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Health andConsumers
IMPORT OF ABP
U.GALJOT, M. MAHNE
Better Training for Safer FoodInitiative
Health andConsumers
Hazardous
waste
Reg
1013/2006
TSE
Reg
999/2001
Directive
97/78
Decision
2007/275
Reg
142/2011
Reg
1069/2009
IMPORT
Health andConsumers
African swine fever
Georgia, 2007
Pigs were fed ASFV contaminated pork brought in on ships
Health andConsumers
Veterinary checks
• All ABP/DP in the scope of Reg 1069/2009 whichmay be imported are subject to veterinary checks
• Concept of end point does not apply to imports(Reg.142/2011 Article 3)
• Which ABP/DPs are subject to veterinary checks isdetermined by whether they are listed inCommission Decision 2007/275 not whether theyhave reached an end point
4
Health andConsumers
Overview of general requirements forimport/transit - Article 41 of Reg 1069/2009
• Imports/ transits must comply with relevant requirements of Reg 1069/2009 and Reg 142/2011
• Conditions to be at least equivalent to the production and marketing requirements of such ABPs/DPs under Community legislation; or
• ABPs/DPs referred to in Articles 33, 35 and 36 -
requirements set out in those Articles must be met
• Cat 3 ABPs/DPs:
• (a) third country on a Community list;
• (b) establishments/plants of origin approved or registered by the CA of the third country and listed for that purpose;
• (c) health certificate / commercial document / declaration which corresponds to the model laid down. 5
Health andConsumers
Exceptions1. SRM – import / transit - only in accordance with Reg
999/2001
6
2. ABPs/DPs mixed with hazardous waste - (hazardous wastes
are listed in CD 2000/532) - to be dealt with in accordance with Reg 1013/2006 (which covers shipment of hazardous waste)
3. Cat 1 or Cat 2 ABP/DPs not intended for manufacture of
• Article 33: Cosmetics, Medical devices, Medicinal products etc.
• Article 35: Pet food
• Article 36: Derived products other than feed for farmed animals (exc. fur), organic fertilisers, soil improvers
imported in line with implementing measures – Reg 142/2011
4. ABPs/DPs for exhibitions, artistic activities, diagnostic, educational or research purposes – partially harmonised rules
Health andConsumers
• Import of ABP that we consider as SRM from OIE negligible risk countries (example: USA)
• Clarification from the Commission
• Tissues, which in the EU are defined as SRM, are allowed to be imported into the EU from third countries with negligible BSE risk status.
• In 2007, Annex V of the TSE Regulation was amended to be brought in line with OIE rules (in which, since 2005, the concept of SRM is applicable only to controlled and undetermined BSE risk countries)
• A derogation was introduced for EU MS with negligible risk status only.
• Commission Decision 2007/453 lists countries according to their BSE risk status, was amended in 2013 to reflect the fact that the USA had negligible risk status.
• No legal basis to refuse imports into the Union of tissues comprised in the EU SRM list when they originate in the USA, since they are not legally defined as SRM in this case. 7
Health andConsumers
Reg 142/2011 Import and transit requirements
Article 25 Reg 142/2011 details
• Prohibited ABPs
• ABP/DPs with no animal health controls
• Materials which can be imported / transited. Requirements to be met are in Annex XIV – divided into 4 Chapters
8
Health andConsumers
Products not subject to animal health conditions
Wool and hair
Factory-washed or treated by another method
Treated and dispatched directly to a plant producing derived products for the textile industry
Untreated, dry and securely enclosed in packaging, intended for dispatch to a plant producing derived products from wool and hair for the textile industry and meets specific requirements.
• Furs which have been dried at an ambient temperature of 18°C for a period of at least two days at a humidity of 55 %.
• Not listed in CD2007/2759
Health andConsumers
Greasy wool. Not securely enclosed in packaging!
Health andConsumers
Health andConsumers
Reg 142/2011: Products not subject to animal health conditions - OF/SI
Mineralised bat guano
If not mineralised: import conditions
Guano from wild sea birds
Art. 22 of 142/2011
12
Health andConsumers
List of prohibited ABPs
• Unprocessed manure
• Unprocessed feathers, parts of feathers
• Beeswax in form of honeycomb
Health andConsumers
14
Health andConsumers
Health andConsumers
16
Health andConsumers
Reg 142/2011 Import/transit
Import / transit conditions: Annex XIV – divided into 4 chapters:
1.Chapter 1: Cat 3 ABPs/DPs for farmed animal feeduse (excluding farmed fur animals)
2.Chapter II: ABPs/DPs not for farmed animal feeduse.
