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Private Food Standards and their Impacts on Developing Countries

Grace Chia-Hui Lee Stagiaire European Commission DG Trade Unit G2

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ACKNOWLEDGEMENT In the course of writing this report, the following people have been consulted. Some of them offered personal meetings to discuss while others gave valuable input in writing or on the phone. Without their willingness to be of assistance, this report could not have been completed. I would like to take this opportunity to thank the following officials in DG SANCO for their explanations of EU legislation on food safety: Michael Scannell, Wolf-Martin Maier, Willem Daelman, Bas Drukker, Frans Verstraete, Ronald Dwinger, Xavier Pavard, Thierry Chalus, as well as Andrew Owen-Griffiths of the FVO. I would also like to thank Gesa Wesseler and Denis De Froidmont of DG AGRI, Florence Van Houtte of DG DEV and Juergen Helbig of DG ENV for your valuable perspectives. Many sincere thanks also to the following people/organizations outside of the Commission for information and discussions: Nigel Garbutt (EurepGAP), Kevin Swoffer (BRC), Ad Klaassen (Dutch Produce Association), Guy Stinglhamber (PIP), Sylvie Fontaine (PIP), Bill Vorley (IIED), Andrew Graffham (NRI), Johannes Kern (Amber Foundation), Stephanie Williamson (PANUK), Linda Fulponi (OECD), Ellen Pay (Freshfel) and Tom Lyall (Freshfel). I am very grateful that Professor Horst Krenzler (University of Munich) took his time to comment on legality of private food standards in the WTO. I also appreciate a great deal what Luis Manuel Portero Sanchez of DG TRADE contributed to the same topic. Special thanks also to Guy Vandelannoite for his IT training. Our head of unit, Jens Schaps, has been very encouraging. Colleagues in our SPS team in the G2 unit have all helped me a great deal both on substantive issues and on team support. Maria Mercedes Monedero Higuero, Emar Gemmeke, Peter Brattinga, Sergio Pavon Gonzalez, Jean Ferriere—I really cannot thank you enough! Our Mariella Vancaster and Caroline Viviani have assisted me a lot administratively. Last but not least, it is Brian Marchant, my advisor, who led me to this interesting project, challenged me with serious thinking and enriched me with various ideas. I could not have been in better hands. Without his encouragement and support along the way, I could not have seen it through. I remember once I made a mistake and was worried about the consequences. Brian only said, “This is all part of life’s rich experience!” Yes, this traineeship is not just a “Stage” of my life, but has become part of my life, and even part of me. I shall take with me the rich experience I have gained here in the Commission. Disclaimer: This report represents the views of the author within her capacity as a Commission trainee only and does not necessarily represent the views of the Commission’s

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services. Any factual mistakes, omissions and inappropriate wording are the author’s own responsibility.

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TABLE OF CONTENTS

Acronyms and Abbreviations................................................................................ 5

EXECUTIVE SUMMARY................................................................................... 6

Introduction ........................................................................................................... 7

I. The Rise of Private Food Schemes .................................................................... 8

II. Overview of Private Food Schemes ................................................................. 9

III. The Journey to EU Markets .......................................................................... 15

IV. Private Food Schemes as Trade Facilitators ................................................. 20

V. Private Food Schemes as Trade Barriers ....................................................... 25

VI. Who Pays What and Who Gets What ........................................................... 29

VII. Comparison between EU Legislation and EurepGAP Control Points ........ 31

VIII. Legality of Private Food Schemes in the WTO ......................................... 34

VIIII. Policy Options and Recommendations ..................................................... 36

Conclusion........................................................................................................... 41

REFERENCES.................................................................................................... 42

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Acronyms and Abbreviations ACP countries African, Caribbean and Pacific countries AIDCO European Aid and Cooperation Office ASP Assured Produce Scheme BRC British Retail Consortium COLEACP Liaison Committee Europe, Africa, Caribbean, Pacific DCs developing countries DG Directorate General DG AGRI DG Agriculture and Rural Development DG JRC DG Joint Research Center DG RELEX DG External Relations DG SANCO DG Health and Consumer Protection DPA Dutch Produce Association EurepGAP Euro-Retailer Produce Good Agricultural Practices FVO Food and Veterinary Office HACCP Hazard Analysis and Critical Control Point IFS International Food Standard IIED International Institute of Environment and Development ISO International Organization for Standardization GAP good agricultural practices GFSI Global Food Safety Initiative GMP good manufacturing practices MRLs maximum residue limits NGO non-governmental organisation NRI Natural Resources Institute, United Kingdom PANUK Pesticide Action Network, United Kingdom PIP Pesticides Initiative Program SQF Safe Quality Food SPS Sanitary and Phytosanitary TBT Agreement Agreement on Technical Barriers to Trade WTO World Trade Organization

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EXECUTIVE SUMMARY In the context of global sourcing, European retailers and supermarkets require private food certification of their suppliers in third countries to ensure that the products they import to the EU are safe. This requirement is part of a commercial agreement between two voluntary parties in a free market, and as such is not subject to state intervention. However, since costs of compliance with these private standards may be high, many suppliers in developing countries (DCs) cannot afford the luxury of private certification. Some DCs have complained about private standards constituting de facto sanitary and phytosanitary barriers to EU markets and ask the Commission to address this specific concern.

This report helps to understand private food standards in relation to EU legislation on food safety. Most essentially, are private food standards more stringent than EU legal requirements on food safety? The answer, based on the analysis of this report on EurepGAP and BRC, lies in the positive. For food of non-animal origin1, the EU requires “equivalence of risk-outcome” as laid out in the Sanitary and Phytosanitary Agreement of the WTO. As long as the final imported products (outcome) pass official controls in Member States (e.g. MRLs), the EU does not look into the process in which horticultural products are produced or processed in third countries

In contrast, EurepGAP and BRC require “equivalence of systems.” They do not necessarily set higher standards on the safety of final products. Rather, EurepGAP and BRC require tight controls over the process in which products are produced or processed. They claim that these requirements set in the production process are necessary to meet EU legislation on food safety and that of Member States. They are composed of specifications to ensure that production systems and processes result in legally-compliant products.

