of Department Tesnov 17 117 05 Praha 1 Tel: +420-221-812-937 Fax: +420- 221-812-965 E-mail: [email protected] www.mze.cz Food Production and Legislation: Ministry of Agriculture Food Production and Legislation Department Mr. Jindrich Fialka Head of Department Tesnov 17 117 05 Praha 1 Tel: +420-221-812-465 Fax: +420-224-810-652 Legislation on Biotechnology: Ministry of Environment Environmental Risks Department Mr. Karel Blaha Head of Department

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Vrsovicka 65 100 10 Praha 10 Tel: +420-267-122-532 Fax: +420-267-310-013 E-mail: [email protected] www.env.cz Exceptions in Food Additives: Ministry of Health Dr. Michael Vit Deputy Minister and Chief Hygienist for the CR Palackeho nam. 4 128 01 Praha 2 Tel: +420-224-972-431 Fax: +420-224-915-996 E-mail: [email protected] www.mzcr.cz State Health Institute Center for Hygiene in Food Chain Dr. Jiri Ruprich Chief Hygienist Palackeho 1-3 612 42 Brno Tel: +420-541-211-764 E-mail: [email protected] www.szu.cz E-mail: [email protected] Wine Legislation: Ministry of Agriculture Food Production Department Mr. Antonin Kralicek Head of Department for Wine Tesnov 17 117 05 Praha 1 Tel: +420-221-812-104 Fax: +420-222-812-367 E-mail: [email protected] www.mze.cz

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ANNEX II. OTHER IMPORT SPECIALIST CONTACTS Plant Health and Pesticides: State Phytosanitary Administration Department for Plant Protection Products Mr. Stepan Kuzma Head of Department Zemedelska 1a 613 00 Brno Tel: +420-545-137-039 Fax: +420-545-137-031 E-mail: [email protected] www.svs.cz Animal Health, Meat Inspection and Import Certificates: State Veterinary Administration Dr. Milan Malena General Director (CVO) Slezska 7 120 56 Praha 2 Tel: +420-227-010-142 or 143 Fax: +420-227-010-191 E-mail: [email protected] www.svscr.cz Food Inspection (other than veterinary): Czech Agriculture and Food Inspection Authority Mr. Jakub Sebesta General Director Kvetna 15 603 00 Brno Tel: +420-543-540-111 Fax: +420-543-540-210 E-mail: [email protected] www.szpi.gov.cz GMO Product Certification and control of feedstuffs: Central Institute for Control and Testing in Agriculture (UKZUZ) Mr. Jaroslav Stana Director

CZECH REPUBLIC

Hroznova 2 656 06 Brno Tel: +420-543-548-271 E-mail: [email protected] www.ukzuz.cz SEUROP clasification and controls body Central Institute for Control and Testing in Agriculture (UKZUZ) Mr. Emil Marecek Director Za opravnou 4 150 06 Praha 5 - Motol Tel: +420-257-294-240 Fax: +420-257-294-239 E-mail: [email protected] www.ukzuz.cz Control and Certification of Organic (Bio) Products: KEZ (Control of Ecological Farming) Certification Department Ms. Jana Bauerova Head of Department Podebradova 909 537 01 Chrudim Tel: +420-469-622-249 Fax: +420-469-622-249 E-mail: [email protected] www.kez.cz Trademark Office: Industrial Property Office Mr. Karel Cada Chairman Antonina Cermaka 2a 160 68 Praha 6 Tel: +420-224-313-245 Fax: +420-224-313-249 E-mail: [email protected] www.upv.cz

ESTONIA

CONFERENCE PAPER OF ESTONIA “FROM FARM TO FORK: EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS”

Author TIINA SARON

FROM FARM TO FORK

30

ESTONIA

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

LIST OF ACRONYMS AND ABBREVIATIONS

BIP

border inspection post

EU

European Union

EPPO

European and Mediterranean Plant Protection Organisation

FAO

Food and Agriculture Organisation

HACCP

Hazard Analysis Critical Control Point

ISTA

International Seed Testing Association

NPAA

National Plan of Adaption of the Acquis

MIS

Market Information System

OIE

World Organisation for Animal Health

WTO

World Trade Organisation

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ESTONIA

INTRODUCTION

FRAMEWORK ANALYSIS

In recent years food safety and food quality have been the issues increasingly dominating public and political debate. A major reason for this is the tremendous development that the entire food sector has gone through both in terms of technology and production. At the same time the debate has also questioned whether the consumers’ demands and expectations are being met. Food safety and quality are of the greatest importance for the consumers and their sensibility in that respect is very high. There is no doubt that the safety of foodstuffs has the absolutely highest priority for every government but food safety issues are also crucial in trade.

1. Short review of the national legislation in the area: the existing administrative, inspection and control mechanisms and the level of approximation with the food safety acquis.

The conclusion of a Free Trade Agreement and the accession procedure with the EU has highlighted the fulfilling of the technical requirements set for processing of agricultural products in Estonian food industry. Achieving a standard of food safety is necessary for the development of internal and external markets. The respective Legal framework and appropriate supervising system must be created. Harmonisation of the acquis communautaire and particularly meeting the technical requirements demand substantial investments, but as a result the opening of EU internal market is possible. The aim of this paper is to share the Estonian experience in implementation and enforcement of the veterinary and food safety acquis. The paper consists of three parts. The first part describes the creation of food safety legislation and supervision system. The second part concentrates on the analysis of the level of meeting the EU production and processing requirements in Estonian dairy and meat industry, also the amount of investments needed to achieve the fulfilment of the requirements is evaluated. In the third part policy options for implementation and enforcement of the veterinary and food safety acquis applied by Estonia are described.

Until 1992 Soviet quality standards were applied in Estonia. Quality control was exercised by the veterinary control system and the health control system. The veterinary service controlled animal health as well as slaughtering and meat processing enterprises. The health control service was responsible for inspection of all processing enterprises (incl. food of animal origin) as well. For food processing companies it meant double control. In the beginning of 1990’s Estonia became a member of several international organizations. As a result, Estonia introduced the standards laid down by the following standard setting organizations: FAO (Codex Alimentarius), OIE, ISTA and EPPO. In accordance with these international standards a new food control system was introduced in Estonia. The first law was the Veterinary Service Act which was passed in 1992 and which set up the veterinary control system. There was no border control between republics of the former USSR during the soviet regime. Under the Veterinary Service Act a system of border inspection has been established at eight points along the Estonian border. Main objective of that was to control trade in live animals and animal products. The overview of the concrete food-safety measures implemented by Estonia is given in a table in annex 1. At the beginning of 1994, the Consumer Protection Act was passed to ensure protection of consumers. The Food Act was passed in 1995 after two years of preparation. Under this law, Ministry of Social Affairs established the Food Board in 1995 and

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

the Food Policy Council chaired by the Minister of Agriculture was set up in 1995. The Food Policy Council co-ordinates food policy and the corresponding control. The food control system was reorganized in 1996 and the Ministry of Agriculture took over the coordination and responsibility for food control. (annexes 2-3) Food safety control in Estonia Several authorities are involved in the food quality and safety control in Estonia. Three ministries share the responsibility for food control: 1) Ministry of Agriculture •Veterinary and Food Board and regional units •The Border Service of the Veterinary and Food Board and border (veterinary) inspection posts (BIP) •Veterinary and Food Laboratory with regional units •Plant Production regional units

Inspectorate

and

•Border (phytosanitary) control points •Control Centre of Plant Production 2) Ministry of Social Affairs •Health Protection Inspectorate regional units with laboratories

and

•Central Laboratory of the Health Protection Inspectorate 3) Ministry of Economic Affairs •Consumer Protection Board and regional consumer protection inspectors Ministry of Agriculture is responsible for drafting legislative acts and co-ordinating co-operation on implementation of legislation between different food control authorities. The Veterinary and Food Board supervises veterinary activities, animal health, animal welfare and food safety from farm

33

to the wholesale sector, including transportation and controls on the state border. The Health Protection Inspectorate is responsible for the supervision of the catering and retail sector. The Consumer Protection Board carries out market surveillance of foodstuffs, which includes labelling and conformity of the composition of food to labelling requirements. The Plant Production Inspectorate is responsible for surveillance of the plant protection, plant health, feeding stuffs and organic farming. Estonia submitted its application for WTO membership in March 1994 and became a member in November 1999. In general, the impact of the WTO on harmonisation of policies was much smaller than the impact of the the accession to the EU. In July 1994, a free trade agreement was signed between Estonia and the European Union, which came into force on 1 January 1995. The Europe Agreement, which was signed in June 1995, took over the trade concessions of the Free Trade Agreement. The Europe Agreement gave Estonia the status of associated country with the EU and envisaged Estonia’s full membership to the EU. The EU membership was the main strategic objective of Estonia for coming years. That was the base for future planning, in broad terms meaning the harmonisation of legislation with that of the EU. A detailed plan was laid down in the National Plan of Adoption of the Acquis (NPAA), first set up in 1996 and updated in all subsequent years before accession. In the agricultural sector, the most strategic one was that of 1998, where policy alignment was projected. The target date defined for Estonian accession was 01.01 2003. All plans were designed in this light (annexes 4 -5) The accession procedure and trade with the EU has highlighted the fulfilment of the technical requirements set for processing of agricultural products in Estonian food industry. Meeting the technical requirements demands enormous investments and as a result the open-

FROM FARM TO FORK

ESTONIA

34

ing of the EU internal market is possible. It is important to achieve optimal level of investments and it is irrational to invest in unutilised processing capacity. 2.2.Background of the production and processing of agricultural products Estonia has long traditions in producing milk and meat products. The production model of the Estonian agriculture that was oriented towards livestock production developed since the 2nd half of the 1960’s on the basis of the so-called industrial principles, which aimed at concentrated production and increased productivity. There were for instance 300 000 cows and most of the cows were kept in stables housing 200-600 cows.

sidiaries) involved in milk processing. The meat processing industry consisted of 10 companies. After the privatisation of state enterprises the number of enterprises rose rapidly. Many of the state enterprises had also subsidiaries that were privatised separately. In the Soviet period, the farm structure was largely based on herds of 100-400 cows and this size range continues to dominate the structure of dairy herds. The production is still concentrated to big agricultural enterprises. Estonia has fairly long traditions in improving raw milk quality. High quality of raw milk was essential not only because of EU accession, although the EU regulations set very clear and tough requirements for the whole chain of milk production including the raw milk production.

Structure and development of dairy sector in 1989-2004 (share in %) Share of milk processing in food industry Share of dairy products in food exports

1989 34 NA

1992 21 NA

1996 26 33

2000 28 28

1996 15 2,3

2000 16 8,0

2003 26 20

2004 32 22

Source: Estonian Statistical Office

Structure and development of meat sector in 1989-2004 (share in %) Share of meat processing in food industry Share of meat products in food exports

1989 35 NA

1992 23 2NA

2003 18 9,6

2004 19 9,4

Source: Estonian Statistical Office

Exports of livestock production accounted to 35-37% of total production in the end of 1980’s. Estonia supplied some of the biggest cities of the Soviet Union. After re-gaining of the independence in 1991 agricultural production declined significantly. According to the general tendency in agriculture milk production decreased by half and meat production by 2/3 compared to production amounts at the beginning of nineties. In the Soviet period milk and meat processing was concentrated in large-scale agro-processing facilities. Immediately before the reform process there were only nine companies (incl. 20 sub-

The quality of raw milk has a very definite effect on the quality and financial return from products made from milk. The first raw milk standard was composed in 1994 and became a basis for milk classification according to the total number of bacteria and somatic cells. The standard became compulsory to be followed by purchase of raw milk in 1995. The quality of milk has significantly improved through the last years. This has been possible due to raw milk quality testing by enterprises and improvement of milking and milk collection equipment. 97% of all milk delivered to dairies meets the raw milk requirements of the EU.

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

35

Structure and development of dairy and meat enterprises and production in 1989-2004

Number of dairies Production of raw milk (th t) Delivered to dairies (th t)

1989 9 1277 790

1992 12 919 542

1996 28 675 490

2000 44 629 395

2003 41 596 483

2004 42 640 538

Number of meat enterprises Production of meat (th t)

8 190

18 108

245 59

261 53

135 68

139 66

Quality of Raw (% of delivered milk of respective)

Source: Estonian Statistical Office

In the meat sector most of the slaughterhouses were established in the middle of 1960s. The dairy industry was generally in better shape than other parts of agro-processing sector. The main problems in Estonian meat and dairy processing enterprises remained meeting the requirements for premises: presence of suitable working rooms, stores and clothing rooms, acceptable construction of walls, floors, ceil-

ings and doors and use of acceptable finishing materials inside the premises. Often the enterprises were lacking of freezing stores for output, and rooms for storage of aid materials. Most of the production facilities were built in 1960’s using the building and finishing materials of that time. Many big and small size enterprises were adjusted to new needs, but the main problem was the layout of production rooms, which often did not allow continuous production processes

FROM FARM TO FORK

36

nor avoided the danger of cross contamination. Later, building new processing plants had somewhat decreased the problem. One of the problems was also the lack of modern equipment and production lines. Additionally, there was no rendering system in Estonia meeting the EU requirements. Although some meat plants had their own rendering departments, the problem of hazardous biological wastes of agricultural production and processing was unsolved in the context of the whole country. Generally, more factors were influencing the development of Estonian food processing industry. Most important was the upgrading of enterprises to meet the EU production and processing requirements and necessary investments. Obviously, there was a need for restructuring of different food processing sectors to ensure competitiveness and efficiency, and taking into account the forecasted amounts of raw materials in meat and particularly in dairy sectors. In 1998, HACCP-based self-control system had been introduced to almost the whole food sector and many enterprises had made the first steps in the development of the system. Dairy industry was the first sector, were the development and implementation of HACCP-based self- control system was started in the framework of a EU Phare project in 1996. That work was carried forward by another Phare quality management project in meat, dairy, fish and bakery industries. The main objective of these projects was to raise awareness of and interest in quality management systems compatible to EU standards and change in management’s logic. These projects focused on the HACCP-system. In both projects producer organisations played an important role. The project team trained theoretically and on-the-job – Estonian experts and organisations with the result, that three organisations (Dairy Association, Meat Association and Bakery Association) were ready to offer advice and practical assistance to companies. One local expert prepared a HACCP handbook with practical guidelines to

ESTONIA

understand and implement the HACCP-system in the food processing industry. 2.3. Estonian experience. Possible models for upgrade of food processing enterprises. In 1999, a survey was arranged with the purpose to find out the level of conformity to the requirements of the EU and the needs for investments, in order to meet the requirements and possible effects that the investments would have on the development dairy and meat enterprises. The direct method is used to evaluate the impact of technical measures. The data originates from questionnaires filled by the companies, interviews with the entrepreneurs and expert appraisals. A similar survey was repeated in 2000. About 60% of the enterprises participated in the survey. (annexes 6-9) 2.3.1. Compliance of dairy enterprises to the EU requirements and calculation of needed investments In 1999, only one dairy plant met the requirements of the EU. One enterprise fulfilled the requirements about 99% and the rest of enterprises reached the level of approximately 20 to 70%. Compliance to the requirements was very low among low capacity enterprises: between 20 to 25%. Considering the results of the survey and expert opinions, the amount of necessary investments was calculated. Forecast was made by groups of requirements and separately for high and low capacity enterprises (annexes 6-7). According to the expert opinions, the total need for investments of all existing dairy enterprises was approximately 65 mln Euro. It is important to make optimal investments and distinguish necessary investments considering the existing processing capacity. According to estimations, approximately 900 000 to 1 000 000 tonnes of raw milk could be processed annually by Estonian milk processing

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

37

Compliance of dairy enterprises to the EU requirements in 1999

Source: MoA, expert opinon

plants. High seasonality (1:2 as an average) also affected capacity utilisation: excess capacity must be reserved for the peak season. Despite of that, it was clear that the over-capacity was nearly 400 000 tonnes.

ther investments in non-complying capacities would have not been rational. Amount of optimal investments in dairy sector would have been approximately 37 mln Euro.

In 1998-2001 the utilisation of existing capacities has remarkably improved. Ten fully complying dairy plants collected 80% of raw milk delivered to dairies and utilised approximately 70% of existing processing capacity in 2001. The enterprises that complied 60% or more, utilised 40% of processing capacities.

