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Export Certification and Role of Export Certification and Role of Equivalence Agreements in Food SectorEquivalence Agreements in Food Sector

By

R BALAKRISHNANJoint Director, EIC

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WTO SCENARIOWTO SCENARIO

Establishment of WTO - Dismantling of barriers for free flow of trade

Creation of global market with equal access to all countries

Quality & safety importantEnvironmental Issues gaining importanceRole of standards & CA proceduresNecessary to lay down rules and disciplines.Non-tariff agreements – SPS & TBT

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SPS AGREMENT SPS AGREMENT

Allows countries to set their own standards for health and safety– Scientific basis, apply to extent necessary, MFN

treatment, National treatment principle Harmonization (Codex)

– Higher standards based on risk assessmentTransparency Equivalence

– Allows countries to use different standards & different inspection methods

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TBT AGREEMENTTBT AGREEMENT

Country has right to adopt voluntary standards & technical regulations

Code of good practice for standards devtEncourages adoption of international stdsRecognition of each others testing & CA

proceduresAcceptance of inspection & tests of CA

based on equivalence

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SAFETY MANAGEMENT SYSTEMS SAFETY MANAGEMENT SYSTEMS APPROACH APPROACH

Shift from CWI to Systems Approach-HACCP/9000

Conrol systems which focus on preventive measures instead of relying on end-product testing for health & safety or quality aspectsSome countries stressing on infrastructural

aspects eg milking machines, flake ice machines; primary production etc

Concept of equivalence needs to be recognised

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CONCEPT OF EQUIVALENCE IN CONCEPT OF EQUIVALENCE IN THE SPS AGREEMENT (THE SPS AGREEMENT (Article 4)Article 4)

“Members shall accept the SPS measure of other members as Equivalent, even if these measures differ from their own or those used by other members trading in the same prod, if the exporting member objectively demonstrates to the importing member that its measures achieve the importing member’s appropriate level of sanitary or Phyto-Sanitary protection”

Members shall upon request, enter into consultation with the aim of achieving bilateral or multilateral agreements or recognition of the equivalence of specified SPS measures.

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EQUIVALENCE AGREEMENTSEQUIVALENCE AGREEMENTS Purpose

Conformance to import requirementsAvoid duplication – use collective resources more

effectively & efficientlyProvide mechanism for cooperative exchange of

expertise, assistance & information to meet requirements

Cover - exchange of information on standards, recognition of certification, provision for retest and appeal, return of rejected consignments

Problems- need: admin burden – control - income - important components not addressed - (SLSI, Canada, USA)

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EXPORT QUALITY CONTROL – EXPORT QUALITY CONTROL –

A BACKGROUNDA BACKGROUND Export (QC&I) Act, 1963 – umbrella Act governing

quality of exports EIC set up to advise Government on measures for

sound development of exports through QC & I to include notification of standards & certification systems

Powers of Central Government under the Act Notify commodities for compulsory PSI Specify standards for export and type of QC & I Establish or recognise Agencies for QC & I

Nearly 1000 commodities notified

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EIC STRUCTUREEIC STRUCTURE Apex Body – Council, Chairman, 18 members,

Member Secretary- Director, EIC Specialist Committees EIC – The Organization

CEO Director, office at Delhio Powers of ‘Head of Department’o Administering export certificationo Administrative & technical control of EIC & EIAs

Machinery for Export Certification – 5 EIAs at Mumbai, Kochi, Kolkata, Delhi and Chennai, under administrative & technical control of EIC

41 Sub-offices & labs Manpower - SS 804; ES 917; vacancies around 70 Financially self supporting

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EIC-ROLE IN WTO REGIMEEIC-ROLE IN WTO REGIME Regulatory role to

address health & safety concerns of importing countries compulsory certification for Marine products, Egg products,

Milk products, Honey products, Poultry Meat products etc. Voluntary export certification – Tea, F&V, Spices,

Basmati Rice Equivalence Agreements/MOUs with trading partners

for recognition of EIC’s certification Certificate of Health (Food items), Authenticity

(Basmati Rice-EC) Laboratory Testing

Support for Export Inspection & Certification Commercial testing (facilities extended to industry) Import testing of food items-EIA Labs identified by MoH&FW

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INTERNATIONAL RECOGNITIONSINTERNATIONAL RECOGNITIONS• ECEC - Designated CA for marine products and issuance of - Designated CA for marine products and issuance of

authenticity certificate for basmati rice; dialogue on for dairy authenticity certificate for basmati rice; dialogue on for dairy products, egg products, poultry meat & honeyproducts, egg products, poultry meat & honey