However, shouldn’t compliance with EU legal requirements alone guarantee food safety? Why do consumers need another level of reassurance from the private sector? Is it true that suppliers in DCs cannot meet EU legal requirements on food safety unless they comply with these private specifications? Why do retailers and supermarkets insist on private certification? Who really needs private food standards for what? Perhaps most intriguingly, who pays for private certification and who benefits from private certification?

It is in the Commission’s interest to understand private food schemes for the following reasons. First, the Commission should be the only legal body to set the level of protection, and legal requirements alone should guarantee food safety. Could its authority of standard-setting be jeopardised by private food schemes? Secondly, Members of the WTO should ensure that their SPS measures do not constitute barriers to trade. Could the EU be challenged at the WTO on grounds of private standards? Finally, there seems to be a trend of European clients asking more and more of their DC suppliers. If nothing is done with this trend, no matter how much the Commission has invested in strengthening capacity for DC farmers to export, they still cannot access EU markets controlled by the private sector. This being the case, the Commission’s commitment and efforts in development will be seriously compromised.

Therefore, this report proposes and analyzes some policy options for the Commission: EurepGAP as certification body to verify EU standards? Dialogues between the Commission and private standard-setting organizations Dialogues among the Commission, supermarkets/retailers, and NGOs Enhance supervision of the market of certification bodies Making use of EurepGAP specifications in technical assistance for DCs The Commission sits on the board of EurepGAP?

1 The discussion of this report focuses on food of non-animal origin, or horticultural products.

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Introduction Private food schemes2 have invited attention in several Directorates General (DG) in the European Commission. DG AGRI and DG JRC, upon request of the European Parliament, have run a pilot-project on private food schemes. AIDCO was presented with requests for technical assistance in meeting private food standards, i.e. EurepGAP, from a number of countries in Asia. DG RELEX was posed with enquiries from third countries about private food standards. DG SANCO is concerned with reported confusion between official EU standards and private ones, in particular in developing countries (DCs). DG TRADE has received complaints from DCs in the WTO about private food schemes constituting sanitary and phyto-sanitary (SPS) barriers to market access. Given all these concerns, the Commission has felt the need to understand private food schemes. What are they? How do they set their standards? How do they relate to one another? How does private certification operate in the market? How do they relate to other economic actors in the supply chain? What are their impacts on third countries in relation to import? How do they affect access to European markets for DCs? How do they relate to EU legislation on food safety? Why are they needed in addition to existing legal requirements? Could the EU be challenged at the WTO on grounds of private food standards? And eventually, what could the Commission do with these private food schemes?

Against this background, this report aims to take stock of the developments of private food standards and discuss their implications for DCs. In particular, this report bears on private food schemes with a perspective of how they relate to compliance with legal requirements. Therefore, throughout this report, private food schemes are less understood as what they are in it own right than understood as how they relate to EU legislation on food safety. Drawing insights from the informal seminar on Dec. 7th 2005, this report also serves as a follow-up to some outstanding issues raised in that seminar.

Methodologically, this report aims at providing a well-balanced presentation of facts. Perspectives from private standard-setting organizations such as EurepGAP and BRC are included. Perspectives from DCs are represented by PIP, World Bank and NRI/IIED. DG SANCO and DG TRADE are consulted on legal and technical details of EU policies and WTO-related issues. The field trip to the Dutch Produce Association (DPA) provides practical understanding of how EurepGAP and BRC operate in reality. The DPA has also kindly provided valuable comparison tables between EU Regulation on food hygiene and EurepGAP.

The structure of the report goes as follows. Chapter 1 discusses the reasons why private food schemes emerged and continue to thrive. Chapter 2 provides an overview of private food schemes and how they relate to one another. Chapter 3 describes European official controls and private inspections for DC suppliers who export to EU markets. Chapter 4 describes beneficial effects of private food schemes on market access for DCs, with examples of EurepGAP and BRC. Chapter 5 explores unfavourable impacts of private food standards due to high costs of compliance with them. Chapter 6 analyzes which actor in the supply chain pays for or benefits from private certification. Chapter 7 provides a factual comparison between EU requirements and EurepGAP control points for food of non-animal origin. Chapter 8 discusses legality of private food schemes in light of the SPS and TBT Agreements of the WTO. Chapter 9 proposes some policy options and recommendations for the Commission in dealing with private food schemes.

The issue on private food schemes is likely to grow in importance, as highlighted in some on-going discussions in the Commission. Hopefully, this report can provide some useful information and contact persons for further discussions on this issue.

2 In this report, private schemes and private standards are used interchangeably to cover food safety and quality.

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I. The Rise of Private Food Schemes Economic theory tells us that market forces do not necessarily serve the perceived public interest. Similarly, some economist indicates that there could be a strong moral hazard aspect in food safety controls, particularly in areas such as maximum residue limits (MRLs) of pesticides, or pathogen levels in food of animal origin.3 Since these attributes cannot be easily detected by the general public, profit-driven firms have a strong incentive not to carry out controls thoroughly. Accordingly, if the provision of food safety is left to the private sector, a tendency of “racing to the bottom” should be expected in standard-setting and controls.

However, the contrary proves to be true in the European food industry. Rather than “racing to the bottom,” there is a trend of “racing to the top” to be observed in supermarkets’ sourcing patterns. These supermarkets require their suppliers to get certified by ever-increasing private standards and compete on grounds of food safety and quality. One cannot help but wonder: Why were private food schemes emerging and then continue to thrive? Consumer concerns and self-protection4 The ever-increasing consumer concerns about food safety and thus the strengthening of regulation on food safety, both at the national and the EU levels, may account for the emergence of private food standards. In the wake of food scares related to Salmonella, BSE, Dioxin etc., the passage of the Food Safety Act in 1990 was a major watershed event in the UK, one that foreshadowed future legislation at the EU level. Under this Act, any supplier of a branded product is responsible for the safety of that product. Also, all fresh produce sold in unpackaged form was considered to bear the brand of the retailer. Accordingly, enforcement action could be taken against a wholesaler or retailer even if the offense was caused by other parties in the food chain (e.g., food importers, overseas exporters). Both reputation and financial resources were at stake (liability claims) if firms failed to prove due diligence in detecting and preventing problems in the food chain.

In response to the legal requirement of due diligence, the major UK supermarkets built up substantial in-house technical teams, and they began to audit primary producers, food manufacturers, and selected overseas suppliers. Each company developed its own code of practice and employed third party auditors to carry out some assessments. These private self-regulation actions resulted in either a set of good agricultural practices (e.g. Assured Produce Scheme) or in a protocol of good hygiene practice (e.g. BRC Technical Food Standard). These actions further became part of the foundation for wider private food safety initiatives in Western Europe. An overview of these schemes will be given in the following chapter.