2.3.2.Compliance of slaughterhouses and meat enterprises to the EU requirements and calculation of investment needs

The compliance of the remaining dairy enterprises was estimated to be below 60%, utilisation of processing capacities below 20% and investment needs in both groups amounted to 28 mln Euro. Considering the continuous under-utilisation of the complying processing capacities it can be concluded that investments in technical requirements have exceeded optimality and fur-

In reality, investments continued and the total amount of investments in milk processing sector in 1999-2004 was 71 mln Euro.

In 1999, there were no fully complying slaughterhouses and meat products producing enterprises in Estonia. The compliance of the two high-capacity slaughterhouses was approximately 80% but the use of the existing production capacities was very low (20-30%). According to the expert opinions, the total need for investments of all existing slaughterhouses and meat enterprises was approximately 77 mln Euro.

FROM FARM TO FORK

38

ESTONIA

Utilisation of capacities, share on raw milk market and investment needs in dairy enterprises in 2001

Compliance of slaughterhouses and meat enterprises to the EU requirements in 1999

Source: MoA, expert opinion

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

39

Compliance to the EU requirements, use of capacities and investment need in slaughterhouses in 2001

Source: MoA, expert opinion

Existing slaughtering capacity of the three biggest slaughterhouses was approximately 330 thousand animal units. Slaughtering in Estonia was approximately 125 thousand animal units; therefore the mentioned capacity covers the need of the sector and also leaves room for possible increase in meat production. The amount of investments needed to bring optimal slaughtering capacity into compliance with the EU requirements was estimated to be 7 mln Euro. It was thus possible to save 22 mln Euro at the expense of less than 50% complying slaughtering capacities. The share of meat products producing companies on the market is important when assessing optimal investment needs. The share of five large capacity meat products producing companies at the meat products mar-

ket was approximately 75%. The compliance of their plants was above 70% and investment needs 7,7 mln Euro. Market share, compliance to the EU requirements and investment need in meat processing enterprises in 2001. The remaining 25% of meat products’ market was divided between six large capacity and nearly 40 small capacity enterprises. According to the EU internal market regulation the market for the production originating from small capacity plants was constrained with the nation’s territory. Considering both the market share and the speed of bringing the processing conditions into compliance with the technical requirements, the amount of optimal investments in small capacity plants could be estimated to be 3 mio euro and it would have been possible to save 17 mio euro on account of large capacity plants.

FROM FARM TO FORK

ESTONIA

40

Market share, compliance to the EU requirements and investment need in meat processing enterprises in 2001

Source: Statistical Office of Estonia

The compliance of the whole meat-processing sector would have been achievable with significantly lower expenses than estimated in 1999. The necessary optimal investments for the meat processing sector’s full compliance with the EU requirements remain in the boundaries of 32 mio euro, 18 mio euro of it was estimated to be necessary to make before accessing the EU. The major part of the investments made in Estonia’s dairy and meat sectors over the last years has been used for improving the production and processing conditions and increasing the efficiency of production. This is mainly caused by Investments in Dairy and Meat Industry (mln Euro) Sector Dairy Meat

1999 9,75 5,47

2000 6,36 3,47

Source: Statistical Office of Estonia

2001 16,07 5,61

the accession to the EU, but also by the fierce competition on the domestic market, which has induced the companies to focus more on satisfying the demand of the consumers and ensuring a stable quality of foodstuffs. The availability of SAPARD since 2001 has also strongly contributed to the growth in investments. Out of total investments in meat and dairy sector 21% and 11% respectively were supported by SAPARD. After the accession to the EU, SAPARD was terminated, but in 2004 it was replaced by the Investment Support for Improving Processing and Marketing of Agricultural Products under the National Development Plan, to be financed from the EU structural fund (EAGGF). 2002 13,6 12,01

2003 17,11 13,0

2004 8,43 8,9

1999-2004 71,32 57,4

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

41

2.4. Expenditures of the Harmonisation

POLICY OPTIONS

For the estimation of expenditures the necessary funds were calculated in all sectors of agriculture, including the sector of veterinary medicine, food processing and animal welfare (annex 1). The initial estimate for the creation of necessary structures in the administrative field was done (annex 2)

In the second half of the 1990s, Estonia (as many of the CEECs) moved on efficiency concerns, institutional reforms and needed to develop appropriate strategies for accession to the European Union. Estonian policy was dependent on the international agreements Estonia had concluded during the time of independence. The two most important ones were the European Agreement and WTO membership agreement. The EU has become the main trading partner for Estonia and preferential tariff quotas for agricultural products have been agreed in quantities covering the bulk of Estonia’s export potential.

Source: MoA, expert opinion

In general, WTO’s impact on harmonisation policy was much smaller than the impact of the accession to the EU. An important pre-condition in fulfilling the quota was complete conformity of processing conditions to the requirements set in the EU directives, which is especially important in processing food of animal origin. Therefore the quotas increased the incentives for enterprises to fulfil the food safety requirements to actually benefit from exports. Furthermore, the access to the EU market was attractive for the enterprises because of the higher price level and higher margin. EU membership was the main strategic objective of Estonia for coming years. The target date defined for Estonian accession was 01.01 2003. All plans were designed in this light and in principle Estonia was ready to meet all requirements even those of environment and did not apply for transition periods in order to gain the opportunity of unlimited access to the common market of the EU. However, in the scope of the association agreement with the European Union Estonia took an obligation to accept all policies and objectives of the EU without any reservations. That obligation had the main impact on the preparations of legislation and control systems.

FROM FARM TO FORK

42

Yet, the accession procedure with the EU has highlighted the fulfilling of the technical requirements set for processing of agricultural products in Estonian food industry. Further production of food both for Estonian and EU market as well as exports to other countries are directly depending on it. A special feature of Estonia is, that all processing facilities are EU fit without a transition period for adapting the EU food safety requirements. Only Cyprus is in the same position. Generally speaking Estonia fulfilled the main goal to join EU without any transitional period. Meeting the technical requirements demands substantial investments and as a result the opening of EU internal market is possible. It is important to achieve optimal level of investments and it is not rational to invest in unutilised processing capacities. Estonia was unfortunately not able to reach this goal, as in some sectors investments were not made in time; in others there were a lot of over-investments. On one hand, food safety is the main priority of the government and of the food processing enterprises as well. All food operators have to take care of that and make necessary investments. On the other hand, the role of the government is to realise institutional reform and apply the legal framework in the field of food safety. Obligation of compliance with the food safety requirements directly influences the number of operating enterprises. As a matter of fact in the transition economies it is not easy to specify appropriate period and measures for implementing the requirements.

ESTONIA

CONCLUSIONS AND RECOMMENDATIONS To ensure that public health is observed through the food chain, a considerable public administration and control system must be set up. The general task of the state inspection of food is to guarantee consumer health safety and to make sure that the production, processing and labelling of foodstuffs, as well as the additives and equipment used, are in compliance with the food law. It is also important to prevent and avoid the risk to the consumer’s health, by ensuring the quality of food and by creating an adequate information system to avoid misinformation on foodstuffs. Food safety issues (incl. legislation and control system in place) are also crucial in trade because stable and well developed markets are protected by very strict sanitary and phyto-sanitary measures. In the context of the accession to these markets it is important to achieve compliance with optimal expenses. All operating food processing enterprises must meet the EU production and processing requirements but in reality it is important to make optimal investments and distinguish necessary investments considering the existing processing capacity. To avoid unnecessary investments a restructuring program for the food sector would be needed. There are two main measures the government can use to influence the situation. On one hand the food hygiene and safety requirements have to be announced as soon as possible with respective plan for harmonisation. After the time has expired the unfit enterprises should be closed. On the other hand enterprises could be supported in their efforts in implementation of food safety requirements When the EU market opens for Bulgaria after accession the food industry will have to compete with concentrated and efficient sector. There-

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

fore structural changes necessary to be competitive are essential in Bulgaria already before the accession. To make the necessary structural changes it is important:

•To follow the deadlines set in national legislation, to avoid further unnecessary investments;

•To use the possibilities of the pre-accession aid programmes in increasing processing efficiency and fulfilling environment requirements requiring big investments;

•To

foresee possibilities of alternative employment to solve employment problems resulting from closing of processing plants;

•To work out closing subsidies for companies that voluntarily decide to quit processing. Accession to the EU brings the opening of new markets and enlargement of trade possibilities, at the same time it also implies increased competition and a need to retain the position on the domestic market and to keep up with the changing preferences of consumers. In order to stand against the competition pressure, more attention should be drawn to marketing and promotional activities including market information system (MIS) and monitoring of consumer preferences.

43

FROM FARM TO FORK

ESTONIA

44

ANNEX 1 Measures on Estonian Export and Import to Estonia

1992

1995

1996

1997 1998

1999

20002003

Measures on export Measures on import Animal and plant health requirements Organization of veteterinary and phytosanitary control on border Annual and monthly reports on animal Regular information on animal health situation health to OIE and WHO/FAO from OIE Public health requirements for food- Import requirements (animal and public health) stuffs Import permission for live animals and for food of animal origin Food labelling requirements Ratification of CITES convension Approval system of enterprises for EU export List of approved enterprises Models of sertificates Residue monitoring programmes List of BIP-s List of goods under veterinary and phytosanitary control List of food additives Updated food labelling requirements Ratification of ATP-Agreement

Food labelling requirements

List of approved enterprises approved for export to Estonia Mutually recognized sertificates Residue monitoring programmes (food of animal origin) Licencing of food import enterprises

Control of list of food additives Control of food labelling Control of transportation conditions Control of non-animal origin foodstuffs on the border Updated list of BIP-s Residue monitoring programmes for foodstuffs Updated list of goods under veterinary, (food additives, mycotoxines, pesticides) food and phytosanitary control State levies Requirements for BIP-s (construction, Import permissions of GMO-s etc) Updated public health requirements Requirements for use of GMO-s Animal welfare requirements Harmonization of border control system with international standards

ANNEX 2

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

45

+

+

Animal Breeding Act

++++

1996

Intra-Community Trade Act

+

+

++

1997

+

1998 ++

1999

+ +*

+*

+*

+*

+*

+*

2000

2001

2002

+

+*

+*

+*

+*

2003

46

Feed Act

Anima Treatment Act

Seeds and Propagating Materials

Animal Welfare Act

Organic Production Act

+

Food Act

Plant Protection Act

+

+

1995

+*

++

1994

Veterinary Service Act

1993

+ +

1992

WTO Agreement

Free Trade Agrrments (10 countries + EU, EFTA)

Legislation

LIST OF MAIN LEGISLATIVE ACTS 1992-2003

ANNEX 3

FROM FARM TO FORK

ESTONIA

0,06 0,4

0,03 0,06

Veterinary Service Act, decree on veterinary education, licensing, sertification on veterinarians (90/424/EEC, 78/1026/EEC, 78/1027/EEC, 78/1028/EEC)

Animal Treatment Act, import requirements for live animals, requriements for the internal trade in animals, regulation of the prevention and protection against animal epidemics, animal identification and recording (85/115/EEC, 90/423/EEC, 80/217/EEC, 92/35/EEC, 92/66/EEC, 92/119/EEC, 90/425/EEC, 89/662/EEC, 89/608/EEC, 91/496/EEC, 90/657/EEC, 85/73/EEC, 64/432/EEC, 91/68/EEC, 90/426/ EEC, 90/539/EEC,91/67/EEC, 89/556/EEC, 88/407/EEC, 90/429/EEC, 92/65/EEC, 92/102/EEC, 92/438/EEC, 91/494/EEC, 80/211/EEC, 85/115/EEC, 82/894/EEC, 82/894/EEC, 77/96/EEC, 72/462/ EEC, 71/118/EEC, 64/433/EEC, 93/53/EEC, 91/495/EEC, 90/667/EEC, 72/461/EEC, 92/46/EEC, 94/65/EEC, 90/667/EEC, 91/497/EEC, 92/117/EEC, 94/968/EEC, 85/73/EEC)

0,42 1998

Total

Implementation General measures of inspection activities

Act on the Pedgree breeding of productive animals, animal recording, herdbooks, certificates (92/102/ 0,18 EEC, 94/515/EEC, 87/328/EEC, 84/419/EEC, 89/419/EEC, 89/502/EEC, 90/255/EEC, 96/78/EEC, 86/404/EEC, 89/506/EEC, 88/124/EEC, 89/503/EEC, 90/258/EEC, 93/623/EEC, 90/256/EEC, 90/257/ EEC, 89/507/EEC, 90/118/EEC, 91/174/EEC, 94/28/EC, 96/506/EC, 96/510/EC, 89/501/EEC, 89/504/ EEC, 90/254/EEC, 92/353/EEC)

0,15

1999-2000

0,9

0,12

0,18

Requirements for the medicaments used in animal health, for the feed supplements and feeds of curative effect, regirty of biopreparations, biostimulators hormones (90/423/EEC, 90/167/EEC, 91/412/ EEC, 64/432/EEC, 80/217/EEC, 92/119/, 85/115/EEC, 81/606/EEC, 96/22/EEC, 90/218/EEC)

Hygiene requirements for food of animal origin (64/433/EEC, 71/118/EEC, 77/99/EEC, 83/201/EEC, 85/73/EEC, 88/409/EEC, 89/362/EEC, 89/384/EEC, 89/437/EEC, 89/662/EEC, 91/492/EEC, 91/493/ EEC, 91/495/EEC, 91/497/EEC, 91/684/EEC, 92/5/EEC, 92/54/EEC, 92/46/EEC, 92/47/EEC, 92/48/ EEC, 92/116/EEC, 92/117/EEC, 92/118/EEC, 93/118/EEC, 95/68/EEC, 94/71/EC, 95/23/EC, 95/71/EC, 96/23/EC, 96/43/EC)

0,14

Animal Protection Act, transportation requirements, animal protection in slaughtering, requirements for keeping animals and poultry, experiments on animals and experimantal animals (88/306/EEC, 78/923/ EEC, 88/166/EEC, 91/629/EEC, 91/630/EEC, 91/628/EEC)

1999-2000

Legislation

1998

Necessary funds, mio EEK

What Estonia has to do?

Factor

NATIONAL PLAN OF ADAPTION OF ACQUIS – THE SECTOR OF VETERINARY MEDICINE

ANNEX 4

2001-2002

2001-2002

Total

1,32

0,18

0,27

0,18

0,14

0,46

0,09

Total

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

47

Optimization of the work of the Veterinary and Food Inspection, making its work more efficient of the inspection staff, incl the meat control inspectors to the staff of the Veterinary and Food Inspection, increase the staff of food control inspectors · Improvement of the qualification of inspectors, training programmes · Improvement of technical equipment for inspectors · Application of state residue monitoring programmes for the food of animal origin · A and B group animal disease observation programmes · An observation programme to detect cattle, pig and sheep infections in estonian hoofed game · Elaboration and implementation of prevention programmes for rabies · Implementation of food safety observation programmes (zoonosis)

of the pedigree breeding of buildings · Optimization of the work of the Pedigree Breeding Inspection · Training of inspectors · Existence of efficient pedigree breeding organisations and their approval · Required bedigree programmes · Approval of the milk analysis laboratory of animal recording centre, accreditation · Modernisation of equipment 0,4

4,0

12,0

0,5 2,7

1,2 0,2

0,6 1,0 0,2 6,0

6,23 2,0 4,5

0,2 0,2

0,6 0,6

14,0

25 2,0

20 1,2

20,0

0,6 8,0 8,5 1,0

1,0 7,5 6,8 0,8

1,2 0,4

1,6 1,6 0,2 6,0

6,23 2,0 4,5

4,0

46,0

45 3,2

2,1 18,2 15,3 1,8

48

5. Animal protection

of a separate unit with the employees of required qualification for the inspection of curative and hormone preparations in animal husbandry and veterinary medicine · Establishment and keeping of a medicament registry, as required · Training of specialists

· Establishment

4. Medicaments

of the existing processing plant approval system and registry, structuring processing plants according to their production volumes · Regulation of meat control in the state

· Improvement

3. Measures for processing industry

· Renovation

· Register

2. Animal identification, recording, pedigree breeding

addition to the existing telephone communication, establishment of a computer network, incl software, that will connect the Veterinary and Food Inspection with the county veterinary centres, vet Laboratories, border service, border inspection posts and the Ministry of Agriculture · Establishment of the local network of country veterinary service (LAN) and foreign connection (WAN), purchase of computers · Contingency planning

