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Health and Consumers IMPORT OF ABP U.GALJOT, M. MAHNE Better Training for Safer Food Initiative

Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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Page 1: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

Health andConsumers

IMPORT OF ABP

U.GALJOT, M. MAHNE

Better Training for Safer FoodInitiative

Page 2: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

Health andConsumers

Hazardous

waste

Reg

1013/2006

TSE

Reg

999/2001

Directive

97/78

Decision

2007/275

Reg

142/2011

Reg

1069/2009

IMPORT

Page 3: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

Health andConsumers

African swine fever

Georgia, 2007

Pigs were fed ASFV contaminated pork brought in on ships

Page 4: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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

Page 5: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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

Page 6: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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

Page 7: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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

Page 8: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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

Page 9: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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

Page 10: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

Health andConsumers

Greasy wool. Not securely enclosed in packaging!

Page 11: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

Health andConsumers

Page 12: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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

Page 13: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

Health andConsumers

List of prohibited ABPs

• Unprocessed manure

• Unprocessed feathers, parts of feathers

• Beeswax in form of honeycomb

Page 14: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

Health andConsumers

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Page 15: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

Health andConsumers

Page 16: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

Health andConsumers

16

Page 17: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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

Page 18: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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)

Page 19: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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

Page 20: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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).

Page 21: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

Health andConsumers

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Page 22: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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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Page 23: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

Health andConsumers

I want to import OF/SI, produced from mixture of unprocessed manure and PAP.

Is it permitted?

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A.

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- No, it is banned

- Yes, in line with requirements for import of PAP

- Yes, in line with national rules

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Page 24: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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

24

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Page 25: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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Company wants to import used cooking oil (UCO) for the manufacturing of Biodiesel.

Is this permitted?

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- 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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Page 26: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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

Page 27: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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?

Page 28: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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

Page 29: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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

Page 30: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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

Page 31: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

Health andConsumers

Page 32: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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

Page 33: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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

Page 34: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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

34

Page 35: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

Health andConsumers

Establishment lists in TRACES &Commission website

Page 36: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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

Page 37: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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

37

Page 38: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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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Page 40: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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Unloading International Catering Waste

Page 41: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

Health andConsumers

Page 42: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

Health andConsumers

International Catering Waste –Category 1 - It can be buried in authorised landfill.

In SLO – Cat 1 Processing plant

Page 43: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

Health andConsumers

Page 44: Better Training for Safer Food - mapa.gob.es...Health and Consumers Exceptions 1. SRM –import / transit - only in accordance with Reg 999/2001 6 2. ABPs/DPs mixed with hazardous

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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