In addition, in the UK, the results of pesticide monitoring program are published quarterly on the government website, explicitly mentioning the names of the brands, retail outlets, packers, country source, etc. of individual samples. This policy of “naming and shaming” has led retailers to carefully monitor their suppliers. More so, several of the UK’s major supermarkets put in place strict requirements for their suppliers to carry out and document MRL test. Furthermore, the traceability principle and the rapid alert system at the EU level have yielded similar effects upon business food operators. For self-protection reasons, European retailers and supermarkets ask their suppliers for private certification or even go further to impose extra requirements of MRLs upon their suppliers. “Racing to the top” could eventually be a reaction of retailers and supermarkets to protect themselves from liability claims.

3 S. Jaffee et al., 2005: 6. 4 This section is based primarily on S. Jaffee et al. 2005, S. Jaffee, 2003, L. Fulponi, 2004 as well as Mr. Kevin Swoffer’s contribution to the informal seminar on Dec. 7th, 2005, Brussels.

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II. Overview of Private Food Schemes Many different private schemes are being promoted or imposed in the food industry. Internationally, Hazard Analysis Critical Control Points (HACCP) and ISO 9000 are the most widely-applied general standards. In many countries, legislation on food safety requires HACCP to be put in place by any food business or organisation.5 The HACCP system identifies specific hazards and establishes control systems that focus on prevention rather than mainly on end-product testing. It is a system based on seven principles and twelve guidelines defined by the joint FAO/WHO Codex Alimentarius Commission. Each company has to apply these principles to its own specific situation.

The vast majority of ISO standards are highly specific to a particular product, material, or process. Nevertheless, ISO 9000 is primarily concerned with quality management. ISO 9000 concerns the processes an organisation manages its work and not directly the end-product. In this way food safety regulations and systems can be incorporated in ISO 9000. Note that however, ISO 9000 is not a specific food safety system. It examines if the regulations for items (e.g. food safety) are properly met. ISO 9000 does not necessarily ensure food safety and does not require a HACCP plan to be completed to the standards.6

In a nutshell, HACCP is a food safety meta-system whereas ISO 9000 is a quality management meta-system. The application of HACCP is compatible with the application of ISO 9000. For food processing companies, ISO 9000 and HACCP have a great overlap. If a company has implemented a HACCP system successfully, generally 80% of the requirements of ISO 9000 are fulfilled. This holds true for the other way round.7

In the EU, the food quality policy was implemented in the early 90’s with the introduction of some well-known labels8 as well as the Organic Farming logo. On top of these well-defined systems, it is estimated that approximately 400 quality assurance and certification schemes have been introduced in the last few years by local or regional authorities, retailers or agro-food industries. 9 Next section provides a two-dimensional framework to capture the complexity of private schemes on food safety and quality. Points of Differentiation Those numerous schemes may be classified along 2 dimensions. First, are they national or international schemes? Second, do they cover one single stage of the supply chain or do they cross the whole supply chain? Accordingly, these schemes may be organized as follows:

Table 1: Classification of Private Food Quality Assurance Schemes Industry-specific Whole Supply Chain

National Implementation Focus ASP IKB, ABM, Certus, Q&S, Label Rouge, DS

Pan-European/Global Initiatives EUREPGAP, BRC, IFS ISO 9000, HACCP, SQF 1000/2000/3000

Source: Author First of all, there are various national schemes focusing on quality guarantee tailored

to specific sector or a single stage of the supply chain. For instance, Assured Produce Scheme (APS) is an industry-wide initiative in the UK which addresses all the important issues

5 W. van Plaggenhoef, M. Batterink and J. H. Trienelkens, 2002:20-22. E.g. Art. 5 of EC Regulation 852/2004. 6 http://www.iso.org/iso/en/iso9000-14000/understand/inbrief.html and W. van Plaggenhoef, M. Batterink and J. H. Trienelkens, 2002: 23-6. 7 W. van Plaggenhoef, M. Batterink and J. H. Trienelkens, 2002: 23-6. 8 Protected Designation of Origin, Protected Geographical Indication and Traditional Speciality Guaranteed 9 http://foodqualityschemes.jrc.es/en/index.html

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concerning the production of fresh produce through the use of integrated crop management. APS was the first attempt to harmonize a set of good agricultural practices in the UK.

Moreover, similar certification schemes are developed in different member states. For example, in the meat industry, the Dutch IKB (Integrale Keten Beheersing), the British ABM (Assured British Meat), the Belgian Certus or the German Q&S (Qualität und Sicherheit) are basically certifying the same standards.10 These national schemes encompass different stages of the supply chain. As Figure 1 shows, the German QS-System covers the whole supply chain. Starting with animal feed production up to the retailing business all involved parties are certified on the basis of standards laid down by the QS-GmbH. In the same spirit, the Belgian Certus requires that each link of the production chain be examined. To a lesser extent, the French Label Rouge, the British ABM, the Dutch IKB and the Danish DS cover requirements for production and meat-processing but not requirements for retailing outlets.

On the other hand, there are certification schemes which cover only one stage of the supply chain. Figure 2 shows that EurepGAP, for instance, refers to the pre-farm gate and has developed specific standards for the first stage of the supply chain. Besides, the BRC Global Standard deals with main pack-house operations, including high care and minimal processing facilities. Further down the supply chain, SQF 3000 is a set of requirements in development for retail outlets. Most of these schemes are of a pan-European or even a global nature, aiming at harmonizing various good agricultural, manufacturing, distributing and retailing practices trans-nationally. Consequently, they are of significant relevance in the context of international trade and will be discussed in detail in the next section.

Apart from those above-mentioned schemes, individual supermarkets have developed their own systems and labels. For example, in the UK, Tesco has developed “Tesco’s Nature’s Choice,” and Marks & Spencer, “Farm to Folk.” As shown in Figure 2, Tesco’s Nature’s Choice is primarily a pre-farm gate standard 11 and contains many of the elements of EurepGAP, but the protocol is more detailed and costly.12 Marks & Spencer Farm to Fork considers packing as well as production, and thus could be seen as a company-specific alternative to both EurepGAP and BRC.13 Similarly, some major French supermarkets have developed quality assurance schemes for their own brands, such as Terre et Saveur of Casino, Filiere Agruculture Raisonnee of Auchan, Filiere Qualite of Carrefour.