· In

1. Animal health measures

· Regulation

·

FROM FARM TO FORK

ESTONIA

Total in food sector, incl dairy farms

Implementation of hygiene requirements

Total expenditures for inspection

of control system as required of specialists

of the work of the BIP, making its more efficient of the number of BIP-s for the import of live animals and food of animal origin · Modernisation of BIP-s · Technical equipment, computer systems · Training of the staff

of dairy farms of used technologies and equipment · Harmonisation of meat processing plants, incl production rooms of cold-stores and slaughterhouses, technologies, the equipment used, storage conditions, transportation with the EU hygiene and structural requirements · Implementation of HACCP-system · Enivronmental requirements · Training of staff

Rendering system

Total in fish sector

455,0

1150,0

300,0

15,0 30,0 15,0

10,0 10,0 5,0 125,0

240,0

100,0

· Harmonisation

of fish processing plants, incl production rooms of cold-stores, used technologies, the equipment used, storage conditions, transportation with the EU hygiene and structural requirements · Implementation of HACCP-system · Enivronmental requirements · Training of staff

125,0

Total in dairy sector

260,0

20,0 30,0 10,0

10,0 10,0 5,0

290,0 200,0

of dairy plants, incl production rooms of cold-stores, used technologies, the equipment used, storage conditions, transportation with the EU hygiene and structural requirements · Implementation of HACCP-system · Enivronmental requirements · Training of staff

100,0

30,0 80,0 10,0

10,0 40,0 5,0 105,0

100,0 200,0 170,0

50,0 50,0 50,0

· Harmonisation

104,5

40,0 4,5 0,6

21,0

1,2 0,2

0,2

Total in meat sector

· Modernisation

· Reconstruction

· Optimization

· Optimization

6. Border control

· Training

· Establishment

711,0

201,0

8,3 30,0 15,0

148,0

150,0

20,0 20,0 10,0

100,0

210,0

40,0 80,0 10,0

65,0 85,0 80,0

53,9

16,0 1,5 0,5

0,2

2316,0

626,0

33,3 70,0 35,0

488,0

535,0

50,0 60,0 25,0

400,0

525,0

80,0 200,0 25,0

215,0 335,0 300,0

179,4

56,0 7,2 1,3

0,4

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

49

Total expenditures for harmonisation of veterinary acquis

Total

·

·

Preparation for international accreditation Implementation of reference and routine analysis methods · Optimization of the number of laboratories and the establishment of a complete network of labs (in 2002 5 labs) · Modernisation of equipment and buildings · Training of staff

Food control laboratories

Total

· Establishment of a rendering system as required in EU, incl waste colletcion, utilization of high-risk waste and treatment of low-risk waste · Pre-project studies · Design and preparation of the construction site · Contrstruction of 2 plants · Development of logistics and implementation of the system · Establishment of crematoriums and adequate burial grounds the necessity of which will be deterimnated on the basis of the number of animals and the contingency plan · Supplementation and modernization of the stock of strategic disinfection agents

489,9

1365,7

21,3

20,0 0,5

12,0 0,5 12,4

0,5 0,3

89,0

15,0 74,0

0,2

1,0

1,0

788,1

13,2

12,0 0,8

0,2 0,2

10,0

10,0

26437,7

46,9

44,0 1,5

0,7 0,7

100,0

FROM FARM TO FORK

50

ESTONIA

Data systems

Implementing institutions

Ministry of Agriculture

Plant Protection Inspectorate regional offices

11 58

Total non-civil servants

Grand total

10

Laboratories and testing services

11

5

Chamber of Agriculture & Trade

MIS

134

35

15

Institute of Agrarian Economy & advisory services

5

99

FADN

47 Institute of Agrarian Economy

Veterinary and Food Inspectorate regional offices

174

39

4

10

15

10

135

41

5

48

3

3

45

414

88

28

15

30

15

326

65

5

23

13

Veterinary and Food Inspectorate central office

19

3

56

30

60 25

9

10

14

16

Total

0

5

4

12

6

10

2

0

3

4

2003

Pedigree Breeding Inspectorate

13

4

EAA

Total no of civil servants

5

Plant Protection Inspectorate central office

Internal market

5

2

Intervention Agency

Market intervention

32

9

8 12

20 10

2

4

20 10

3

4

Agriculture & Rural Devel. Agency central office 10 5 Agriculture & Rural Devel. Agency central register Agriculture & Rural Devel. Agency county of7 fices

Department of Foreign Relations and Trade

Trade measures

3

4

4

2001-2

Structural funds & CAP

Veterinary and Food Department

Internal market

3

4

19992000

2

Department of Agriculture

CAP

4

1998

3

Department of Rural Life Development

Responsible institution

Structural funds

Policy Instrument Applied

CREATION OF INSTITUTIONS NECESSARY FOR EU ACCESSION IN THE ADMINISTRATIVE FIELD OF THE MINISISTRY OF AGRICULTURE

ANNEX 5

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

51

* expert appraisal

Total no of enterprises Complying to EU requirements Non-complying to EU requirements EU hygiene and structural requirements General and specific requirements (structure) Hygiene requriements Training of the staff Self-control (HACCP) equipment

No of Enterprises 1999 15 0 15 2000* 2001* 2002* 2003 14 13 9 4 5 9 10 8 0 28.2 20 2.5 0.5 0.2 5

10 1.5 0.5 0.1 2

2000

14.1

1999

25 2 0.5 0.5 15

43

2001

mio

15 2 0.5 0.5 18

36

2002 2003

Necessary invetments EEK

MILK AND MILK PRODUCTS (92/46/EEC) LOW-CAPACITY ENTERPRISES (amount of processed milk less than 2 000 000 l per year)

ANNEX 6

70 8 2 1.3 40

121.3

Total

FROM FARM TO FORK

52

ESTONIA

* expert appraisal

Total no of enterprises Complying to EU requirements Non-complying to EU requirements EU hygiene and structural requirements General and specific requirements (structure) Hygiene requriements Training of the staff Self-control (HACCP) equipment

No of Enterprises 1999 26 4 22 2000* 2001* 2002* 2003 24 20 16 9 15 16 15 5 0 135 70 5 10 10 40

50 5 5 5 30

2000

350 95

1999

90 5 5 5 80

175

2001

mio

50 5 5 5 70

145

2002 2003

Necessary invetments EEK

MILK AND MILK PRODUCTS (92/46/EEC) HIGH-CAPACITY ENTERPRISES (amount of processed milk more than 2 000 000 l per year)

ANNEX 7

260 20 25 25 220

550

900

Total

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

53

* expert appraisal

Total no of enterprises Complying to EU requirements Non-complying to EU requirements EU hygiene and structural requirements General and specific requirements (structure) Hygiene requriements Training of the staff Self-control (HACCP) equipment

No of Enterprises 1999 15 0 15 2000* 2001* 2002* 2003 15 10 7 8 0 1 3 8 15 9 4 0 179 89 8.12 5.2 0.3 76

66 4.8 3.1 1 14

2000

89

1999

57 10.1 6 0.3 39

112

2001

mio

61 8.1 2 0.1 30

101

66

66

2002 2003

Necessary invetments EEK

HIGH CAPACITY MEAT ENTERPRISES (64/433; 77/99; 94/65; 92/45)

ANNEX 8

339 31.6 163 1.7 159

547

1070

Total

FROM FARM TO FORK

54

ESTONIA

* expert appraisal

Total no of enterprises Complying to EU requirements Non-complying to EU requirements EU hygiene and structural requirements General and specific requirements (structure) Hygiene requriements Training of the staff Self-control (HACCP) equipment

No of Enterprises 1999 264 0 264 2000* 2001* 2002* 2003 187 101 97 88 13 44 88 0 174 57 17 88 241 165 28 6 1.5 40

37 10 3 1.4 18

2000

66

1999

172 23 2 0.9 50

248

2001

mio

66 7 0.7 0.3 25

99

2002 2003

Necessary invetments EEK

LOW-CAPACITY MEAT ENTERPRISES (64/433; 77/99; 94/65; 92/45)

ANNEX 9

440 68 12 4 133

657

Total

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

55

FROM FARM TO FORK

56

ESTONIA

HUNGARY

EXPERIENCES OF THE MODERNIZATION AND REMOVAL OF INSUFFICIENCIES IN THE HUNGARIAN MEAT AND MILK PROCESSING PLANTS DURING THE PRE- ACCESSION PERIOD

Author ZOLTÁN SZABÓ

FROM FARM TO FORK

58

HUNGARY

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

EXECUTIVE SUMMARY During the pre-accession period there was significant pressure on the food sectors processing raw materials from animal origin because the market success of export-oriented Hungarian agriculture depends fundamentally on its image in Europe. According to the importance of these sectors during the harmonisation of the tasks with the EU system related to the structure, guidance and control of these economically sensitive sectors Hungary has to consider to a greater extent its economic interests. The adoption of EU requirement started with favourable position for Hungary, because many elements of its legislation (mainly technical and methodology items) were already in harmony with the international standards due to open character of Hungary before 1990 as well. In addition, the Ministry of Agriculture implemented and edited the quality policy of food sector in 1997 which also helped the preparation of the players, turning their mentality from the centralised control and sanction actions towards the liability of entrepreneurs. For the preparation of the EU requirements, a national fund was available between 1998 and 2003 from which 755 million HUF were utilised for the introduction of HACCP system in the food sector. About half of this source was allocated to the meat industry and dairy sector. After 2003 about 2,1 billion HUF that helped the quality improvement of these two sectors, belonged to the SAPARD measures from which about 85 % were utilised for the meat sector. After the accession 500 million HUF from the measures of ARDOP helped the dairy sector in the improvement of the hygiene and quality. The success of the quality improvement from farm to fork is influenced in a greater extent by the preparation of Hungarian food law in 2003 which is in harmony with the European legislation and also the legal declaration of the “Good

59

Agricultural Practice” in 2004, including its conditions and documentation which is obligatory to the claiming of the area payment. The two legal acts enforce the legal frame of food safety and traceability based on the liability of the producers, processors on the whole vertical chain of agro-food sectors. The harmonisation of the authorities’ control and institutions behind them was realized till the accession by the establishment of the co-ordination agency and by the improvement of the unified control system as well. Therefore, after the approval of the EU, the production of the Hungarian meat and dairy sector with the certification of Hungarian authorities became part of the single market.

INTRODUCTION The legislation of the food processing, including the sectors processing raw materials from animal origin changed significantly in the last decades on international level as well. The changing of the general rules of the product liability in the mentioned period brought up the liability of the producers of the raw material together with the food processors, e.g. the food safety and traceability from farm to fork became an unambiguous demand. The food scandals (like dioxin infection, BSE etc.) in the nineties and the beginning of this decade basically changed the judgement of the tools for consumers’ safety and induced also new aspects in their institutions as well. According to these changes were taken some typical measures e.g. as the German Ministry of Agriculture changed its name involved the expression “Consumers’ Protection” or as the food safety issues moved from the DG AGRI to the DG SANCO within the EU. Therefore, during the adoption of the international trends the Hungarian food sector, especially the sub-sectors processing raw material from animal origin over the application of the technical conditions has to be prepared for the enforcement of this new mentality. According to the situation, the preparation of the Hungarian meat and dairy sec-

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HUNGARY

60

tor has to investigate in different aspects in which the implementation of technological and hygienic requirements is only one segment. The changing in the way of thinking is more significantly related to the effect which pushes the regulations, the institutions and of course all players of vertical chains towards a new behaviour. In this lecture I try to summarise the main steps of this process and the results of these various activities, as well the conclusion of the potential steps and strategy of the countries which are candidates for accession in EU. During the analysis research, there was significant difficulty due to the fact that the information related to accession negotiations was available only within the system of state authorities and due to character of the negotiation, it wasn’t public information. The topic itself caused difficulties in the analysis because the data from the control of the meat and dairy sector was too sensitive from the point of view of Hungarian agro-food sector and from the point of view of entrepreneurs both control and subsidies data during accession were business secrets as well. In this way, the public availability in Hungary is limited to the data which is necessary for an unbiased analysis. Therefore, the data is collected from different sources, e.g. besides the open website of Ministry of Agriculture and Rural Development and website of Office of Agriculture and Rural Development (Paying Agency in Hungary) as well, personal information from officials related to the veterinary authorities, and in some cases some semi-quantitative databases from other departments of the Ministry. At the same time, for background of the analysis are used public documents which are available on the website of the Ministry and are related to the policy issues and developments financed from public money as well.

FRAMEWORK ANALYSIS The Hungarian food sector made significant efforts for improvement of quality also before 1990 which is based on the export- oriented character of Hungarian agriculture. It is well-known that from the new members of EU, Hungary is a unique country, which keeps its net-exporter position in the market of EU, although there was significant declining in its production. The defence of this position was possible only due to permanent existence of such quality policy behind the Hungarian production which was significantly in harmony with the internal demands of the single market of EU. The state before 1990 had a determinant role and an extended institutional system related to the control of the quality which involved the activities of State Authorities. The soil analysis, phyto-sanitary, veterinary and hygiene control belonged to the Ministry of Agriculture and Food and respectively the human public health service belonged to the Ministry of Health. This broad system basically stressed the state control with many parallel activities and the control was enforced by different authorities of the different ministries. The main responsibility belonged to the Ministry of Agriculture and Food, but the Ministry of Health, the Ministry of Industry and Trade, and the Ministry of Environment and Regional Development also had their own role. The distribution of the roles amongst the ministries and authorities behind them before 1990 are summarised in the Appendix, as they participated in the process of licensing of a new processing plants. After the beginning of the accession negotiations Hungary elaborated the quality policy of the sector in 1997 which was a significant step in our preparation. The quality policy edited by the Ministry included the following main elements: 1. State tasks during the implementation of the quality policy 1.1. Legislation of quality

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

1.2. Supervision of authorities

61

1.3. Quality research and training in the state institutions

negotiation with EU and in the action plan of accession as well. The most significant elements of the preparation were:

1.4. Coherence with other policies

- legal harmonisation

2. Tasks of the quality policy demanding participation of state

- transformation of the control of state authorities

2.1. Participation in the national standards and in the other regulation as well

- improvement of the products’ certification and quality assurance systems

2.2. Participation in the development and implementation of the product certification and quality assurance systems

Therefore the presentation will introduce the steps of the Hungarian preparation to the accession and will summarise its experiences by the analysis of these elements.