3.Chapter III: Research and diagnostic samples,trade samples, display items
4.Chapter IV: Certain Other ABPssome Category 1 materials
some Category 3 materials for feeding to animals other than farmed animals. e.g. mealworms, fishing bait
17
Health andConsumers
18
Table 1
3. Import and transit conditions:(a)The processed animal protein must have been produced in accordance with Section 1 of Chapter II of Annex X, (b) the PAP shall comply with the additional requirements set out in Section 2 of this chapter
4. Third country lists: PAP exc fishmeal: 3rd countries in Reg 206/2010 Annex II Part IFishmeal: 3rd countries CD2006/766 Annex II
5. Certificates / model documents: Annex XV Chapter 1
1. Product: Processed animal protein
2. Raw materials ref Reg 1069/2009): Cat. 3 materials Article 10(a),(b),(d),(e),(f),(h),(i),(j),(k),(l),(m)
Health andConsumers
1 in 6 bagged PAP and all bulk PAP sampled for salmonella.
•All fishmeal must be sampled for terrestrial bone (Reg 999/2001 Annex IV II.B.b). Sampled in accordance with Reg 152/2009.
•Analysed in accordance with Reg 56/2013
FishmealRequirement to sample is in 999/2001 Annex IV II.B.bSampling procedure and analytical method in Reg 152/2009
Fish meal for animal feed
Health andConsumers
20
Reg 56/2013 - Ammending Reg 999/2001
Each consignment of feed materials and
compound feed, intended to be used for the
feeding of non-ruminant farmed animals (except fur
animals): analysed to verify the absence of
unauthorised constituents of animal origin
a) PAP - including fishmeal, derived from non-
ruminants;
b) Blood products derived from non-ruminants;
c) Compound feed containing feed materials
listed in a) and b).
Health andConsumers
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Health andConsumers
I want to import OF/SI, produced from mixture of unprocessed manure and PAP.
Is it permitted?
A. - No, it is banned
B. - Yes, in line with requirements for import of PAP
C. - Yes, in line with national rules
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I want to import OF/SI, produced from mixture of unprocessed manure and PAP.
Is it permitted?
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A.
B.
C.
- No, it is banned
- Yes, in line with requirements for import of PAP
- Yes, in line with national rules
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Health andConsumers
Company wants to import used cooking oil (UCO) for the manufacturing of Biodiesel.
Is this permitted?
A. - No, it is banned
B. - Yes, UCO can be imported in line with national requirements of the MS of destination
C. - Yes, UCO for production of biodiesel are out of scope of ABP legislation
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Health andConsumers
Company wants to import used cooking oil (UCO) for the manufacturing of Biodiesel.
Is this permitted?
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A.
B.
C.
- No, it is banned
- Yes, UCO can be imported in line with national requirements of...
- Yes, UCO for production of biodiesel are out of
scope of...
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Health andConsumers
SECTION 4
IMPORT of TREATED HIDES & SKINS
(i) a third country or, in the case of regionalisation in accordance with Union legislation, from a part of a third country, appearing on the list set out in point (a) of the column ‘third countries’ list’ of row 5 of Table 2 set out in Section 1 from which imports of fresh meat of the corresponding species are authorised and they have been treated as referred to in point 28(a), (b) and (c) of Annex I;
•(ii) a third country appearing on the list set out in point (a) of theapplicable column of row 5 of Table 2set out in Section 1 and they have been treated as referred to in point 28(c) or (d) of Annex I;
LIST OF TC IN TABLE
Health andConsumers
Import of research and diagnostic samples, trade samples and display items
• Reg 142/2011
• Art.27 – Research & diagnostic samples
• Art. 28 – trade samples and display items
• Chapter III of Annex XIV
• Questions:
• Authorisation in advance by MS of destination?
• From which TCs?
• Health requirements?
• Health certificate?
• Listing of exporting establishment in TRACES?