Still others primarily focus on social or environmental issues; examples include Social Accountability 8000, the Ethical Trading Initiative, and the Marine Stewardship Initiative. It should be borne in mind that some of these national, industry-specific, and supermarket-specific schemes mentioned previously also cover issues on environmental conservation, worker health and animal welfare, but these issues are not their main appeals. Trends to Harmonization14 In early days, each retailer developed its own code of practice and inspected his own suppliers. As a result, the various company codes of practice became increasingly confusing, and the multiple inspections were costly and time-consuming. In response, firms have organized

10 G. Jahn, M. Schramm and A. Spiller, 2005: 8. 11 Although farm packaging is included, issues relating to main packhouse operations and further processing are not considered. 12 P. Greenhalgh, T. Wandschneider, J. Orchard, A. Graffham, and C. Coote, 2005: 48. 13 Marks and Spencer measure other standards against the Farm to Fork code and may require their suppliers either to adopt Farm to Fork or to add additional measures to EUREPGAP and BRC. Mozambique Report, p. 48. 14 This section is based primarily on W. van Plaggenhoef, M. Batterink and J. H. Trienelkens, 2002; P. Greenhalgh, T. Wandschneider, J. Orchard, A. Graffham, and C. Coote, 2005; S. Jaffee, 2003 and the respective web sites of these private food schemes. Also, the contributions of Miss C. Francois from CIES and Mr. A. Schmid from Royal Ahold, the Netherlands in the informal seminar on Dec. 7th, 2005 in Brussels are included.

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UNITED KINGDOM: Assured British Meat

Growers/FarmersPrimary Production

PRE-FARM GATE POST-FARM GATE

Food-processingFood-packaging

Retail outletsSupermarkets

DENMARK: DS

NETHERLANDS: Integrale Keten Beheersing

BELGIUM: Certus

FRANCE: Label Rouge

GERMANY: Qualität und Sicherheit

Nat

iona

l Im

plem

enta

tion

Focu

s

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POST-FARM GATEPRE-FARM GATE

Growers/FarmersPrimary Production

Food processingFood packaging

Retail storesSupermarkets

2000

HACCP

HACCP

Indu

stry

Sta

ndar

ds

1000

3000

MARKS & SPENCER MARKS & SPENCER

Supe

rmar

ket-s

peci

fic

Stan

dard

s

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collective action to formulate and apply joint or industry-wide protocols embodying the core elements of GAP, GMP, and HACCP. In so doing, they hoped to reduce problems created by having a plethora of industry standards. EurepGAP has been one prominent initiative as such at the level of primary production while BRC, IFS and SQF have developed common requirements for food packers and manufacturers.

EurepGAP emerged against the background of several outbreaks of food safety scares in Europe. At that time, the adoption of GAP was yet to become part of any compulsory requirement in EU law or that of any individual Member State.15 The APS was a private initiative to consolidate GAP industry-wide but was only a national scheme in scope. Given that a comparatively large proportion of their fresh produce products consists of imported fruits and vegetables, several UK supermarkets felt the need of developing a ‘European standard’ for ‘Good Agricultural Practices’ and promoting integrated crop management. In 1997, a Euro-Retailer Produce Working Group (Eurep) was formed and by 1999 they had established a single harmonized set of protocols for the application of GAP for all sources of supply—EurepGAP. EurepGAP membership covers 30 major retailers 16 in 12 European countries. EurepGAP members control 85% of the Western European fresh produce market.

At the post-farm gate, the British Retail Consortium (BRC), which represents all UK retailers, took the initiative in 1998 to harmonize retail standards. Under the Food Safety Act of 1990, retailers or brand-owners have a legal responsibility for the products under their own label. Consequently, the BRC introduced Food Technical Standard to evaluate whether manufacturers fulfill the requirements of retailers who sub-contract manufacturing of their own brand food products. BRC takes a HACCP system-based approach and considers all aspects of packhouse operations. With a BRC certificate, manufacturers satisfy all that British supermarkets demand at once. Likewise, some German food retailers have developed International Food Standard (IFS) in 2002. IFS aims to create a consistent evaluation system for all companies supplying retailer branded food products with uniform audit procedures and mutual acceptance of audits. In 2003, French food retailers (and wholesalers) have joined the IFS Working Group. It is indicated that BRC and IFS cover for 80 % of the same issues.17

Beyond Europe, Safe Quality Food (SQF), an Australian initiative, has been developed to control the whole supply chain in both Australia and overseas. SQF combines a management quality system (like ISO 9000) and a food safety system (HACCP) with requirements for tracking and tracing. SQF differs from BRC in that the latter only resort to HACCP, but not to ISO 9000 on food quality. The SQF 1000 is a simple HACCP-based system for primary producers. SQF 1000 is similar to EurepGAP, but the latter goes beyond food safety issues to cover environmental conservation and animal welfare. The SQF 2000 is a quality assurance system tailored specifically to meet the needs of food businesses. The SQF 3000 is in development at the moment, focusing on retailers.

In order to further reduce multiple auditing costs incurred by these industry-wide schemes—similar in requirements but just different in names, the Global Food Safety Initiative (GFSI) was established in 2000 by a group of over 50 retailers worldwide, controlling approximately 65% of food retail revenue globally. GFSI does not intend to be applied as a code in its own right. Instead, it compiles a set of ‘key elements,’ including food safety management, GMP or GAP, and HACCP. These elements serve as the requirements against which existing food safety standards will be benchmarked. In so doing, GFSI does allow retailers to demand compliance with codes and protocols that meet one single standard.

15 Several Council Regulations, i.e. 2078/1992, 2200/1996, and 1257/1999 refer to the need for primary producers to take better account of environmental concerns. S. Jaffee, 2003: 20. 16 Tesco, Sainsbury’s, Delhaize, MacDonald, ASDA, Metro Group, Ahold, Mark & Spencer, to name a few. 17 S. Williams, E. Roth, and J. van Roekel, 2005:21.