2.3. Participation in the quality info-system 3. Tasks of the quality policy demanding state support 3.1. Knowledge transfer related to quality, promotion of change in the way of thinking 3.2. Introduction of quality systems and voluntary quality assurance systems in the sector The principles of the implementation of the tasks related to quality policy included amongst other the following items: - During the allocation of the sources the state tasks have a priority, the catalytic activity of the state will be preferred depending to the amount of sources; - Advantage has to be provided to the tasks which cause broader effects. The improvement of infrastructure and the knowledge transfer has higher priority compared to the programs providing benefits to individuals; - The small and medium sized entrepreneurs, due to their lower capital supply and less modern technology have to be preferred, with the purpose of improvement of their competitiveness and dynamics. The preparation of the document of quality policy was an important tool both in the

LEGAL HARMONISATION The harmonisation of the legislation is not only a simple proclamation and adoption of the EU legal texts but a spreading of a different way of thinking. The legal frame before 1990 involved the detailed and obligatory standards of products, based significantly on the external state control (with sanctions) i.e. generally based on the dominancy of central decisions or with other words the basement of the quality policy wasn’t the liability of producers. At the same time due to the centralized regulation and standardisation many technical elements (like residue, methodology, sampling etc.) of Hungarian quality system originated from Codex Alimentarius and by this way are in total harmony with the EU legislation. This situation is verified by the fact that 2 weeks after the declaration of the Hungarian Food Law in 1995 (2 years before the above mentioned quality policy) the Ministry declared the obligatory adoption of EU legal texts, including regulations, decisions and directives in 81 topic (mainly in the quality specification and methodology). At the same time the changing in the approach of food legislation in Hungary was loosened by the food law in 1995, but the liability of processors was completed according to the EU principles only in 2003 (law 82.). After analysing the changes between both laws it became clear that the objective of the new legislation was not the

FROM FARM TO FORK

62

creation of central directives of production and its conditions, but the determination of the conditions amongst which the producers, based on their liability, produce foods and the determination of the tasks and tools of related to this process state activities as well. The structure of the new law was also simpler because after the accession, the EU regulations and decisions came into force directly, therefore the new food law did not include those elements. Of course the most sensitive topic in the new legislation is the veterinary and food control. During the screening period, the competent Directorate of EU (DG Sanco) was watching closely the Hungarian Authorities for the adoption of 199 EU legal texts. Within this legislation were 18 regulations, 124 decisions and 57. The preparedness of Hungary is verified by the fact that until 2003 50 of these directives wеre fully adopted so at the moment of the accession in 2004 the legal harmonisation of control system was finalised. The changing in the way of thinking related to the food safety isn’t imaginable without the changing in the production of raw material. In Hungary before 1990 the phyto-sanitary and veterinary prescriptions were very rigorous due to the exportoriented character of the agriculture and even in some cases the limits of residues were lower then in the EU legislation. Thеsе requirements wеre preserved during the transition period. The legal harmonisation improved the law for plant protection in 2000 (law 35), respectively the Minister of Health modified the regulation concerning residues of animal medicines in 1999, and the regulation dealing with the residues of materials for plant protection as well. These legal texts had to be changed only because their content was linked to the former system of production, which deviated from the EU practice and presumed an extended state system for control for which financial resources were not available in the national budget after the accession. The conversion of quality policy to a based on producers’ liability one, within the private owned primary agriculture

HUNGARY

was helped also by the accession, because the eligibility of the area payment complies with minimal requirements and documentation of “Good Agricultural and Environmental Conditions” and “Good Agricultural Practice” as well. By the introduction of this legislation (4/2004 regulation of Ministry of Agriculture and Rural Development) the Hungarian food safety system had a coherent contemplation for producers’ liability from farm to fork and the traceability was realized by the documentation provided by them. Experiences and provisions of state control during accession period The significance of the state control was not declined by the producers’ and processors’ liability especially in the plants processing raw material of animal origin. The EU monitoring report about preparedness of Hungary in November 2003 drafted that the structural and hygienic situation of these plants has a significant insufficiency. The report also showed that the nationwide state control of authority was unsufficient in 2002-2003, because it was not able to speed up the implementation of companies’ plan for the compliance with the EU requirements. Аfter the declaration of the quality policy in 1997, as a tool of this policy Hungary provided significant subsidy to the introduction of quality systems (HACCP, TQM). The subsidy to the food industry from the national budget was 50 % of the expenses and started in 1998. The annual subsidies for quality development are shown in Figure 1. The subsidy helped the speed up of the introduction of HACCP system especially in 1999 and 2000, but in 2001-2002 the available sources declined besides the increasing of the applicants. Behind the limitation of allocation in the national budget was concealed the expectation of the government for the more rapid start of SAPARD program and they hoped also for co-financing of EU for a faster preparation. The failures of the SAPARD preparation therefore also influenced the more rapid joining up of this sector. At the

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63

Figure 1. National subsidy of quality systems between 1998 and 2003

same time the successive decreasing of the sources led to a decreasing of the potential of the applicants, which parallel with the increasing competition, caused the unprepared players to give up their activities.

After the above mentioned report of EU concerning preparedness of Hungary in 2003, the plants received deadline to eliminate their insufficiencies, especially the red meat processing plants till the end of December 2003, the others till 15th March 2004. Table 1. Comparison of situation in October 2003 and March 2004 RED MEAT High capacity slaughter

DAIRY Low capacity

processing

slaughter

Low capacity

processing High capacity

0,5-2,0 million l

Below 0,5 million l

Year

03

04

03

04

03

04

03

04

03

04

03

04

03

04

Compliant

27

42

32

24

16

17

67

117

31

32

-

2

2

2

Compliant before accession

87*

17*

34

24

157

14

103

81

34*

16*

18*

-

20*

5*

7

40

3

11

47

55

21

153

4

8

1

10

4

18

121

99

69

59

220

86

191

151

69

56

19

12

26

25

Insufficient after accession Total

* 15 meat plan, 12 high and 9 small cap. dairy received 1 year exemption

FROM FARM TO FORK

HUNGARY

64

The Hungarian authorities were obliged to implement control in two stages, the first one in October 2003 and the second one in March 2004. As a result of that about one-third of the plants - 261 red meat plants and 36 dairies were closed in 2003-2004 due to lack of compliance with EU requirements. The plants which received one year extension could continue their activities with constant capacity, but they were allowed to sell their products only in Hungary.

of funds for the preparation for compliance with EU requirements, namely the meat sector utilised higher proportion of these resources (28-29 %), respectively the dairy only 22 %.

After the closing of the national subsidies the preparation for compliance with EU requirements continued with the utilisation of the SAPARD sources since 2003 and after the accession with the sources of ARDOP. Within the SAPARD measures the meat sector had more significant proportion (see in Figure 2.) The measures for processing the meat sector represented 35 %, and respectively the dairy plants - 8 %. The general situation of the sectors is illustrated by utilisation

The experience of the first stage of the investigation in 2003 showed that the control of the authorities has to be implemented with a unified system and in order to develop such a system the Ministry established a professional working group in 2003. Based on their activity by the time the second stage of the control, unified professional documentation was prepared, helping the control enforced by the authorities in 2004, as well as the better professional training of the staff.

Within the projects of ARDOP (Figure 3.) until the end of July 2005 there is no demand for funding for the preparation of meat sector; only from the dairy sector conclusions can be made about the development of food safety.

Figure 2. SAPARD projects for compliance with the requirements

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

65

Figure 3. ARDOP projects till middle of 2005

The activities of the authorities had to consider the different interests of the producers, processors and consumers as well. The fragmentation of the institutes also represented this difference as it was mentioned also in the introduction. For the better co-ordination of the tasks the government established the Food Safety Office in 2003. This agency was originally established with the supervision of Ministry of Agriculture and Rural Development with the co- financing of Ministry of Health for co-ordination of scientific tasks. The Food Law in 2003 and the common regulation of the Ministry of Agriculture and Rural Development, the Ministry of Health and the Ministry of Economy determined also the significant tasks to be co-ordinated. Since 2005 the Office is under the supervision of the Ministry of Health with the following main objectives: - co-ordination of the scientific risk analysis; - co-ordination of the control of authorities related to food and feed;

- operate the rapid alert system; - providing the information flow - authentic, careful communication with attention to the population’s interest - primary contact with the international institutions (EU - EFSA, DG SANCO) - assistance of the entrepreneurs in the preparation to the new requirements.

SPECIFIC MEASURES RELATED TO THE QUALITY CERTIFICATION The aspects of increasing consumers’ confidence are served by specific marks which is an important tool for the processor/merchants. The trade marks influence the mentality of the consumers, provide better sale by the quality expected behind marks, but the trade mark represents always a single company. The consumers’ mentality also is influenced by other marks which are regulated by EU in its legislations

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66

related to geographic indication and indication of origin, respectively related to traditional specialty guaranteed of foods as well. These marks are not property of the companies. The process for permission of utilization starts with an initiative of communities (processors, producers) and is put into practice by a special procedure of the national authorities. Before 1990 in Hungary existed a so-called Forum of Excellent Goods. There was also legal procedure behind the utilization of national symbols on exported specific quality foods (like salami, tokaj wine). The harmonization of the Hungarian legislation with EU requirement before accession was started by the 11th law in 1997 related to the trade- marks and geographic indication and finished in 2003 (law 102.). The detailed rules were introduced by the regulation of Hungarian government (78/2004) which made possible the direct application of the mark „Protected Geographical Indication”, respectively the mark „Protected Designation of Origin” to the Hungarian goods in Europe. Conclusions and policy recommendations According to the Hungarian experiences the main components of the preparation for the EU accession related to quality in the food sector are the following: - the food sector and the Hungarian food legislation due to former market situation applied the majorities of the international requirements (mainly technical issues) before 1990; - for the accession negotiations the Hungarian government developed the quality policy of the sector which helped the preparation of sector for harmonisation with European legislation; - since 1998 there was national subsidy helping directly the introduction of HACCP which possibility after 2003 was opened by SAPARD and ARDOP measures for the quality development in meat and dairy sector;

HUNGARY

- parallel with the accession negotiations significant proportion of European legislation was adopted directly to the Hungarian legal frame increasing the awareness of the market players e.g. the spreading of changing mentality from the quality system based on external and subsequent control towards quality assurance based on the permanent monitoring of the processes; - besides the regulation of food processing, the primary agriculture also was involved in the legislation by minimal requirements and documentation (Good Agriculture Practice) which resulted in the unified approach of quality and the traceability of products on the whole vertical chain based on the liability of the producers; - through the official control was developed the unified approach and the professional guidelines which provided the adequate assessment of food processing plants and by which the conformity was certified; - the unified institutional system of food safety was put into practice by the establishment of Food Safety Office and by determination of its tasks related to the co-ordination of the parallel control authorities. The candidate countries of course have to develop their own strategy related to quality and legal harmonisation based on their own situation. According to the Hungarian experiences over the listed elements we have to draw the attention once more to the importance of awareness related to quality policy and to the training of staff of authorities as well. Majority of the delays during the process of preparation are caused by leaving those factors out of consideration. Therefore, it has to be underlined that the success of the legal and institutional harmonisation, the implementation of quality system in the chain “from farm to fork” and the real food safety can be made possible through awareness and collaboration between the market-players and the authorities.

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

SOURCES OF INFORMATION Notice of Ministry of Agriculture related to the tasks and realisation of quality policy of Hungarian agrofood sector Report of EU about the pre- accession preparation of Hungary (2003) Website of Ministry of Agriculture and Rural Development (policy issues and legislation) Website of Office of Agriculture and Rural Development (SAPARD and ARDOP measures) Personal interview: - Food Department of Ministry of Agriculture and Rural Development (general situation of sectors, introduction of HACCP) - Animal Health and Food Control Department of Ministry of Agriculture and Rural Development (legal harmonisation, official control of authorities)

67

SHORT RESUME OF THE AUTHOR The author educated as a chemist and his professional activity started in 1973 in the Department of Chemistry in the University of Horticulture. At the beginning of his research, he dealt with the biochemical role of micronutrients. His university doctors degree is achieved by the research of the role of microelements on the enzymatic process of fruit abscission. After 10 years education and research activities his work continued in the Ministry of Agriculture and Food as the rapporteur of improvement of agricultural higher education. Later he was Head of the Department of Education. During this period he dealt with general administrative, legal and economic issues which were not only official tasks, but it became also part of his research. The development policy of Hungarian agricultural higher education based on the so-called Bologna declaration and the project plan of adaptation of European advisory systems supported by PHARE are the main results of this period. At 1992 he returned to the University of Horticulture and Food, dealing with the continual training and advisory service for SMEs and parallel educated in Wageningen (quality assurance and marketing management) and in Rome (FAO project management). He has a PhD in economy since 1996. In his thesis he elaborated the structural development of the advisory service. Since the same year he participated in the renewal of co-operative system in Hungary and besides his university activity from 1998, he is a general secretary of HANGYA Co-operative Association. In his research activity he turned towards the general issues of agricultural policy, participated in the ex-ante evaluation of NRDP of Hungary. From 2003 his main occupation is the general secretary of HANGYA Co-operative Association and in 2004 he was elected a vicepresident of European Association of Co-operatives (COGECA).

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68

APPENDIX Tasks of authorities related to the licence of new processing plants, foods and related activities in 1996 Activity Licence of the new processing plant

Authority County Animal Health and Food Control Station (AHFCS)Supervision :MoA*

New additives and technological National Research Institute materials of Alimentation and Nutrition (NRIAN)Supervision: MoH** Licence of new packaging NRIAN materials, new detergents and disinfections Minimum test on food hygiene AHFCS NPHMOS and quality assurance Licence of new food Minister of Agriculture Licence of food for specific NRIAN nutritional demands Permission of new products and AHFCS its documentation Commercialisation of the prod- AHFCS uct over shelf-life Preservation by radiation Minister of Agriculture Conformity of import raw mate- NRIAN rial and additives from aspects of public health Preliminary analysis of new KERMI Kft, (Trade Quality foods from import Control Ltd.) MERTCONTROL (QUALITYCONTROL Co.) Supervision: MoITr**** * MoA : Ministry of Agriculture and its successors ** MoH: Ministry of Health and its successors *** MoEWm: Ministry of Environment and Water-management and its successors **** MoITr : Ministry of Industry and Trade and its successors

Partner Institute National Public Health and Medical Officers’ Service (NPHMOS) Supervision: MoH**Environmental Control InstituteSupervision: MoEWm** at the national preparation of additives AHFCS

AHFCS NRIAN NPHMOS Additives and aromatic substance:NRIAN

AHFCS / NRIAN

NRIAN

POLAND

THE POLISH EXPERIENCE IN THE IMPLEMENTATION AND EXECUTION OF THE FOOD SAFETY REGULATIONS

Author ANETA HEROD PHD

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POLAND

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71

SUMMARY

INTRODUCTION

Consumer health and safety is one of the most important goals of the European Union policies. Maintaining a high level of safety of products is crucial not only for public health protection but also for the consumer’s confidence in the safety of all food products that fulfil certain health conditions. In other words, the consumer can be sure that these products are not physically, microbiologically or chemically contaminated, and are safe all along the food chain, from the primary production stage up to the distribution of the final product.

Food safety is one of the most important goals of the European Union. This philosophy is widely understood and accepted in all EU countries. “From farm to fork” is a very wide concept and covers a whole sector of food manufacturing from primary production of food of plant origin and feed, their storage, processing, the use of animal feed and as a result, the production of edible products of animal origin. The way this sector functions is regulated by a number of regulations which impose duties and requirements on both economic units and controlling authorities. In the Polish system the responsibility for the legislation making (which means its adjustment to the EU regulations) is vested in the Ministry for Health and the Ministry for Agriculture and Rural Development. The National Sanitary Inspection Agency, in its turn, is the supervisory body responsible for the control of health quality, permitted food supplements and other food ingredients, observance of sanitary requirements during the manufacturing process and the distribution of these articles as well as other food contact materials and products. Whereas, the Veterinarian Inspection Agency supervises the production of raw materials of animal origin and food manufacturing out of these raw materials. For the diagram presenting the functioning of both agencies see Annex 1.

Before the European Union accession, Poland had adjusted its legislation and its structures to the EU health safety requirements. Since the EU legislation gives the priority to ensuring consumer safety, it is strictly demanded that food producers and distributors act according to the “from farm to fork” control regulations. Poland was under an obligation to implement the EU requirements set out in the EU regulations as well as to introduce an effective control system. Due to welfare reasons as well as to the structure of the Polish industry the Polish negotiators asked for transition periods for meat- and milk-processing plants. Today, the EU food sector is waiting for the implementation of “hygiene package” regulations, which had been prepared with the view to establish a comprehensive and integrated policy for this sector. The adoption of this package demands the adjustment of the Polish legislation to the new regulations. On balance, Poland’s accession to the EU with regard to the milk and meat sector can be deemed beneficial and the decisions made during the negotiations sound. Thanks to a number of measures taken in order to adjust to the EU food hygiene regulations Poland was able to enter the EU milk and meat market and trade with other countries of the EU.