Health andConsumers
28
Commodity List of third
countries
Health
requirements
Health
certificates
Listing of
exporting
establishment
into TRACES
Research and
diagnostic
samples
At the
discretion of
CA of MS of
destination
At the
discretion of
CA of MS of
destination
At the
discretion of
CA of MS of
destination
NO
Trade
samples
row 14
Tbl 2; Sect. 1;
Chapt. II;
Annex XIV
At the
discretion of
CA of MS of
destination
Certificate
Chapter 8 of
Annex XV
NO
Display items row 14
Tbl 2; Sect. 1;
Chapt. II;
Annex XIV
At the
discretion of
CA of MS of
destination
At the
discretion of
CA of MS of
destination
NO
Health andConsumers
Annex XIV Chapter IV
Section 1: Category 1 materials (ref article 26)
Must not be for feeding, OF/SI for grazing land, cosmetics, medical devices, etc:
• Hides and skins subject to an illegal treatment
• Ruminant intestines with or without contents
• Bones and bone products containing vertebral column and skull (to be TSE free)
Harmonised conditions on:
• Labelling : ‘Prohibited in food, feed, fertilisers, cosmetics, medicinal products and medical devices’.
• To be delivered direct to approved / registered ests.
• Disposal29
Health andConsumers
Section 2: Certain materials for purposes
other than feeding to farmed land animals
ABPs from aquatic animals
from aquatic & terrestrial invertebrates
Rodentia and Lagomorpha: animals and parts
“The CA may authorise for purposes other than feeding to farmed land animals, except for feeding to fur animals, provided there is no unacceptable risk for the transmission of diseases communicable to humans or animals”
(i.e. national rules)30
Annex XIV Chapter IV
Health andConsumers
Health andConsumers
SI national rules:• TC list: members of OIE• ABPs/DPs deep frozen or dried (Salmonella!)• Packed and labelled• Certificate• Sent directly to plant of destination
Health andConsumers
Import of intermediate productsAnnex XII of Reg 142/2011
• Allowed category depending on the intended use
• Category 2 and 3
• TC of origin: member of OIE
• Establishment/plant of origin on the list
• Accompanied by a model declaration – Chapter 20 of Annex XIV
• Additional guaranties for Cat 2 materials
• After check at the BIP Sent directly to:
• Registered plant for production of final products
• Approved storage
• BIP vet to inform Local Veterinary Unit responsible for the destination via TRACES
Health andConsumers
Establishment lists
Article 41 of 1069/2009: The lists of establishments… shall be kept up to date and communicated to the Commission and the Member States and made available to the public.
Regulation 749/2011“they must come from an establishment or plant which is registered or approved by the competent authority of the third country, as applicable, and which is on the list of such establishments and plants referred to in Article 30”
Central lists maintained by Commission and registered in TRACES
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Health andConsumers
Establishment lists in TRACES &Commission website
Health andConsumers
36
Channelling
1. Directive 97/78 (Article 8.4)a. Blood/blood productsb. Bone/bone products, horns/horn products,…c. ABPs for production of feed, pet food,…d. Rendered fatse. Trade samples
2. Sent directlya. Woolb. Research/diagnostic samplesc. Display itemsd. Certain Category 1 materials
Health andConsumers
Channelling requirementsDirective 97/78 Article 8.4
• Transported in leak-proof containers
• Containers sealed by competent authority
• Under T5 control - Customs
• BIP vet to inform Local Veterinary Unit (LVU) responsible for the destination via TRACES
• Destination establishment must confirm arrival to their LVU
• LVU must then inform BIP via TRACES within 15 days
• Products to undergo required treatment at destination
• LVU must check establishment’s records periodically
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Health andConsumers
Can products for human consumption that fail veterinary checks at BIP
become ABP?
A. - No, they have to be destroyed or returned
B. - Yes, they become Category 3 ABP
C. - Yes, they become Category 2 ABP
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Can products for human consumption that fail veterinary checks at BIP become ABP?
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- Yes, they become...
- Yes, they become...
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Health andConsumers
Unloading International Catering Waste
Health andConsumers
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International Catering Waste –Category 1 - It can be buried in authorised landfill.
In SLO – Cat 1 Processing plant
Health andConsumers
Health andConsumers
Consumers, Health And Food ExecutiveAgency
Better Training for Safer Food
BTSF
JVL Consulting s.a.
Rue Matagne 15
B-5020 Vedrin
Belgium
Website: http://btsf.euroconsultants.be
•European CommissionConsumers, Health and Food Executive Agency
DRB A3/042L-2920 Luxembourg
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