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Based on these key elements defined by the GFSI, four food safety management standards at the post-farm gate have been benchmarked so far, namely, the BRC Technical Standard, the Dutch HACCP Code, SQF 2000, and IFS. At the pre-farm gate, SQF 1000 is recognized by GSFI. EurepGAP and GFSI are discussing about benchmarking the fruit and vegetable protocol. The GFSI states that these benchmarked food safety standards can be applied by food suppliers throughout the whole supply chain, upon agreement with retailers, when defining contracts for sourcing of products. The application of the benchmarked standards to particular products is at the discretion of retailers and suppliers.

Aside from GFSI, ISO 22000 is a global standard launched on 1 September 2005 and recognised by more than 40 countries. The standard is applicable to the entire food chain ranging from primary producers over processing businesses (i.e. dairies, meat processors and bakeries) to retailers. It also applies to ingredient, feed, transport and packaging businesses. The standard builds on the internationally recognised HACCP principles and focuses on management’s commitment and communication. An interesting question which has gained currency is how ISO 22000 will affect GFSI and food safety standards.

This paper concerns itself primarily with private food assurance schemes and their implications for developing countries. Developing countries export a significant amount of tropical fruits and vegetables to the EU. Most of the European retailers require their producers in developing countries be EurepGAP certified. BRC is important if companies in developing countries invest in fresh cut and minimally processed fruit and vegetable. Therefore, more technical details on both schemes will follow in the next chapters.

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III. The Journey to EU Markets What will a small-scale grower in developing countries (DCs) be undergoing if he wants to export fresh produce to the EU? The Single Market is certainly not a homogenous monolithic market. In fact, there is rather wide variation in the intensity and specificity of the food safety, environmental, quality, and other standards required of supplier/exporters across different EU member states. This is a reflection of different market structures, national laws, business cultures, and the preferences of consumers. Let’s have a look at EU markets first. The situation of EU markets18 Most importers of fruits and vegetables in Europe sell the product directly to retailers (75–80 percent). These importers source tropical fruit and vegetables from producers in developing countries, often on a contractual basis. Most retailers deal with preferred suppliers who follow the retailers’ specifications for production, handling, and packaging. The share of imported product sold to wholesalers is approximately 15–20 percent (restaurants, ethical markets, local supermarkets) while 5–10 percent is re-exported. It is reported that there is an oversupply of tropical fruits and vegetables in the EU market, and retailers and importers can therefore choose their preferred suppliers from a large number of fruit and vegetable suppliers.

The EU’s DG Health and Consumer Protection (DG SANCO) stipulates official food safety standards and monitoring practices for imported fruits and vegetables from third countries. In addition, each EU member state has developed food safety regulations, packaging and labeling requirements, and inspection systems for cross-border agricultural chains. Besides, retailers or supermarkets have their own specifications. Consequently, in order to supply EU markets, farmers and exporters in DCs need to contend with at least these three levels of requirements, i.e. the EU, member states and the private sector.

Food safety and quality inspections take place at different levels in the food supply chain. Figure 3 shows how fresh produce from DCs to the EU are controlled by different public and private entities (producers, exporters, national control agencies, importers, and retailers) at different points in the supply chain. The upper half describes private requirements, among others, EurepGAP and BRC, while the lower half describes EU requirements. Official controls19 Of the array of official standards applied for imported fruit and vegetables, the most relevant ones controlled at the point of entry to the EU are the requirement for a phyto-sanitary certificate, the compliance with MRL tolerances as well as the marketing standards on quality. Regulation EC/852/2004 stipulates general hygiene provisions for primary production, according to which competent authorities in third countries should carry out inspections on farm. However, neither on-site controls nor HACCP-based procedures are compulsory. If fruit and vegetables are semi-processed and pre-packed in DCs, Regulation 852/2004 requires HACCP-based procedures in pack houses. For pre-cut fruit and vegetable and sprouted seeds ready to eat, Regulation 2073/2005 requires microbiological criteria be met.

Part B of Annex 5 to Directive EC/29/2000 stipulates a range of plants which should be accompanied by phyto-certificate when imported to the EU. Before these products are transported to the EU, exporters in DCs must obtain a phyto-sanitary certificate issued by the plant health authority of the country of origin to prove that the material has been inspected by competent authority, meets the requirements for importation into the EU, and is generally free from disease and pests. At the point of entry to the EU importing country, inspections are 18 S. Williams, E. Roth, and J. van Roekel, 2005:5-15. 19 This section is based primarily on P. Greenhalgh, T. Wandschneider, J. Orchard, A. Graffham, and C. Coote, 2005; S. Jaffee, 2003; and S. Williams, E. Roth, and J. van Roekel, 2005.

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15-20%: Wholesale

markets

Ethnic markets, Restaurants etc.

Reg. EC 882/2004 on documentary, identity, and physical check. Food hygiene, additives, materials in contact with food, contaminants etc. may be controlled by competent authorities in member states at the point of entry, the point of release for free circulation, the importer’s premises, retail sale units etc. on a sample basis.

Producer Farmer

Pack House Exporter

75-80%: Supermarkets

Importer Processor

Sea/Air Freight

POINT OF ENTRY

EU Member

States

POINT OF DEPARTURE

Developing Countries

For semi-processed prepared F and V: traceability, HACCP, microbiological testing

Reg. EC852/2004 general hygiene provisions, no HACCP-based procedures, no official control on site required for primary production.

Exporters must obtain a phyto-sanitary certificate issued by his competent national authorities for plants stipulated in Part B of Annex 5 to Dir. 29/2000/EC.

- Dir. 29/2000/EC on Phyto-certificate

- Reg. EC 396/2005 on MRLs for pesticides

- Reg. EC 2200/96 on marketing standards

Reg. EC 852/2004: detailed requirements after primary production. HACCP-based procedures Reg. EC 2073/2005: microbiological requirement for pre-cut F&V and sprouted seeds (ready to eat)

10%: Re-exporting

For primary production: Good Agricultural Practices

DUE DILIGENCE DEFENCE

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carried out by the National Plant Protection Services. They involve scrutiny of documentation and checks of identity and plant health on a representative sample or on all of the plant matter. In case a problem appears during the phyto-sanitary control, the whole shipment is rejected.