Competent authorities administrate the policies ensuring food safety on the basis of risk analysis. Official Control Programmes of the whole food sector and the related feed sector as well as animal communicable diseases monitoring programmes are prepared annually. All these elements complement one another with the aim of maximization of consumer safety. The aim of this publication is to discuss the issues related to manufacturing of food of animal origin in the milk and meat sector, the challenges confronted by the milk, and white and red meats manufactures. I will also discuss the level

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of implementation of the EU regulations, the Polish administration experience as well as future prospects of animal origin food producers. The following concepts consistent with the EU legislation terminology are used in this publication: - foodstuffs – food products, substances or their mixtures containing ingredients intended for human consumption in the natural or processed form; - food hygiene – measures and standards necessary for hazard control and assurance of fitness for human consumption of foodstuffs with regard to their intended use; - food safety – the body of measures and requirements to be met along all stages of manufacturing and distribution of food products and feed for animals for farming purposes in order to ensure safety of human life and health; - health quality of food – the body of characteristics and criteria according to which food is characterised with regard to its nutrition, organoleptic qualities, and the consumers’ health safety; - permitted food supplements – substances, which are not consumed separately, and are not typical food ingredients, with or without nutritive value, and whose purposed technological use in the process of manufacturing, food-processing, preparation, packaging, carriage and storage brings about the intended results in the foodstuffs or half-processed food products that are their ingredients; permitted food supplements may become ingredients of foodstuffs directly or indirectly or many influence food characteristics in other ways, excluding the substances added with the intention to preserve or enhance products’ nutritive value; permitted food supplements can be used only on condition that their use is technologically grounded and does not pose hazard to human life and health;

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- the HACCP (Hazard Analysis and Critical Control Point) – the systematic identification and management of risks associated with the manufacturing, distribution and use of food ingredients; - Good Hygiene Practice – a body of measures and requirements necessary to ensure food safety on all stages of food manufacturing and distribution; - Good Manufacturing Practice – a body of measures and requirements necessary to ensure that the production of food products as well as food contact materials is of adequate health quality and according to the purposed use; - risk analysis – the process comprising three basis stages: risk assessment, risk management and risk information; - food contact materials and products – equipment, appliances, tools, packages, and other materials that come in contact with foodstuffs, substances used in food-processing, permitted food supplements, and other food and beverages supplements; - risk management – the process, different from risk assessment, which implies the analysis of alternative policies in agreement with the parties concerned, consideration of risk assessment and other legally justified factors, and if the need arises - the choice of adequate means of risk prevention and control; - Rapid Alert System for Food and Feed – administrative proceedings of official food control authorities and other units that control food safety, aimed at informing government administration organs as well as the EU Commission and the European Food Safety Authority about direct or indirect hazards to human life and health posed by food or feed; - Primary production – manufacturing, cultivation or husbandry of primary products,

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

including harvesting, milking and husbandry of animal kept for farming purposes before slaughter. It also covers hunting, fishing and collecting from the forest. a. The analysis of the situation in Poland in the light of the EU accession In agreement with the arrangements made during the pre-accession negotiations set out in the Accession Treaty, the requirements defining transition periods for Polish milk- and meat-processing plants were set out in Annex XII. At the time of signing of the Accession Treaty (16 April, 2003) the EU requirements were fulfilled by 53 milk-processing plants, 35 poultry plants (slaughter houses, jointing plants, processing plants), 95 red meat plants (slaughter houses, jointing plants, sausage-casing manufactures, red meat refrigerators). These plants were qualified as A category plants, which meant that from the 1st of May, 2004 they could trade within the whole territory of the EU without any limitations. However, the number of these plants was relatively low, as compared to the number of plants which committed themselves to meet the EU requirements before the date of the accession. There were 170 such plants for the milk sector, 184 for the white meat sector and 1318 for the red meat sector. Despite the promises of the industry representatives, many of them did not manage to introduce all the necessary changes till the accession. Thus, for the date of the 1st of May, 2004, altogether 207 milk plants, 156 slaughter houses and white meat jointing plants, 546 slaughter houses and red meat jointing plants, as well as 338 both red and white meat-processing plants met the EU requirements. A list of Polish plants to which transition periods were given is to be found in Supplement B to Annex XII, Accession Treaty. The Supplement contains the list of plants, information on the requirements still to be met by these plants as well as the dates by when these shortcomings are to be removed. In the aforementioned Supplement B there are 113 milk plants, 94 poultry plants, 267 red meat plants listed. The plants were obliged to adjust

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to the EU requirements, including the development and full implementation of procedures arising from the HACCP system during the transition periods. Supplement B also contains a separate list of milk plants which were allowed to process both milk fulfilling and milk falling short of the EU requirements on separate production lines. For 29 plants the transition period was given till 30 June, 2005, for 14 plants till 31 December, 2005, and for 13 plants till 31 December, 2006. In addition to that, these plants were obliged to take the necessary measures in order to separate the milk fulfilling the EU requirements from the one that falls short of them as well as take other internal measures related to storage, processing, packaging, and storage of finished products. At the same time, the emphasis was put on ensuring full traceability of products. Moreover, the competent authorities (the Veterinarian Inspection Agency) were obliged to control the aforementioned plants in order to ensure the fulfilment of the Accession Treaty requirements, and in particular, the Annex XII requirements. Since not all milk produced by individual farmers met the strict EU milk quality requirements, a list 56 plants which could process milk falling short the EU requirements was made. Obviously, the producers who were given transition periods to meet the EU food quality and manufacturing process requirements can sell their products only on the internal (national) market. Yet, the possibility of selling milk products falling short of EU requirements gave ample time to the individual farmers to adjust their milk production to the EU health quality and hygiene standards. The Accession Treaty was signed on the 16th of April, 2003 and published on the 23rd of September 2003. However, the Commission of the European Communities Decision 2004/458/EC of 29 April 2004 amended Supplement B to Annex XII, Accession Treaty of 2003 which contained a list of some meat, fish and milk sector companies to which transition periods are given. This Decision covered 200 both red and white meat sector plants and 35 milk plants. This change

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was conditioned by earlier adjustment to the EU requirements of a number of plants. The Decision was made at the request of Poland, after all the necessary documents proving the fulfilment of the requirements by the plants had been sent to the Commission. The later amendments of Supplement B to Annex XII were also made in the form of the Commission Decision 2005/271/ EC of 30 March 2005 which again covered some fish, meat and milk plants. As it can be seen, the process of plants’ adjustment is quite dynamic, which is the result of the benefits from the access to the EU market. Polish food producers demonstrate growing awareness of these benefits, at the same time, by meeting the strict EU requirements, they considerably improve their competitiveness on the demanding EU market. A good illustration of this fact is growing sales of high quality relatively cheap Polish foodstuffs to other member countries, including the “old EU” countries. Apart from structural changes, the greatest challenge for Polish economic units is the implementation of the HACCP rules. Assumptions of this system demand changes in the very structure of the plant, adjustment of production lines, as well as fulfilment of strict hygiene requirements. All these measures require a high level of investment as well as the improvement of knowledge of both managers and the staff employed in the manufacturing process. Thus, it is necessary to Picture 1. Integrated Food Safety System

have regular qualifications improvement training seminars for the staff, to precisely define the scope of their responsibility, to implement a system of internal control and good organisation of work in the plant (movement of people and equipment). In the light of the current legislation, the HACCP system is obligatory for all units operating in the food sector, including the discussed meat and milk sector. The process of the adjustment of Polish hygiene regulations to the EU regulations required the implementation of about 700 legal acts from this area, including 147 directives set out in the Law Act on health conditions for food and nutrition of 11 May 2001. In accordance with these regulations the HACCP system covers the following rules and the mode of proceedings in meat and milk plants: - identification, assessment of hazard, and risk of its occurrence as well as identification of ways of its reduction and elimination; - identification of critical control points in the manufacturing process; - identification of the acceptable deviations from the control points; - development and implementation of monitoring of critical control points; - identification of remedial measures in case of irregularities.

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

Units obliged to implement the HACCP system can use GMP and GHP guides for its preparation and implementation. Both GMP and GHP guides as well as HACCP system comprise the so called Integrated Food Safety System. It also includes such elements as legal basis, (legislation making, interpretation, and implementation), dissemination (training seminars, information materials) implementation (consultations, instructions, documentation preparation, internal audits) as well as control (external audits and authority controls) (Turlejska, 2003). The implementation of quality systems, including HACCP, results in measurable benefits for producers. For example: - improvement of food-manufacturing safety;

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does not require any adjustments or actualisations. This is one of the basic errors of plant managers. The initial stage of the identification of possible hazard. The next stage is the assessment of particular hazards and identification of critical points in the whole manufacturing process. Plant owners often consider that the more critical points are identified, the more effective the system is. However, we cannot forget about the necessity of monitoring those identified critical points, identifying acceptable deviations, and developing remedial measures for every case. It happens that the monitoring of individual critical points is neglected. Rather than having tens of critical points which are not monitored in practice, a far better solution is to implement proceedings with regard to the most important critical points and monitor them systematically.

- reduction of public health hazard; - more effective food control; - greater consumers’ confidence in food producers who have implemented GHP, GMP and HACCP rules; - meeting the legal requirements; - reduction of the risk of health hazard, and as a result, greater producer’s safety. The development and, especially, the implementation of the system is a long-term process that involves both employers and employees. An additional benefit of the system is a greater staff’s awareness and competence. The HACCP system is based on 7 rules, which are successive development and implementation stages. All the descriptions of critical points, monitoring rules, critical points parameters, irregularities procedures should be kept in the so called HACCP guide. It has to be emphasised that the HACCP system development and implementation is not a one-time activity. Every change in the process of manufacturing, addition of new ingredients, change of the product profile requires the adjustment of the system. Sometimes company managers assume that a once implemented system

The Polish Law Act on health conditions for food and nutrition refers to Regulation 178/2002/EC of the European Parliament and the Council of 28 January 2002 which sets the general rules and requirements for food legislation, establishes the European Food Safety Authority as well as sets out food safety procedures. The assurance of high level of protection of human life and health is the most important aim of the 178/2002/EC regulation. Rules that aim to prevent the distribution of hazardous food as well as enable the traceability of a particular goods consignment. This regulation, on the basis of the EEC Council Directive 92/59/EEC requirements from 29th of June, 1992 on general product safety, broadens the scope of activity of the Rapid Alert System for Food and Feed (RASFF) as well as the system of crisis management. Under it every member state is obliged to develop the public administration system that would ensure effective functioning of the system as well as dissemination of information on discovered hazards and effective remedial measures within the system. In Poland this structure was established by the terms of the aforementioned law on health conditions for food and nutrition. The diagram of this structure can be seen on Picture 2.

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Picture 2. The RASFF in Poland diagram.

b. The Analysis of the situation in Poland in the light of the EU hygiene requirements amendments New legal regulations commonly known as “hygiene package” were passed by the European Parliament and the Council. The regulations are in accordance with both Regulation 178/2002 and the Polish law on health requirements for food and nutrition. The “hygiene package” concerns the body of the EU legal documents regulating hygiene requirements, as well as control measures, control by Food and Veterinarian Office inspectors and trade with third countries with the view to establish a comprehensive and integrated policy.

For the purposes of the present publication the most important is the Regulation 852/2004 which determines the minimum hygiene requirements for food production, including food of animal origin, as well as puts an obligation on food sector plants to implement programmes and procedures based on the assumptions of the HACCP system. These requirements do not apply to primary production, yet the European Commission has a possibility of developing such requirements for this type of production in the future. Until than member states can disseminate information and encourage primary production plants to develop requirements on the basis of GHM, GMP and HACCP rules. This Regulation does not define “primary production” , which was earlier defined

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

in Regulation 178/2002. For the first time at the EU level the requirements for this type of production were determined on such a scale and in such a detailed manner. These requirements are set out in Annex I to Regulation 852/2004 and concern hygiene provisions for primary production of plant and animal origin and associated operations. Moreover, the requirements for retaining documents were set out. These measures aim at ensuring hygiene standards starting from the basic level of food manufacturing. Such a restrictive approach of the EU towards this issue can be explained by the fact that on the primary production level there are many food hazards (presence of mycotocsins and heavy metals in food, remains of plant protection substances and veterinarian medicines). It has to be emphasised that these provisions are not very demanding for economic units dealing with primary production. Big, specialised plants can meet Annex I provisions without serious difficulties. However, in the case of small farms, where production is not one-lined, this is more problematic. Moreover, it appears that the greatest problem is not meeting the provisions, but informing individual farmers and raising their awareness on this subject matter. Although there are agricultural trade unions of individual farmers, their organisation and functioning remain weak and do not unite all primary production food manufacturers. Moreover, a considerable challenge in the Polish case is the big number of individual farms specialising in plant cultivation (about 1 400 000) and in husbandry (about 875 000). This is a challenge for agriculture consulting agencies, government administration, including Ministry of Health, Ministry of Agriculture and Rural Development as well as controlling authorities, such as National Sanitary Inspection Agency and Veterinarian Agency. The requirements towards all other (than primary production) plants operating in this sector are set out in Annex II to Regulation 852/2004. These provisions cover food premises, all rooms where food is prepared, treated or proceeded as well as movable and/or temporary premises such as

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marquees, market stalls, mobile sales vehicles. Moreover, requirements for equipment, transport, staff training and personal hygiene, refuse, packaging, heat processing are also laid out in Annex II. Discussing the aforementioned requirements it is necessary to pay attention to the fact that Regulation 852/2004 comes into force only on 1 January 2006 at the earliest. This transition period is aimed at gradual and effective adjustment of all units of food sector to the discussed requirements. This regulation allows the competent national authorities to have a flexible approach to the implementation of this regulation, yet, strongly emphasises the importance of food safety and so the fulfilment of the requirements of this regulation. The date when Regulation 852/2004 comes into force was determined to a large extent by the publication of Regulation 853/2004 of the European Parliament and the Council of 29 April 2004, setting out special provisions for animal origin food hygiene. The reasons for developing one detailed document were the large number of directives regulating hygiene issues in this sector on the one hand, and many instances of microbiological and chemical hazards in these products, on the other. The publication of Regulation 852/ 2004 putting an obligation on units to implement procedures based on HACCP system provisions leads to the simplification of the current regulations. It has to be emphasised that “hygiene package” does not introduce drastic changes in the requirements towards milk and meat sector units. Yet, it defines new requirements for animal origin food sector. An important element of the EU philosophy on food chain is the issues of traceability. Slaughter houses will be responsible for data verification on animals origin, diseases in the region and herd, and possible received treatment via an animal registration and identification system. Additionally these measures cover verification of information

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on feed, with the emphasis on medicated feed, due to the possibility of medications’ remains occurrence. In case of lack of such information on animals delivered to a slaughter house, the competent authorities should be informed about this fact and the slaughter of such animals should be suspended.

with much reserve by entrepreneurs who were expecting simplification of the process, yet now predict many difficulties. In contrast, the “hygiene package” was better received by the Polish food producers, which does not mean, however, that the new legislation is free of the feeling of anxiety.

Detailed requirements for different types of production of food of animal origin are laid out in Annex III to Regulation 853/2004. The Annex is divided into sections where all types of production are discussed.

Representatives of the food sector pointed to its too general formulations, despite the “hygiene package’s” impressive size. The terms used in the new regulations leave much room for interpretation and different approaches/readings in different member states. Most ambiguous term are “according to needs”, “where appropriate”, “adequate”, “sufficient.” Moreover, according to the new regulations production limits will be abandoned, which will bring about slight changes in the present requirements. Presently, the regulations allow for a flexible approach to the economic units depending on their scale of production, which, however, may lead to different interpretations of the new regulations. In order to prevent the discrepancies in the interpretations of the regulations a number of training seminars for controlling authorities have been planned. Yet, these measures do not exclude the possibility of different interpretations of the regulations which may result in many misunderstandings.

c. Selected examples of Polish administration activity and opinions milk and meat sector The discussed regulations were incorporated into the Polish legislation, although they do not come into force until the 1st of December, 2006. The vacatio legis period gave food producers ample opportunity to acquaint themselves with the document and take the necessary measures to prepare themselves for the new legal situation in this sector. Government administration, including the Ministry of Health and the Ministry of Agriculture and Rural Development undertook measures aiming at the adjustment of Polish regulations. Presently a new draft law on food hygiene is being prepared by the Ministry of Health. This law will replace the current law on health conditions for food and nutrition. The amendments of laws regulating competences of controlling authorities are also prepared. The amended regulations will predominantly concern the functioning of public administration organs, information flow, the RASFF functioning rules, academic councils of particular organs. Whereas plants and their production will be regulated by detailed requirements laid down in “hygiene package” regulations. However, the draft law on food hygiene contains 49 delegations for the Ministry for Health and the Ministry of Agriculture and Rural Development, which will make possible the passing of 49 different executive acts. These provisions were received

The experience shows that all anxieties connected with the new situation in the food sector will be verified after 1 January 2006. In practice it would mean that if some regulations will not prove effective, the comitology procedure will be employed. This will make possible the amendment of regulations so that the primary goal of the legislation, which is consumer safety, could be achieved.

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

POLISH ADMINISTRATION EXPERIENCE IN THE NEGOTIATIONS PROCESS In the EU legislation the priority is given to ensuring consumer safety, that is why it is strictly demanded that food producers and distributors act according to the “from farm to fork” control regulations. Poland was under an obligation to implement the EU requirements set out in the EU regulations as well as to introduce an effective control system. Due to social reasons as well as to the structure of the Polish industry the Polish negotiators decided upon transition periods for meat- and milk-processing plants. In order to structurally adjust Polish milk farms, milk-processing plants and meet the EU milk standards Poland was given transition periods till the 31 December 2006 in the scope of: - structural adjustment of milk farms; - meeting the adequate milk standards (with regard to somatic and bacteriologic cells content). Yet, this period should be as short as possible. With regard to meat-processing sector the transition period was given till the 31st of December, 2007. Due to transition periods, certain obligations were imposed on milk and meat plants. The plants falling short of the EU requirements have to submit reports on the improvement of the quality of bought milk, whereas plants meeting the EU requirements have to implement permanent veterinarian control. The latter plants can process both extra class and 1st class milk after the accession. Moreover, Poland was obliged to submit annual reports on the progress in adjustment of plants which were given transition periods, as well as to provide information on plants which finished their adjustment in the given report period and remove them from the list of plants which had to adjust till the accession date or the list of plants that were given transition periods. Additionally Poland was put under an obligation

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to implement the HACCP system requirements in milk plants till the accession date. After the accession it has to mark products from plants given a transition period with the square mark; to mark the products from plants meeting the EU standards with the oval health mark; and mark the products from plants of handicraft character meeting the EU standards with the round mark. Furthermore, Poland had to guarantee that fresh, processed meat or products from plants given transition periods will not be sent to plants that were not given such a derogation. Another Polish task was adequate training and preparation of Veterinarian Inspection Agency staff as well as a greater involvement of the central level staff in the monitoring and control process. Due to BSE certain tissues and ruminant carcasses, regarded as special risk material, were prohibited from use in the production of animal feed. Poland applied for financial support for adjustment from the EU funds as well as participated in PHARE projects, the aim of which was dissemination of EU experts’ experience.