• USA (USFDA)USA (USFDA) - recognized for Black Pepper – no detention if - recognized for Black Pepper – no detention if accompanied by EIC certificate; initiated dialogue for other foodsaccompanied by EIC certificate; initiated dialogue for other foods

• Australia (AQIS)Australia (AQIS) - recognized in December 2002 for marine - recognized in December 2002 for marine products – maximum 5% consignments to be subjected to random products – maximum 5% consignments to be subjected to random verification- seeking for dairy products, spices etc.verification- seeking for dairy products, spices etc.

• Sri Lanka (SLSI)Sri Lanka (SLSI) - recognized for 85 products regulated by - recognized for 85 products regulated by Sri Lanka (food, cement, engineering items, electrical appliances Sri Lanka (food, cement, engineering items, electrical appliances etc. – Agreement signed in Dec’ 2002 – Assessment by SLSI team etc. – Agreement signed in Dec’ 2002 – Assessment by SLSI team in April 2003 – level of inspection reduced to 25% in 1st yearin April 2003 – level of inspection reduced to 25% in 1st year

• SingaporeSingapore – negotiating MRAs in area of food & agri, electrical – negotiating MRAs in area of food & agri, electrical & electronics, drugs, telecommunication& electronics, drugs, telecommunication

• OthersOthers - EU countries, S.Korea, Libya, Japan, Canada, Argentina - EU countries, S.Korea, Libya, Japan, Canada, Argentina

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SYSTEMS OF INSPECTION & SYSTEMS OF INSPECTION & CERTIFICATIONCERTIFICATION

Consignmentwise inspectionSystems Approach

In-Process Quality Control Self-Certification Approval and monitoring of processing and

manufacturing units based on food safety management systems such as GMP/ GHP / HACCP.

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PRODUCTS COVERED UNDER PRODUCTS COVERED UNDER EXPORT CERTIFICATIONEXPORT CERTIFICATION

Nearly 1000 commodities notified in all sectors (Food, footwear, chemicals, engineering, leather, jute etc.)

Under Mandatory Certification Fish & Fishery Products Dairy Products Egg Products Poultry Meat & Poultry Meat Products Honey Raw Meat (Frozen/chilled), Processed Meat

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PRODUCTS COVERED UNDER PRODUCTS COVERED UNDER EXPORT CERTIFICATION EXPORT CERTIFICATION (Contd.)(Contd.)

Under Voluntary Certification Covers any food item, primary or processed including

snack/ready-to-eat food products. Envisages both Consignment-wise and in-process approval

system certification. Certificate of Inspection/Health Certificate can be issued

as per requirement. Basis of certification: Buyer’s/ Importing Country’s/

Codex/ ISO/ Any International Requirements. Details available on website: http://www.eicindia.org

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CERTIFICATION BASED ON FOOD CERTIFICATION BASED ON FOOD SAFETY MGMT SYSTEMS APPROACHSAFETY MGMT SYSTEMS APPROACH

• Food items covered include marine products, milk products, egg products, poultry products, honey.

• Requirements for approval of processing plants. - GMP/GHP/HACCP - Minimum test facilities - Waste disposal/Effluent treatment mechanism - Record keeping mechanism - Competence of technical manpower - Conformance of products to standards

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3-TIER SURVEILLANCE SYSTEM3-TIER SURVEILLANCE SYSTEMMONITORING BY EIA OFFICIALS TO VERIFY

– Sanitation & Hygiene– Process controls– Implementation of HACCP plan– Records– Observe testing by laboratories– Draw samples of raw materials, water , ice, finished

products, swabs of workers hands and work places

SUPERVISORY VISITS TO CHECK– Compliance to norms by processors– Quality and correctness of monitoring by EIA officers.

CORPORATE AUDITS– Independent audit by EIC to verify operation of

scheme by EIAs as per documented systems.

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CONCERNS RELATED TO EXPORTSCONCERNS RELATED TO EXPORTS Exports continuing without approvals-honey, egg Residue control important – RMP, coordination b/w

various organizations, prohibiting use of certain antibiotics in livestock products

In case of systems approach, processing to be only in ‘Approved Units’

Deficiencies observed relate to HACCP implementation etc

Not a one-time approval–maintaining system imp Raw material control & traceability lacking Tampering with certificates

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Thank youThank you