Fruits and vegetables imported into the EU must comply with the relevant MRLs for a given active substance in combination with a given commodity. There has yet to be a harmonized MRL at the EU level. Directive 1991/414/EEC concerns the placing of plant protection products on the market, and provides for the EU to examine pesticide active substances under all safety aspects. The member states annually prepare their national plans for the control of residues of pesticide on fruits and vegetables. Their plans indicate selected products that are subject to control during that year and the number of controls per product. About 10 pieces of fruit per product category are taken per control in accredited private labs for testing to analyze the residues of pesticides. A “rapid alert system” of the Commission provides cross-country information on problems about MRLs encountered. The information collected is passed on to the private sector through the national inspection services. Regulation 396/2005 will harmonize MRLs at the EU level in a couple of years’ time.

EU marketing standards, i.e. Regulation EC/2200/96, define quality parameters of the produce to be termed as class 1 or class 2 produce. If a commodity has a marketing standard under Regulation EC/1148/2001, compliance with this standard must be demonstrated. At the point of entry, the customs authorities review relevant papers. In case the class of the products does not correspond with the class indicated on the pallets, that product is reduced to a lower quality class. Exporters can wait for inspection to be carried out in the EU but this is risky as produce may have to wait 4-5 days prior to inspection, with a large loss of shelf-life for any fresh produce. Therefore, under article 7 of EC/1148/2001, governments of third countries may apply for approval from the EC to issue certificates of conformity with the relevant marketing standard prior to the produce leaving the country of origin.

In case of Kenya, exporters indicate that quality-related problems identified by private clients cost them much higher financial costs than official detentions or rejections of products. In cases where products do not complied with private standards, the exporters have either to divert the product to less quality stringent clients or to do substantial grading out of saleable produce. These private requirements will be discussed in the following section. Private inspections The producers in DCs must also comply with the private quality and safety standards required by retailers and importers in the EU. EurepGAP certification, among others, is a requirement of the largest retail companies in the EU and is often seen as the minimum standard. EurepGAP was originally created as a due diligence defence and participation in the scheme is voluntary. Nonetheless, EurepGAP certification had become a market access condition for 30 European retailers as of 2005, most of which are British or Dutch. In France, Carrefour is the first to adopt EurepGAP. From 2006 onwards, the German market only accepts EurepGAP-certified products. Apart from supermarkets and retailers, even some wholesale markets begin to ask for EurepGAP certification from their suppliers in DCs.

In order to acquire EurepGAP certification, the grower or group of growers must apply to a recognised certifying body for a certification audit. The certifying bodies carry out the initial certification and annual verification audits of farms wishing to become producer members of EurepGAP. A total of 214 control points is divided into 49 Major Musts, 99 Minor Musts and 66 Recommendations. These controls points include specific requirements in relation to site management, varieties and rootstocks, soil management, fertilizer usage, irrigation, crop protection as well as waste and pollution management. Stipulations with regard to worker health and welfare as well as wildlife conservation are also covered. The successful grower is issued with a certificate valid for one year. If a grower cannot fulfil a

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“major must”, its certificate will be temporary suspended. When less than 95% of the “minor musts” is fulfilled, the certificate will also be temporary suspended. The suspension period has a maximum of 6 months. After this period, and without fulfilment of the requirements, the certificate will be terminated.

BRC certification is important if companies invest in fresh cut and minimally processed operations, and this would be applicable for semi-prepared and ready-to-eat salads, fruits and vegetable combination products.20 To supply the EU’s leading supermarkets, a supplier in DCs must have a HACCP program in place and must be able to demonstrate product traceability. These are essential elements of the BRC standard. In addition, microbiological testing is part of the due diligence defence, and supermarkets generally require importer/distributors to have such tests done. There are no specific microbiological requirements in BRC food standards; however, if the auditor believes there is microbiological risk to the product, he/she may raise this for consideration, for instance, if cut vegetables are handed directly, without any form of cooking or further preparation by the customer. The microbiological test in this instance monitors the hygiene management within the factory. BRC does not cover ethical or environmental issues.

When products enter the EU, the importer checks the packing material and visual appearance of the products at arrival, takes samples of the products, and sends these to a laboratory on a periodic basis or in case problems have occurred. For fruits and vegetables, samples are taken once or twice a year per product per supplier. The importer sometimes checks the internal condition of the fruit and the sugar content by cutting the fruit. The supermarket also inspects the visual appearance of the products briefly at arrival in the distribution centers. HACCP and traceability are not yet essential to supplying wholesale markets. An array of other measures related to food safety, environmental safety, social concerns and animal welfare are of greater or lesser importance in different markets.

On the next page, Table 2 complied by S. Jaffe21 of the World Bank shows clearly that suppliers in developing countries have at least three levels of requirements to contend with, namely, official requirements at the EU level, national requirements in the different member states and various private certification schemes required by European retailers and supermarkets. The journey to the European markets is perhaps not an enjoyable one. In the rest of this paper, we hope to figure out what for a role does private food schemes play in this journey and how to make this journey easier for suppliers in developing countries.

20 P. Greenhalgh, T. Wandschneider, J. Orchard, A. Graffham, and C. Coote, 2005:46. 21 S. Jaffe, 2003: 24.

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TABLE 2 Market Destinations of Kenyan Fresh Vegetables and Compliance Requirements

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IV. Private Food Schemes as Trade Facilitators In order to understand the impact of private food schemes on exports from developing countries (DCs), we shall start with what their requirements are and how they set these requirements. Most of the European retailers require their producers in DCs be EurepGAP-certified. Some companies in DCs are BRC-certified if they invest in fresh cut and minimally processed fruit and vegetable as well as in processed fish products. Accordingly, EurepGAP and BRC will be discussed in detail in the rest of the report. How EurepGAP sets its standards22 Technically speaking, EurepGAP is a set of normative documents suitable to be accredited to internationally recognised certification criteria such as ISO. It consists of a set of general regulations, protocol for GAP23, and an auditing system with a checklist. The protocol is broken down into 214 control points which are organised into 14 chapters. The scheme covers the whole agricultural production process of the certified product, from before the plant is in the ground (seed and nursery control points) to non-processed end product (produce handling control points). A summary of the chapters and their applicability to the production process is shown in the following table:

Table 3: Production Stages Covered by EurepGAP Control Points CROP PRODUCE

Seed & Nursery Site Selection Crop Protection Harvest & Transport

Storage, Washing, Treatment

1. Traceability 2. Record Keeping and Internal Self-Inspection 3. Varieties and Rootstocks

4. Site History and Management

5. Soil and Substrate Management

6. Fertiliser Use 7. Irrigation/

Fertigation

8. Crop Protection 9. Harvesting 10. Produce

Handling 11. Waste and Pollution Management, recycling and Re-Use 12. Worker Health, Safety and Welfare 13. Environmental Issues 14. Complaint Form Source: P. Greenhalgh, T. Wandschneider, J. Orchard, A. Graffham, and C. Coote (2005) p. 37.