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CONCLUSION AND RECOMMENDATION Looking from the perspective of mid 2005, the choices made during the negotiations appear to be sound. The favourable attitude of the food producers seeing their chance in the open EU market is also important here. It has to be emphasised that the Polish choice of the more beneficial option – which is membership with a short transition periods for milk and meat sector – allowed for the inflow of financial resources and permanent growth of the export of agricultural and processed food products. The best approach to the integration was negotiating transition periods, where they were necessary, based on careful study of regulations. The active role of professional organisations in determining their adjustment needs was very important. During its candidacy, Poland was also learning extensively from other member states’ experience and trying to adapt this knowledge to the Polish situation. Thanks to PHARE projects EU experts’ were able to give their recommendations on the adjustment of legislation and administration system in these sectors to the EU requirements. With the hindsight, Poland’s accession to the EU with regard to the milk and meat sector can be deemed beneficial. The good results of Polish companies on the EU market also make the Polish food producers take an optimistic view on the changes. The Polish presence on the EU market is possible thanks to a number of adjustments to the EU requirements regulating food hygiene. Food producers who had to face a number of challenges, such as restructuring, investment, staff training, today can reap the fruits of their efforts. An important fact is that Polish companies active in the EU market enjoy the same rights as other member states companies. As a consequence, Polish food producers have the access to EU financial assistance, and can participate in the EU Commission preparation of the legislation

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regulating milk and meat sector. Moreover, Polish producers can join European trade-unions, which defend their members’ rights within the EU as well as abroad. The current EU candidate countries should learn from the experience of the new EU member states, who still remember their hopes and anxieties, yet already have a year-long experience in the EU. The candidate countries should pay attention to such issues as: - development of a comprehensive and effective system of milk and meat sector control and maximal reduction of the number of official control organs; - precise formulation of government organs’ competences in the acquis regulations and requirements for the meat and milk sector in the national law implementing the EU legislation; - the earliest possible start of trainings for controlling authorities staff in the area of EU milk and meat sector regulations and requirements; - trainings for milk and meat sector government administration staff with the aim to acquaint them with the future challenges connected to the EU accession; - making greatest possible use of FVO inspectors’ controls of the level of public administration adjustment and their following recommendations with a view to effectively implement the public administration structures and the EU legislations, to reach the best results in the implementation of EU law and its organizational structures connected to food safety.

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ANNEX 1 Veterinary Inspection Agency organisation:

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National Sanitary Inspection Agency organisation:

ABOUT THE AUTHOR Aneta Herod PhD Agency for Restructuring and Modernisation of Agriculture Department for Animal Identification and Registration Currently held position: chief specialist Aneta Herod PhD is the contact person of Agency for Restructuring and Modernisation of Agriculture for direct contacts with the European Commission for questions regarding animal identification and registration. She has comprehensive knowledge of the conditions of Poland’s membership in the EU structures. She has also knowledge of the Central Database of the Identification and Registration of Animals System. Education: Warsaw Agricultural University, Faculty of Animal Sciences Master Thesis “Comparison of Milk Market Regulations in Poland and the European Union” Doctor Dissertation “Marketing of Food of Animal Origin in the Light of the EU Accession of Poland”

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ENFORCING THE FOOD SAFETY REQUIREMENTS IN BULGARIAN MEAT PROCESSING INDUSTRY AND THE ROLE OF THE ASSOCIATION OF MEAT PROCESSORS (AMB) IN THIS PROCESS

STATE OF DAIRY PROCESSING INDUSTRY IN BULGARIA

Authors DR SVETLA CHAMOVA MR. MICHAIL VELKOV

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EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

LIST OF ACRONYMS AND ABBREVIATIONS

BIP

border inspection post

EU

European Union

EPPO

European and Mediterranean Plant Protection Organisation

FAO

Food and Agriculture Organisation

HACCP

Hazard Analysis Critical Control Point

ISTA

International Seed Testing Association

NPAA

National Plan of Adaption of the Acquis

MIS

Market Information System

OIE

World Organisation for Animal Health

WTO

World Trade Organisation

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ENFORCING THE FOOD SAFETY REQUIREMENTS IN BULGARIAN MEAT PROCESSING INDUSTRY AND THE ROLE OF THE ASSOCIATION OF MEAT PROCESSORS (AMB) IN THIS PROCESS Food, of course, is a global industry. Everyone on Earth is a customer of this global food industry. Consumers expect suppliers to ensure that their food is safe and at the same time they are interested in quality and price. Logistics enable worldwide marketing of fresh perishable produce. We need to remember that news of food shortage travel around this planet just in seconds. No wonder that everyone wants detailed data about the food that they consume. The recipe for success is to ensure that we are able to satisfy all stakeholders. This particularly applies to food businesses that have to satisfy inspectors, customers and consumers. Over the last 10 years it is registered that the volume of world trade in food has grown. Imports into the USA alone grew by 500% for the period 1992 – 2002. While in 1992 there were 1.6 million lines of entry or individual consignments, in 2002 this has grown to a staggering 8 million lines. As an applicant state for membership of the growing European Community, Bulgaria has a great opportunity to start now to account for and to comply with the world requirements relevant to the food safety and traceability so that, when Bulgaria is accepted, the needed food safety and food traceability will already be satisfied. It is interesting to look at what has happened as a result of the 10 new member states joining the EU. A number of food processing establishments in the Czech Republic, Hungary, Latvia, Lithuania, Poland and Slovakia were considered unlikely to meet the EU standards by 1st May 2004 and were granted three year transitional

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period to adapt. Those establishments will only be allowed to continue selling food in their home member state and will not be eligible to sell to other member states. So, as you can see, the efforts that Bulgaria makes to avoid the transitional period are well worth – the Bulgarian food processing establishments will be able to supply their production to the EU market from the date of Bulgarian acceptance in EU. The food industry in Bulgaria is the largest one in comparison to all other industrial sectors – 25,4% relative share of the gross added-value in the industry. 102 thousand people are employed in this sector. The relative share of the meat and meat products production accounts for 18,9% from total food production in the country. The relative share of income from goods sold by the meat industry amounted to 15% out of the total food industry income; this rated the meat sector as third after the bread-backing and sugar production (with 25%) and beverage industry (with 24%) Meat and meat products sector is 100% privately operated, numbering many small and medium sized enterprises. According to NVS there are 552 operational enterprises Type of Industrial Small Total Production capacity capacity Meatproduction 195 68 127 enterprises Meat processin213 83 130 genterprises Mince meat and meat prepara144 13 131 tions enterprises

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

The newly established enterprises for processed meat products are at high technological level and are in compliance with the EU requirements while the ones in the meat production sector are still underdeveloped.

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The System for food safety control in EU is implemented by:

The problems facing the meat processing industry in 2005 – a turning point for the sector are as follows: o To finalize, by the end of 2005, the process of enterprises’ restructuring in line with the requirements for harmonized legislation, otherwise some of the enterprises in this sector have to be closed down. o To implement self-control systems in the enterprises, specifically the HACCP system, in the meat production enterprises, mince meat enterprises and meat processing enterprises of industrial capacity. o To implement the SEUROP system for quality classification of clinical carcasses. o To implement the new European requirements for product traceability. o To increases the companies’ cost for purchasing raw materials. The preparation of Bulgaria for the EU membership in is in fact preparation of the Bulgarian business for its integration into the United market of EU, while the legislation of EU in practice introduces “the rules of the game” of the United market of EU, and more precisely : o The principle of free movement of goods; o The principle of mutual recognition; o The full responsibility of the producer in respect to the food products safety for the European market.

The SAPARD Programme plays a positive part for the development of the Bulgarian meat industry and in particular the measure provides for the enhancement of the enterprises’ competitive power by improvement of the quality of production and hygiene conditions, the implementation of new technologies, the presentation and packing of the products, the environmental protection, laboratory monitoring, etc. As off the Programme was initiated and until July 1st, 2005 the total number of projects approved under SAPARD for all measurers is 1920 at the total investment value of 1513 million BG leva. Under measure 02, 238 projects have been approved out of which 91 projects for meat processing at the total investment value of 188,9 million BG leva. It is expected that financing under the programme shall be resumed, and civil works of 5 new slaughterhouses (2 for red meat and 3 for poultry meat) and additional equipping of existing enterprises in this sector is foreseen.

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THE ROLE OF AMB IN APPLICATION OF FOOD SAFETY REQUIREMENTS IN THE BULGARIAN MEAT PROCESSING INDUSTRY The Association of Meat Processors in Bulgaria (AMB) unites 187 member–companies that are involved in slaughtering, meat processing, as well as in other activities related to the meat industry. According to expert evaluation the member-companies of AMB take about 75% of the market with meat and meat products in Bulgaria. Since 1998 AMB is an observer member of the European Association of Meat Processors (CLTRAVI), as off 2004 the association is associated member of the European Livestock and Meat Trading Union (UECBV). The Association made many efforts to prepare its members for the implementation of the Good Manufacturing Practices (GMP) in 2002 and HACCP (Hazard Analysis of Critical Control Points) system in 2004 – 2005. The Association elaborated an analysis of the Bulgarian meat production sector, has created a data base for small size and medium size enterprises and another data base for experts in the meat processing industry in Bulgaria who are trained trainers for the HACCP system. The experts’ council of AMB and other leading experts in the field of meat-processing sector elaborated “Manual of hazard analysis of critical control points (HACCP) in the slaughtering and meat processing enterprises”. Further, as supplements to this Manual have been worked out sample HACCP plans for the production range of the slaughtering and meat processing enterprises. The Manual and its supplements could be found on AMB Internet site (www.аmb.dir.bg or www.аmb99.com) At present the generic HACCP plans are being worked out for small size enterprises.

BULGARIA

The success of HACCP lies in the training of the management and the staff of the enterprises in that targets these people to applying the system as well as to know it in detail and to be convinced of the necessity for its implementation. The Association has organized 9 seminars, where about 600 people have been trained, of which 180 are veterinary inspectors of NVS. Furthermore we have trained the HACCP teams of 25 leading companies in the country. Because of the efforts of AMB, the Ministry of Economy, through the Executive Agency for Encouragement of Small and Medium Enterprises has granted free financial support amounting to1 million BG leva for the implementation of HACCP in the slaughtering and meat-processing enterprises of industrial capacity. The support granted amounts to more than 10 thousand BG leva for each enterprise. The Ministry of Economy covers for 50% of the necessary investment. The applying for enterprise co-finances not less than 50% of the total project value. 127 companies were eligible to apply for this project, of which 100 companies did apply. 68 enterprises signed contracts for free financial support. They have to finalize the project by the end of November 2005. The Bulgarian meat processors could refer for information regarding issues of interest and relevant normative acts in this sector to the weekly newsletter “The Meat Bulletin”, while regarding new technological issues of interest in the field of meat industry they could refer to the specialized magazine “Meat and Meat Products”, both being published by the Bulgarian Association of Meat Processors. The Bulgarian meat industry had to make tremendous efforts to survive in the past few years. Many companies managed to do this nevertheless the obstacles proceeding from various governments and despite the necessity of amendments in the Law for Veterinary-Medical Activities of 1999 with the relevant sub-legislative norma-

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tive acts and the Foods Law of 2000 with the relevant sub-legislative normative acts.

•1986: BSE (Mad Cow) - confirmed disease

During 2005 new Law for Veterinary-Medical Activities as well as new Foods Law are expected to be passed with all the relevant sub-legislative normative acts together with one new challenge – the introduction of the new requirements of the so called “Hygiene Package”, which will come in force in January 2006 for the EU, while for Bulgaria – by 31st December 2006.

•1996: Ban on use of beef in UK

With the enforcement of the new legislation the hazards could not be fully avoided however could be brought down to manageable and acceptable levels. WHAT DOES IT MEAN? o The producers are responsible for the product safety; o The producers have more freedom in the process control; o Is all that more profitable taking into consideration the huge investments, which are involved for its implementation? The reasons which forced the European Commission to work out new legislation and to transfer the responsibility for the products produced completely and solely onto the producers have originated from the consumers discontent following the:

•1992: BSE – Peak of the disease in UK

•1999: Dioxin crisis •2000: Second BSE crisis •2001: Foot and Mouth Disease, etc. It was easier for the Bulgarian control authorities and the state administration to issue normative documents harmonized with the European ones, but its application remained solely and only full responsibility of the producers. This had both negative and positive implications. At present we are the people who work on the practical aspects of the application of the new legislation. The people working in field of industry are much more trained by their branch organizations, having approach to the information not in the form of dry matter such are the normative acts, but just the opposite – in the form of practical handy manuals as you will see for yourselves from the distributed materials at this Meeting. As it is well known, the General principles and requirements of the legislation in the field of food production – Regulation 178/2002 outlines the basic principles and requirements which apply to the complete food legislation that aims to secure high level of health protection of customers and effective functioning of this legislation on the local market.

The latest novelty which we will be working on in 2006 is FOOD TRACEABILITY

This is widely applied framework structure which offers traceability across the complete food supply chain

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The requirements towards legislation in the field of food products include the possibility of traceability of food and fodder products, responsibility of the producers, withdrawal from the market of the hazardous food and fodder products and notifying the competent authorities. EU Regulation 178/2002 was adopted on 28th January 2002.One of its purposes is to work out general definitions and to outline guiding principle and legitimate preconditions for legislation in the field of food production in order to protect people’s health and for effective functioning of the local market .

Which are the main problems? o SME’s believe that in order to meet their objectives with regard to effectiveness, it would be necessary to develop electronic tracing systems. They believe that the introduction of full automation will keep the cost in proportion to the economic reality. Whilst they are prepared to buy a bank of unique numbers at an acceptable price they generally do not agree to pay an annual fee and the vast majority of European SME’s have refused to join the EAN system for unification of the bar codes.

The application of these requirements from the 1st January 2005 raised a number of questions, as on behalf of the producers from the EU countries as well as on behalf of the trade partners from third countries.

o The European Cold Storage and Logistics Association face quite different challenges. Its members cannot be held legally liable to identify and keep records that belong to the internal traceability of their customer on behalf of whom they handle the goods.

The Regulations are intended to harmonize at EU level principles (Article 5 to 10) and the requirements of legislation in the field of food production (Article 14 to 21), already in force in the legislation history of the member states and to bring them to European level, providing them with basic framework of definitions, principles and requirements of the future European Food Bill.

o The Organization who represent the retail, wholesale and international trade of about 2 million firms have the specific aim to guarantee prompt and effective withdrawal and confiscation of non quality production which jeopardize the customers’ health.

There is no doubt about it, consumers in Europe – that’s you and me, want full traceability across the whole food chain to assure us of the safety, quality and authenticity of what we eat and it is expected from the authorities and industry to provide this mechanism. We must recognize that two significant issues are currently influencing the development of food supply chains. The first one is globalization of trade, and the second one is the increasing regulatory demands for traceability. Fortunately America and Europe are moving in a similar direction and are introducing legislation for we might term one-up one-down traceability.