Clearly, EurepGAP is composed of process specifications. By checking compliance

with these control points one by one, EurepGAP requires demonstration of “equivalence of system.” According to its representative, EurepGAP does not set out in its standard-setting to intentionally exceed EU requirements. Rather, it aims to raise the awareness of and complement regulatory requirements, including intra and extra EU legislation. To this end,

22 This section is based on correspondence with EurepGAP and P. Greenhalgh, T. Wandschneider, J. Orchard, A. Graffham, and C. Coote, 2005:33-43. 23 i.e. EurepGAP Control Points and Compliance Criteria

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EurepGAP applies three guiding principles in its standard-setting. First, where there are explicit EU regulations, EurepGAP would normally refer to them; where EU requirements are broadly stated, EurepGAP may have specific guidance. Obviously, these 214 control points are specific steps set to meet EU requirements.

Second, some Member States can set more rigorous requirements than EU ones. Where this is the case, EurepGAP requires and assists farmers in achieving compliance with Member States’ requirements. An example would be EurepGAP’s specific crop protection controls and integrated pest management. The MRLs have yet to be harmonized at the EU level, and each member state has set its own MRL for imported fruits and vegetables. EurepGAP requires compliance with MRLs as set in the country of destination of the produce, normally an EU member state. EurepGAP has a procedure to assist producers in ensuring this level of compliance in the market of final sale.

Third, EurepGAP also require compliance with legislation in the country of production. In practice, some major exporting countries, e.g. South Africa, Chile, operate to the most stringent member state requirements so that they are sure that they will meet all the legal requirements. As a result, legislation in these countries might be more stringent than EU requirements. The certifiers auditing EureGAP will normally check compliance with national legislation of country of origin as well. Taken together, EurepGAP could be regarded as providing a service to implement compliance with relevant regulations, which should ensure successful imports into the EU. It is believed that if a producer has EurepGAP certification, he should meet all food safety requirements of the EU.

However, the EU does not require a HACCP-based approach for primary production. The EU requires “equivalence of risk outcome” as required by SPS and TBT. Only samples of the final imported products are officially controlled in Member States, such as phyto-certificate, MRLs, additives, contaminants etc. With regards to the process of production, Regulation EC/852/2004 sets out general hygiene provisions for primary production.24 And competent authority should carry out regular official controls on food of non-animal origin imported into the EU.25 However, no official certification is required to verify compliance with these hygiene provisions. For food of non-animal origin, no positive lists of countries or establishments allowed to export to the EU are required. In other words, as long as the final imported products (outcome) pass the official controls in Member States, the EU does not look into the process in which fruits and vegetables are produced in third countries.

Unlike EU official controls on risk outcome, EurepGAP is a process certification which guarantees the production process results in legally compliant products. In its standard-setting process, EurepGAP conducts a generic full HACCP assessment which determines the types of risk across specific product sectors, such as fruit and vegetables or livestock production. EurepGAP does require some risk assessments to be carried out but does not follow strictly the step-by-step process of Codex HACCP. This is because most farmers would not have had that kind of formal training. “This is in line with EU Regulation which supports a HACCP-based (risk assessed) approach for primary producers,” a representative of EurepGAP maintained, “this in our opinion obviates the need for a full Codex HACCP assessment to be carried by every farm/farmer.” EurepGAP carries out part of the risk assessment for farmers, but in certain cases farmers should look at local circumstances as well and may be required to assess certain risks themselves. “That is different to making HACCP a mandatory prescription, which we do not,” this representative emphasised.

24 including infrastructure, equipment, water quality, pest control, personal hygiene, pre-operational and operational hygiene. 25 Regulation EC/882/2004, Article 15.

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How BRC works in developing countries26 The BRC Global Standard—Food sets out the requirements for the manufacture of processed foods and the preparation of primary products supplied as retailer branded products, branded food products and food or ingredients for use by food service companies, catering companies and food manufacturers. Certification will apply to products that have been manufactured or prepared at the site where the evaluation has taken place. Certification will include storage facilities that are under the direct control of the production site management. In short, BRC lays down specific requirements for food safety management systems in factories and packhouses where the product is packed for the final consumer. Table 4 shows that there are several BRC-certified companies in DCs.

TABLE 4: BRC-certified Companies in Developing Countries and Their Activities Country Company Activity Products

Ghana 3 canning factories fruit and vegetables Ivory Coast 2 canning factories fruit Kenya produce packhouse green beans, pineapples etc. Nambia beef slaughter Zambia produce packhouse Zimbabwe food packaging material

(BRC Packing Standard)

Senegal 1 canning factory tuna 2 factories chilled frozen fish Vietnam 2 canning factories fish 4 canning factories fish and vegetables Peru 1 produce packhouse

Seychelles canning factories tuna Mauritius 2 canning factories tuna Mexico 1 canning factory Morocco 1 canning factory vegetables Source: Mr. Kevin Swoffer, Head of Technical Services, BRC

For foods after primary production, Regulation EC/852/2004 requires HACCP-based systems in place. This legislation lays down what a company must meet, but it does not specify how to meet these requirements. BRC verifies the existence and effectiveness of HACCP and traceability. It is therefore important to understand how BRC Standards relate to legal compliance. According to a representative of BRC, although EU legislation does not require quality management systems, many of the requirements under such quality management systems would ensure compliance with the EU General Food Law and the new EU Hygiene Regulations. Suppliers with BRC certification would be trained to achieve good manufacturing and hygiene practices.

The risks to products under the scope of the BRC are significantly higher than those risks to primary production as in the case of EurepGAP. BRC procedures are designed to eliminate or reduce the risk of high pesticide or primary contamination reaching the ultimate consumer. In some technologies, e.g. canning and the production of chilled ready to eat meals, the technology itself is infinitely more dangerous than risks posed by primary product. Therefore, if such requirements are not in place, there is little or no incentive for companies to improve their food safety standards and hence no guarantee of product safety. Contamination, mislabelling, under-processed product, etc. could all happen. “Food safety is not achieved by enforcement alone;” this BRC representative avers, “the drive for major change and continued compliance is one of commercial recognition to supply a market.” 26 This section is based on the information provided by BRC.