The basic definitions of traceability are as follows: o The ISO definition states: The ability to trace the history, application or location of an entity by means of recorded information (ISO 8402:1994). o Food Law states: The ability to trace and follow a food, feed, food producing animal or substance through all stages of production and distribution (draft EU regulation – Food Law 8-5-01). o Whilst the regulatory requirements which will come in force from 1st of January 2005 is for one-up one-down stage traceability. The key objectives of Traceability are as follows:

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

o Helping people communicate (exchange of data) across the food supply industry. o Meeting the legal, safety, commercial (market) and consumer requirements. o Recognizing the differences between food supply chains and food supply networks. The Food Trace Generic Framework provides a coordinating model covering everyone in the network. It will enable each operator to play his part by : o Identifying what comes in. o Identifying what goes out. o Keeping records. o Providing an exchange of information with customers and relevant authorities. o Getting information from suppliers. The Generic Framework distinguishes the following requirements : o The need for the universal means of numbering and identification which will allow for total adoption by food supply chain businesses and which will be capable of accommodating the inherited legacy systems. o Systems that can be defined and implemented in a manner which allows migration strategies from existing systems to the universal system with a minimum of disruption. o An implementation methodology for systems that will allow added value process development in addition to the fulfillment of all traceability functions, including process developments that support better traceability. o Systems that allow item identification and linkage to associate information sets. It should be held and maintained in the chain supporting businesses and as appropriate in distributed databases. o Systems that can accommodate consumer information needs and enhanced access to traceability information, etc.

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It might sound complicated. It really is quite simple. This is the common sense. It is necessary the people across the entire food supply chain to be singing from the same song sheet. It is necessary to identify items using standardized systems. It is necessary to agree the set of data carriers. It is necessary to store and exchange information. The food trace co-ordinating model should enable each operator to play his part by identifying what comes in; what goes out; keeping records; providing an exchange of information with customers and relevant authorities; and getting information from suppliers. So, it is very important to remember the law. One step backward, one step forward. From farm to fork. Most of the world now accepts this principle. This simple rule is the basis for a giant traceability network linking all food businesses to customers. Key points for suppliers to remember in the onestep back process is to pay attention to your supply chains to ensure the safety and authenticity of materials and to work with suppliers to improve quality and to reduce costs. You really do need to be able to identify everything. This means unique identification of products, batches and items, containers, locations and people. The product may have a bar code or another product code, or both, and batch code and date codes. The specified composition of the product is on the pack, The traceability data may include actual values for each batch or production period; record which batches of product relate to outer packaging; records which containers are on each pallet. The Ideal Solution – a common numbering standard that everyone can use; a range of data carriers that can accommodate that numbering system; a set of identifiable information files and a standard means of data communication.

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It must be recognized that traceability cannot be isolated to one region, to one country or even to one continent. It is global. Whether we like it or not, traceability is becoming a requirement in all the world major markets and companies from around the world who ignore these new national and regional traceability issues, will face a tough future and could find that traditional export markets are closed to them.

Evolution of present society: o the distance between production and consumption of the EU market; o better informed-i.e. more demanding consumers; o regarding additives, colour, taste, shelf life of products, better quality at less cost; o preservation of environment–dioxine crisis;

This message is very simple. To be successful everyone along the food supply chain needs to use common sense and to succeed we need to ensure collaboration, harmonization and strategic thinking.

o start of new production line - the beginning of problems; o aging of population – enhancing of risk

The customers are demanding from us FULL TRACEABILITY to assure them of the SAFETY, QUALITY, AUTHENTICITY AND PROMT REACTION, when needed

EUROPEAN EXPERIENCE IN INTRODUCTION OF IMPLEMENTATION AND ENFORCEMENT OF THE VETERINARY AND FOOD SAFETY ACQUIS

It is necessary to expand the meaning of traceability beyond tracing of one article in order to accommodate the requirements for safety and quality and to enable the governments and the sector to introduce mechanisms which will make the user be sure that one general approach is being applied. Everyone interested in the matter have different requirements and to satisfy all : inspectors, traders and customers, we, together with the Institute of European Integration and the Association of milk-processing enterprises in Bulgaria have worked out Guide for Traceability of the Products. The Guide presented at this Forum represents a document comprising important instructions addressed to the food industry. Its purpose is to clarify and to standardize the procedures for identification and withdrawal of hazardous food products from the food supply chains. The systems of traceability and the withdrawal from the market are fundamental components of the food safety system for economic subjects working in the field of food industry. The Guide has been worked out based on the Guide of the Irish Control Body on food safety, the executive agencies, food industry and food and beverage federation within the Irish Confederation of business organizations and employers also take use of materials of the European Association of meat-processors. Expansion of EU and food safety is key word for the Bulgarian membership in EU The position of EU is clear : The expansion must not jeopardize the interests of the customers of the present and future member states of EU – the expansion could not cause any risk to lessen the standards regarding food safety of the EU. The Bulgarian Position : The membership in EU = immediate access to the EU market = enhanced responsibilities = responsibility not only regarding the Bulgarian customers, but regarding the customers of the EU members states

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THE PRINCIPLE FOR FULL CONTROL OF THE PLACE OF ORIGIN OF FOODS IS GREAT CHALENGE TOWARDS THE PRODUCERS BUT VERY USEFUL FOR THE CUSTOMERS

WHERE IS THE CONTROL? Cattle-breeding farms • All ruminants are individually identified and could be traced as long as they live – British agency for movement of ruminants (BCMS) • All ruminants’ checked.

medical

papers

are

• Most of cattle are fed with fodder produced by approved feed enterprises. Slaughterhouse • Upon arrival to the slaughterhouse, all reminants are inspected by a veterinary. • The inspectors on hygiene of meat inspect all carcasses. • The specialists on human treatment of animals execute control regarding human attitude towards animals. • All slaughterhouses observe strictly the normative standards and regulations regarding labeling beef meat. Customers • The customers are informed on a regular basis regarding all issues in connection with food safety and traceability. • The customers are informed about methods for make and use beef products. All business organizations in the field of food production must have at their disposal system for traceability and plan for withdrawal of hazardous foods from the market as part of their “Systems for management of food safety”.

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BULGARIA

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STATE OF DAIRY PROCESSING INDUSTRY IN BULGARIA The first dairy industry branch organization is registered as Union of the dairymen in Bulgaria on 12 March 1991 after closing down of the Dairy Industry State Group. The founders are 61 dairy processors, scientists and distinguished specialists in the dairy branch. Representatives of the dairy enterprises were directors of 53 new reorganized from the ex-state societies trade companies. On 10 November 1994 in Plovdiv was founded an organization of 14 private enterprises in the region – Maritza Milk Association. On 9 March 1998, according to the decision made by the Boards of Directors of the two organizations was founded the Association of Dairy Processors in Bulgaria (ADPB). Its supreme organ is the General Assembly, which gathers once a year at least. At the head of the ADPB there is a Board of Directors consisting of 13 members and Control Council consisting of 3 members. These councils, as well as the Chairman, are chosen by the General Assembly, as the Chairman is, and authorized for a 3-year period. Now the ADPB includes about 75-80% of the companies in the country. Associated members of the ADPB are 21 companies related to the dairy branch. The enterprises united in the ADPB process about 80-85% of the milk produced in the country and assure 80% of the dairy products market. About 85-90 enterprises including 28 possessing certificate are approved to export to the European Union markets. The ADPB is a voluntary non-profit branch organization. The reasons for its foundation are: unification of the goals and tasks of the enterprises and protection of their interests before the state and public structures; keeping the market niches and stability in the competitive environment of the new economic relations; saving the traditions and originality of the Bulgarian dairy products; introducing new products and enlarging the range

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structure; assuring effective control and ameliorating raw milk and dairy products quality. One of the basic purposes of the ADPB is to protect the legal interests of its members, to contribute to resolve their problems on the basis of the partnership and equity. The ADPB makes efforts to create equal conditions and loyal competition in the reaching out to the markets, to strengthen Bulgarian traditions and professionalism in production. It co-operates with the state institutions when legal documents related to milk production and processing are prepared and approved. Our experts take part in the Advisory Dairy Council in the Ministry of Agriculture, in the Bulgarian Industrial Association and in the Bulgarian Chamber of Commerce and Industry. They participate in generating and adopting ideas concerning the branch development according to the requirements of the European standards. Distinguished scientific cooperators and specialists are included in Scientific Advisory Council. It discusses all contemporary problems and opinions about the development of the dairy production. The ADPB consults companies and assists them in the introduction of the Good Manufacturing Practices (GMP) and the HACCP system. It consults and assures qualified development of technological documentation and business projects for SAPARD program aiming to develop and enrich the variety of the milk products according to the world requirements and nutrition standards. Until now, the ADPB took part in the implementation of many programs like PHARE-program and other European funds. SAPARD projects prepared by thirty-five companies have been approved. Ten to fifteen other companies are preparing their documents. We have worked in co-operation programs with the Japanese company JAICA, with the FAEL organization, in a Greek Twinningproject, with the German-Bulgarian Industrial and

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Trade Chamber, with the American Vega Company, etc. In the seminars dedicated to the introduction of the GMP and the HACCP system have been trained representatives of almost all companies in the branch, including non-members of the ADPB. We organize the enterprises of the branch to take part in the traditional international exhibition FOODTECH in the International Plovdiv Fair in the early May. Regularly 70-80 dairy ranges are presented, including several new products. Every year some of our exponents are awarded by 8 to 10 diplomas and golden medals (which are one third of the ones given in the field of the food industry). Last year for the first time we organized the national exhibition “The World of Milk” in the Bulgarreklama Center in Sofia. The results were really satisfying and this year we expect two times more participants. During the exhibition on 16 to 19 November this year we will organize a national competition for milk products sampling. Bulgarian dairy processing companies present their own products to the international exhibitions, like SIAL, Paris, Anuga, Köln, and Berlin’s “Green Week” Food Fair. The consumers in Germany meet with great interest the unique Bulgarian products of the companies like “United Milk Company”JSC, “Zorov 97”ST, “Josi”Ltd, “EccoF”Ltd, “Kondov Ekoproduction”Ltd. These exhibitions helped the above-mentioned companies to find a place on the markets of some European countries. Bulgarian milk products are already regularly sold in the prestigious trade chains REWE, KAUFLAND and KAUFHOFF. Every year national scientific and practical conferences on questions of present interest in the branch became a tradition. The interest constantly increases and the number of the participants reached out 160 directors, technologists and operators from the processing companies and from companies related to the dairy branch.

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In the University of Food Technologies every year are trained about 70 technologists, operators and masters of the dairy processing. Training lecturers are high-qualified professors from the Universities and other scientific research departments. Extremely useful for the people working in the enterprises is the fact that the ADPB organizes the publishing of professional books and guidances, such like “The Bulgarian yogurt”, “Book for the brined cheese”, “Kashkaval and semi solid cheeses“, “Handbook for laboratory analyses of milk and dairy products”, “Guidance on introducing the HACCP system”, “Legal documents in the dairy industry”. Guidance in the wealthy and safe conditions of working in the dairy enterprises is prepared and will be issued before the end of this year. For 8 years the ADPB has published a specialized fortnightly bulletin named Dairy Processor. Regularly new information is published about scientific research work, new technologies, laws, regulations and other documents issued by the institutions in the country and in the European Union. The bulletin became a necessity for dairy branch companies and specialists, foods stores, wholesales and retailers. The bulletin is distributed free of charge for the members of the ADPB. It reaches out all the Ministries, public organizations and other institutions related to the milk and dairy products production. Through our issue, many producers found out the true way to advertise, to enlarge the markets and to succeed in business. The Direction of the ADPB made great efforts about the subsidies of the export of the milk products. Since last year (2004) there are subsidies for the export of the white brined cheese and kashkaval for the countries outside Europe. Unfortunately, these funds are not totally used. For 3 years we have tried hard before the competent administrative institutions and the Parliament to reduce the VAT cost for the milk and dairy products to 8-12 per cent, as it is in many Euro-

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pean countries. Our suggestions entered to the preliminary discussion in the Parliament. However, at the discussion the Parliament rejected the differential rates with not very persuasive arguments. The deputies did not agree as well with the proposition of the voluntary registration on the VAT law of the agriculture producers who did not reach out the threshold of 50 000 leva. These changes would reflect positively on the price of the raw milk. What is the status of the dairy processing industry? Following the European Directives and Regulations of the Bulgarian administration, during the two previous years, our enterprises were and are subject of constant verifications and control. Difficult processes of restructuring and modernization, and an inevitable reduction of their number took place. Experts of the Regional VeterinaryMedicine Services (RVMS) precisely assessed the situation of every company and gave particular recommendations and instructions what to change for the retention of the production activity. The changes and improvements necessary to be realized are consequently indicated in the business plan of every company for the synchronization with the new Regulations 852 and 853 of the EU. All colleagues agree that there is no place for any delay or compromises. The rules are precised and their observing is imperative. The year 2007th is after only 15 months. Now 273 companies work in the country. In 1989 and 1990 milk was processed in 53 enterprises in a twice-bigger volume. After the privatization, the Government stimulated financially the establishment of new enterprises and their number reached 826 in 1995. Now, they have decreased more than 3 times. This decrease of many enterprises for a 10-year period is mainly conditioned by the lack of financial and economic stability and appropriate sanitary and hygienic conditions, and by the unsuitable technical situation and low quality of the production. This process

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ought to be painful for many of them, but it is the normal way of economic development in the dairy branch, as it is in the present moment. Everyone should estimate really their capacity: how will they meet the hard competitive pression of the European goods and will they defend their market niche. Last years, many of our enterprises became conscious of the necessity to invest extra if they want to be able to shorten the deadlines on their way to Europe. 36 projects of 75 600 000 leva are approved as a financial support by the SAPARD program, or 33 000 000 leva are granted as gratuitous help. This year, however, the program did not start yet, in spite of the fact that many enterprises have ready projects, or are preparing them. Almost all of the enterprises, which will remain on the market, have ready plans how to accomplish the necessary reconstructions and improvements in agreement with the European Directives, Regulations of the Food law, Veterinary-medicine activities law and other legal documents. According to the legal status of the companies, about 50 per cent of them are trade companies. Lately, trade unions are created, which include vaster and vaster industrial areas, coordinate their activities and enhance their presence on the internal and external markets. It is comprehensible that the future belongs to the consolidated production. According to the Agrostatistika data, there are 25 companies processing about 100 tons per day, about 20 processing 30 to 100 tons per day, about 50 processing 10 to 30 tons per day. About 90 to 100 enterprises process 2 to 10 tons per day, and almost the same number of companies does about 2 tons per day. There is a sensible tendency of stabilization of the production and quality especially in the bigger enterprises. In the 2004 the production of the dairy products increased in comparison with the 2003.

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Table 1. Dairy foods produced Final consumption product Packed pasteurized milk (thousand liters)

Cream (tons) Natural yogurt (tons)

2003

2004

2003/2004 (%)

14 527

11 560

79,6

Semi-skimmed

8 002

9 476

118,4

Skimmed

9 534

15 095

158,3

32 063 1 062 107 063

36 130 1 284 131 631

112,7 120,9 122,9

18 202

3 769

20,7

1 463

1 938

132,5

Butter

126 728 870

137 338 1 015

108,4 116,7

Other

466

208

44,6

1 336 40 752

1 223 39 219

91,5 96,2

6 245

5 789

92,7

668

2 476

370,7

47 665 29 700

47 484 29 440

99,6 99,1

1 472

1 242

84,4

184

176

95,7

In total In total

31 356 642

30 858 553

98,4 86,1

In total In total

2 316 191

4 302 792

185,8 414,7

In total

82 170

83 989

102,2

Whole

In total In total Whole Semi-skimmed or skimmed Drink In total

Milk fats (tons)

White brined cheese (tons)

In total Cow’s cheese Sheep’s cheese Other milk cheese

Yellow cheese (tons)

In total Cow’s cheese Sheep’s cheese Other milk cheese

Processed cheeses (tons) Curds (tons) Other cheeses (tons) Cheeses in total (tons)

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The most important increase (more than 4 times) is considered about the production of non-traditional cheeses, which we explain with the enlarged production range and augmented number of the ranges. The dessert pasteurized milk and yogurts are more and more presented at the market. The production of the natural yogurt constantly increases. The cheese and the yellow cheese production level is kept high, about 83 000 tons. The production of milk fats decreased because of the high prime cost and lower prices of the imported cow’s butter.

ficiency of raw material, especially in the autumn and winter seasons. Traditionally, large quantities are imported from Ukraine (18 per cent), Germany (16 per cent), France, Romania etc. It is curious that the great import of milk powder from Ukraine is 40 per cent less compared to the year 2003rd because of the imported quantities from the European countries. As the custom agency data show, the import of dairy products in the first 6 months of the year 2005 is 15 per cent less compared with the same period of the 2004 year. We consider that this year it will be at least 10 per cent less.

The last years, in contrast to the period from 1989 until now, the less quantities of the produced milk caused the augmentation of the import of the dairy products. It satisfies the need of a consumers group whith higher financial abilities. Mainly cheeses and cow’s butter for direct consumption are imported. The most important part is the milk powder and dry whey, respectively 12 200 tons and 5 850 tons. These products take 73 per cent of the structure of import. They balance the insufTable 2 Main products Milk and dairy products – in total, tons Milk and cream, non concentrated, non sweetened Milk and cream, concentrated, sweetened Yogurts and fermented milk Whey – concentrated or in powder, non sweetened or sweetened Natural butter and milk fats Cheese, yellow cheese and curds

During the last 4 or 5 years we noticed a positive tendency of increase of the export of milk and dairy products from Bulgaria. The import in 2004 increased by 6 393 tons compared with the import in 2001, growth of 68 per cent and 8 per cent more than in the previous 2003. We expect the quantities in 2005 to increase again by 8 per cent about to 17 000 tons more than in 2004.

2001

2002

2003

2004

2004/2001 (%)

9 395

11 501

14 603

15 788

168

146

229

197

225

154

285

394

415

76

27

319

163

116

108

34

2

-

0,5

2,5

125

67

27

36

149

222

8 576

10 688

13 838

15 228

178

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The main quantities in the export list are the cheese and the yellow cheese – the quantity of all exported products is 15 788 tons, and only cheese and yellow cheese is 15 228 tons, or more than 96 per cent of the whole quantity, and above 60 per cent of them are sheep’s milk products. It shows that the original dairy products restore step by step their positions on the external markets. Last year, we almost reached the levels of the export to ex-Council for Mutual Economic Assistance markets countries before 1989. In 2004 the export prices were by 14-17 per cent higher. It is hard, however, to restore our positions in Russia and some Arabic countries. In return, the niche for Bulgarian cheese and yellow cheese was enlarged in the USA, Greece, Australia and Germany. The agreed duty-free increasing every year quotas encourage the export to the EU. The quota for the 1 July 2004 to 31 May 2005 period was 6 700 tons. According to the contracted step for the next period to 30 June 2006 the quota quantity becomes 7 000 tons. Of course, for the success of the export contributed these 28 enterprises that lately received export licenses for the European countries. Three companies are waiting for the approval of the competent institutions. Our capacity is not realized on the European markets yet. The reason for it is the variable quality of the lots of the different enterprises and the adding of milk powder in the products. The ADPB insisted that the export could be stimulated, and in 2004 export subsidies were given for cheese and yellow cheese. Unfortunately, they were used by a very little number of companies, and for the current year contracts are signed for few quantities. The dairy products’ balance is positive; in numerical expression it is 31 per cent. It is a very good achievement, in view of the unfavorable proportion in the foreign trade balance of the country where the import is predominant. We expect the presence of Bulgarian dairy products in the Euro-

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pean countries to be considerably enlarged after Bulgaria joins the EU, equalization of the custom duties, stopping of state assistance to the production of cow’s milk and export to many European countries. For this reason, many efforts are needed to improve the quality of the raw milk and constant high quality of the production. We have important opportunities to enhance the export to another countries, like USA, Canada, Australia, the Arab countries, etc.

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In the country, there is a positive tendency of stabilization and consolidation of the existing important stockbreeding companies. 9 per cent higher than last year is the number of farms where more than 10 dairy cows are bred. In general, smallsized disunited production structure keeps predominating. About 51 per cent of the cows are bred in little cattle breeding farms. This unfavorable organization leads to lower effectiveness, difficult selection activity, insufficient sanitary and hygienic conditions and unsatisfactory feeding about yield of milk of high quality, especially concerning the microbiological aspect.

STATUS OF THE MILK-PRODUCING SECTOR The activities in the dairy industry depend on the production of raw milk in the country and on the quantities industrially processed. After the privatization and the changes in the agriculture and livestock breeding sector, more than 90 per cent of the dairy cattle were given back to the farmers, and 30 per cent were sold to the meatprocessing plants. Quantities of milk to process reduced almost 3 times. Table 3. Production and distribution of raw milk №

1

Number of animals, average milk yield and raw milk production Milk cow – number Average milk yield – liters Production – tons Sheep dams – number

2

Average milk yield – liters Production – tons Goats dams – number

3

Average milk yield – liters Production – tons Cow-buffalos – number

4

Average milk yield – liters

2002

2003

2005 prognosis

2004

358 178

361 846

368 719

362 000

3 540

3 511

3 541

3 540

1 305 912 1 379 061

1 308 525 1 278 759

1 344 750 1 351 212

1 319 924 1 332 000

82

67

84

8411

93 479 619 465

88 679 592 572

117 682 578 501

5 804 583 000

189

167

217

200

104 820 3 927

101 530 4 542

129 381 4 056

119 981 4 175

1 100

1 133

1 488

1 400

Production – tons 4 410 5 276 6 229 6 032 It is the situation of the dairy cattle-breeding sector. The low average milk yield of the animals does not stimulate the investing for ameliorations of We can see that the data show an increasing the conditions needed to the milk production. In number of the cows and cow-buffalos in the last the following table are shown quantities of proyears, and a decreasing number of sheep dams duced milk and its distribution. and goat dams.

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Table 4. Production and distribution of the raw milk

Kind of milk

Milk collected to be processed in the dairies, thousand liters 2003 2004

Use in the farms, thousand liters

2004

2003

774 310

231 107

273 155

247 388

2 780

1 750

847

3 039

1 470

1 246

5 097

6 035

46 496

40 538

1 466

16 585

37 718

56 580

85 680

113 703

2 331

2 359

2 180

1 941

94 158

121 434

98 669

125 734

818 957

235 600

294 720

380 734

437 377

1 459 860

1 551 054

In total: 843 525

In 2004 the milk production in the country is increased by 6 per cent, mainly because of the cow milk quantities. The milk for industrial processing is about 53-55 per cent (as Agrostatistika data show). It turned out that a great part of the milk quantities is used in the farmers’ families for food and for feeding calves, or is sold for use in the households. The production of raw milk is the most important for the dairy sector and takes the main part in the milk raw material in the country (84 per cent). The sheep milk yielded in 2004 considerably increased by 33 per cent. It takes, however, only 7,5 percent of the produced milk in the country. We expect the same quantities of raw milk in 2005 and estimate that the goat and sheep milk will increase. As seen in the table, the part of the milk to be processed in 2004 decreased to 53 per cent. The direct sales from the farms achieve 25 per cent and the quantities for satisfying the families’ needs (to be directly consumed, processed in dairy products or for animals feeding) grow to 22 per cent.

2004

Total quantities of yielded milk, thousand liters

2003

Cow milk 791 918 Cowbuffalo milk Sheep milk Goat milk

Direct sales in the farms, thousand liters

2003

258 117 1 270 413

2004 1 305 582

Great are the direct sales and the quantities of sheep and cow-buffalo milk used in the farms, respectively 64 per cent and 70 per cent. The shown quantities of the goat milk for industrial processing are unreal, because great part of it is mixed with the cow milk. There are reserves for the increasing of the milk for industrial processing, indeed, and they depend on the purchase price and on the prices of the dairy foods on the market. It is expected that the production of dairy products in the families in the following years will decrease, as well as the direct sales from the farms. The basic factor in the production and price making of the dairy products is the cost of the raw milk that takes about 60 per cent in the prime cost of these products. Lately, the milk purchase price becomes stable at a satisfying level. In 2004 it increased to 0,38 leva per liter for the cow milk – it is 22,6 per cent more than in the previous year. Comparatively stable and suitable are the prices of the other kinds of milk (sheep, goat and cow-buffalo milk). The sheep milk is the most expensive and sheep’s milk products are directed generally onto international markets.

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This year started with a higher raw milk price, in comparison to the average in 2004. Respectively, it is 18,5 percent related to the average in 2004 and 2,3 percent related to the one in the first three months. Lately, prices became stable and are regularly paid by the dairy processors.

The dairy products prices normally follow the raw material price. In 2004 and in the first six months of the current year consumers bought dairy foods on real achievable prices. It is normal that they are higher than in the previous periods. In 2003 and in 2004, we see a logical movement and relation of the purchase price of the cow milk, of the cheese and cow’s cheese trade and retail prices (tables 5, 6 and 7).

Table 5. Cow milk purchase prices took by three-month periods 2003 Period

Cow milk – leva/l

2004

I

II

III

IV

average price

0.30

0.28

0.28

0.38

0.31

I

II

III

IV

averaver- age age price price

2005 I

II

0.44 0.36 0.32 0.40 0.38 122.6 0.45 0.36

Table 6. Trade prices 2003 Products Milk, leva/l Yogurt, leva/ piece Cow’s butter, leva/kg Cow’s cheese, leva/kg Vitosha yellow cheese, leva/kg

2004

2005 ave- 04/03 rage (%) price

IV

average price

I

II

0.78 0.77 0.77

0.79

0.78

0.80

0.79

0.78 0.80 0.79 101.3 0.85 0.84

0.46 0.45 0.45

0.46

0.46

0.47

0.46

0.46 0.47 0.47 102.2 0.47 0.47

4.53 4.43 4.46

4.64

4.52

4.86

4.75

4.56 4.75 4.73 104.6 4.82 4.85

2.66 2.56 3.09

3.28

2.90

3.37

2.89

3.20 3.42 3.22

5.29 5.18 5.23

6.28

5.50

6.99

6.14

5.88 6.54 6.39 116.2 6.79 6.43

I

II

III

III

IV

111

I

II

3.55 3.28

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Table 7. Retail prices 2003 Products Cow milk, leva/l Cow’s yogurt, leva/ piece Cow’s butter, leva/ 125 g Cow’s cheese, leva/kg Sheep’s cheese, leva/ kg Vitosha yeloow cheese, leva/ kg

I

II

III

2004 IV

average price

I

II

III

2005 IV

ave- 04/03 rage (%) price

I

II

0.89 0.88 0.88 0.89 0.89 0.90 0.90 0.89 0.91 0.90 101.1 0.95 0.94 0.52 0.51 0.51 0.52 0.52 0.53 0.52 0.51 0.52 0.52

100

0.78 0.77 0.76 0.78 0.77 0.78 0.78 0.73 0.74 0.76

98.7

0.53 0.76

0.53 0.75

3.03 2.97 3.45 3.70 3.29 3.85 3.34 3.62 3.85 3.67 111.6 3.95 3.69 5.57 5.43 5.41 5.62 5.51 5.72 5.64 5.46 5.65 5.62

6.02 5.87 5.94 6.96 6.20

102

5.71 5.78

7.75 6.91 6.58 7.16 7.10 114.5 7.53 7.15

It is seen that the prices of the milk vary depending on the season of its production, and the trade and retail prices of the cow’s cheese follow logically the same movement.

ment, issue 98/05.11.2004).

During the last years, efforts are made so that the legal basis is brought to the European Directives. Now a number of government documents are acting concerning the production and the market demand of milk and dairy products. Most important of them are:

5. Regulation about the specific requirements towards appellation and labeling of milk and diary products demanded on the market (State Journal, issue 11/10.02.2004).

1. Regulation №30 from 20 November 2000 about the veterinary and sanitary requirements towards the yield of raw milk, production of dairy products, building and exploitation of the dairy processing enterprises. 2. Stock-breeding law. 3. Regulation about the requirements for labeling and presentation of the foods (State Journal, issue 62/28.07.2000, amend-

4. Regulation № 31 about the safest norms of pollutants in foods (State Journal, issue 88/08.10.2004).

6. Regulation about the specific requirements towards fats to spread (State Journal, issue 22/15.03.2005). 7. Regulation №4 about the order for reception of applications, supplying files with foods with specific non-traditional characteristics (State Journal, issue 23/18.03.2005). 8. Regulation №6 about monitoring of the cow’s milk and dairy foods produced and distributed on the market (State Journal, issue 50/17.06.2005).

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9. Regulation about the order of issuing agriculture products import licenses in the frame of the tariff quotas. On a preliminary discussion session the Parliament accepted a new Veterinary medicine activities law conformable to the newest European norms. In accordance with the Stockbreeding law on 15 April 2005 a National Dairy Board was founded, which is an interprofessional organization of producers, processors and commercials of dairy products whose basic mission is to develop milk and dairy foods production, processing and trade, and protect common interests of the companies in this sector. The Board will direct and control the origin, the authenticity and the quality of the traded products and will participate in the distribution of the production quotas. It will research the technical, economic, financial, juridical and other problems related to the global development of the production and distribution of raw milk and dairy products. Eight regional Dairy Boards are now being structured. This year, the Ministry of Agriculture provides for 850 000-leva budget subsidy for the start of the Boards. Foundation of an interprofessional organization is a direct commitment of the state and the Ministry of Agriculture concerning the obligations in Agriculture section. For controlling the raw milk and dairy products quality is provided the building of three laboratories as a PHARE project that will start before the end of the current year. In the coming 15 months before the country joins the EU, the basic mission of the ADPB is to cooperate with the Ministry of Agriculture and the National Veterinary Medicine Service and to prepare the different structure of the dairy branch. The dairy enterprises should respond to the requirements and levels of the European norms if they want to become a part of the European dairy industry and common markets.

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According to the decision made by the Board of Directors the ADPB applies for membership in the European Dairy Association (EDA). All formal procedures are done and during the General meeting that is lying ahead in the end of this month in Warsaw, we expect our application to be approved. Priority in the work of the members of the National Dairy Board is to prepare successfully the applying and management of the quota principle when raw milk is yielded and processed, according to the quotas quantities defined by the EU. Table 8. National raw milk quota NATIONAL RAW MILK QUOTA 1. National quota - 979 000 tons •Delivery quota - 722 000 tons •Direct sales quota - 722 000 tons •Referent fat content – 3,91% For this purpose, the Ministry of Agriculture issued Regulation №6, which regulates clearly and precisely all consecutive steps. Before the end of this year we plan to pick up real information about the production and distribution of the raw milk, and in April 2006 we would like to introduce experimental quotas. Before the end of this year and in 2006 the dairy processing companies are to introduce the HACCP system. It is based in the Food law. Up to now the HACCP system is introduced in about 10 per cent of the enterprises. All of the other companies work actively in this direction. Because of a program of the Ministry of Economy, 79 enterprises obtained as gratuitous help 721 045 leva for approved projects introducing the HACCP system. Their own co-financial part value is 1 587 774 leva. We look forward to the middle of the 2006 when will be introduced functioning systems, which

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control sanitary and hygienic conditions and quality of dairy products. We expect more precise programming and realization of measures for higher effectiveness and competitiveness of the enterprises. According to the European Directives and our obligations in the Agriculture section, after 1 January 2007 the producers of dairy products will process not only milk that meets the European standards, but also milk with lower value according the regime of the derogation. From this milk, until 2010, only foods for the internal market will be produced. For this purpose, the enterprises prepare special technological sets of machines. To the end of 2006 will be particularly defined the processors of:

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activities, and young stockbreeders are much assisted. All these measures and activities, which are subject to our attention, must ensure the production of high qualified and competitive dairy products. For the dairy branch, an interesting possibility is the production of biological (ecological) foods. This is an opportunity to increase the incomes of the farmers and the effectiveness of the dairy foods produced in our enterprises. It is well known that dairy products are a part of the three principle types of pure ecological foods supplied on the world markets. It is noticeable that their sales increase the most, to 25-26 per cent per year. In the country, there are circumstances about such production and it is obligatory for us to profit by it.

- milk meeting the European Directives; - milk which value is lower; - milk of both categories. It is comprehensible that the health-prophylactic measures and control of the milk quality can be realized in the consolidated stock-farms. The ADPB and major processing companies are searching for forms and ways to stimulate and directly assist farmers to consolidate the production by buying high productive animals, by partially financing pedigree-stockbreeding, organized supply of fodder and health-prophylactic activities, etc. In this direction, in the frame of the Animal Husbandry program, the Ministry of Agriculture has set apart credits of 15 000 000 leva from Agriculture State Fund for this year, and the conditions are much benign for machines, equipment, buildings reconstructions, etc. For the first quality milk produced and given for processing is provided a purpose subsidy of 9 000 000 leva. Such subsidies are for feeding animals of the national gene pool and the import of high producing brood animals and series of other

For the short period until 2007 the preparation for the new conditions will be accomplished, and there will be many more specific problems we are obliged to cope with. The tasks lying ahead in the dairy branch are difficult and complicated. We are convinced that we will resolve them with common efforts and synchronization in the work of the branch organizations and state administrative structures in one hand, and in the other, with colleague consulting assistance of the European countries, especially the new members, so that we could surely step after 15 months on the vast European road and walk confidently on it.

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