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TABLE 5: Sections of the BRC Standard where there are no specific requirements in the EU law or where BRC requirements exceed stated requirements

Sections of BRC Global Standards—Food Specific Requirements Quality Management System Quality Policy

Quality Manual Management Structure and Responsibility Customer Focus Management Review Resource Management Internal Audit Purchasing—Supplier Approval and Performance Monitoring General Documentation Requirements Documentation Control Specification Corrective Action Traceability (exceeds EU requirement but not guidance) Complaint Handling

Factory Environment Standards Layout, Product Flow and Segregation Maintenance Staff Facilities (exceeds EU requirements) Transport

Product Control Handling Requirements for Specific Materials Product Packaging Stock Rotation Product Release

Process Control Calibration of Devices Source: Mr. Kevin Swoffer, Head of Technical Services, BRC

With regards to BRC’s impact on DCs, the representative from BRC holds that it assists suppliers to meet EU legal requirements on food safety since markets are opened by ensuring the product that are manufactured or packed are safe and meet EU and retailer requirements. BRC has produced guidance to advise companies how to meet the BRC standard or how to enhance their systems. BRC has provided a number of examples regarding companies both within the UK and overseas where suppliers have gained access to markets following their BRC certification.27 The favourable effects of private food schemes Based on how the systems of EurepGAP and BRC work, it seems that both claim a merit of facilitating imports from DCs to the EU. As mentioned in the 3rd chapter, exporters to the EU have to contend with EU legal requirements plus another 25 Member States potentially where there is no harmonized EU standard. Some of the suppliers in DCs may appreciate the precision of regulatory requirements made by EurepGAP or BRC which render them a clear understanding of what must be done in order to export to the EU markets. Moreover, EurepGAP and BRC are harmonized sets of various European retailer requirements. With EurepGAP or BRC certification, suppliers do not have to struggle with diverse audit arrangements required by retailers and supermarkets in the EU.

In addition, EurepGAP and BRC may contribute to improvement of agricultural, hygiene and manufacturing practices in DCs. Modernisation of food safety or agricultural health control systems in DCs might in turn render production more efficient.28 Besides, less and correct use of pesticides benefit the local environment and worker health as well. Moreover, meeting an internationally recognised standard, such as EurepGAP and BRC, can

27 Among others, Egyptian Potato Consortium in Egypt, Freshtrop Fruits in India, Naftali Estate (Pty) Ltd. in South Africa. 28 S. Jaffee et al., 2005: 71-2.

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improve suppliers’ reputation and thus reassure client confidence in the long run. This can in turn sustain continued access to the European markets or even lead suppliers to market segments of higher prices. Finally, private food schemes seem to have broader employment effects. The shift from unprepared to semi-prepared produce exports has substantially increased the demand for labour in the pack-houses of the leading companies.

Based on its rich experience with farmers in DCs, NRI recognises the merits of EurepGAP. It is pointed out that some farmers in Zambia like EurepGAP concept and apply it to all crops. Similarly, Kenyan farmers also recognize the benefits of BRC certification. It is reported that most exporters consider the BRC standard and audit process as being far superior to the previous system of diverse audit arrangements. They regard the BRC standard as giving Kenyan and other suppliers very clear guidelines on what is required of them.29

What if no private food schemes? The benefits of private food schemes could be seen in a counterfactual analysis: What would happen in the absence of private food schemes? Would we see more or less trade from DCs to the EU? It is reasonable to argue that without EurepGAP, farmers and exporters in DCs would have to come to grips themselves with complicated EU regulations on food safety and those of the member states as well. In this sense, private food schemes help to reduce the transaction costs by making information about European regulations on food safety systematically available and practically achievable.

Moreover, private food schemes ensure products to be legally-compliant. Without them, suppliers and importers cannot be guaranteed if their products do not exceed the official MRLs and other requirements. Once food safety or pest-related problems are detected at the border, consignments of fresh fruits or vegetables could be detained, rejected or even destroyed by regulatory authorities in Member States. More seriously, prior consignments from the country or supplier would be recalled from the markets. Temporary or permanent bans on exports could be imposed. All these measures could cause sustained damage to the reputation of the exporting country, the supplier, and the importer, which might in turn affect downstream customer confidence and result in loss of EU market buyers. In extreme cases, suppliers may be forced out of the market altogether.

As previously discussed, European business operators are responsible for products they imported. Therefore, they resort to private schemes as due-diligence defence and self-protection. If there were no private schemes, would retailers and supermarkets rather source products from countries with advanced food safety systems? Might overall demands for products from DCs have declined because downstream customers want to avoid any possible border detention or rejection? With the caveat that we need to hear the other side of the story, private food schemes could somehow claim a merit of facilitating imports from DCs to the European markets. Next, we shall look into the adverse effects of private food schemes on market access for DCs.

29 S. Jaffee, 2003: 49.

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V. Private Food Schemes as Trade Barriers What adverse impacts might private food schemes exert on exports from developing countries (DCs)? In spite of the benefits of private food schemes identified in the previous chapter, costs of compliance with these private requirements are high, which might weaken the competitive position of DCs or compresses the profitability of their export-oriented activities.30 In addition, there are concerns that many DCs lack the administrative, technical, and scientific capacities to comply with these requirements. Economic costs of compliance—non-recurring and recurring costs These compliance costs can be classified into two categories: non-recurring and recurring. Non-recurring costs are the one-off or time-limited investments made in order to be able to achieve compliance. Typically, these include the upgrading of laboratory infrastructure and processing facilities, establishing new procedures and the associated training of personnel, or the costs of designing new management systems. Since different companies or factories or farms have different food safety systems and infrastructure in place, costs of investment vary from factory to factory, from farm to farm, from growers to growers. Also, the level of preparedness/experience of companies or growers, the breadth of their activities and dependence upon particular markets all play a role in the level of compliance costs.31

Much of the cost of compliance with EurepGAP is derived from improving farm infrastructure to reach a EurepGAP compliant farm or out-grower system. This includes the development of centralised systems for handling produce and storing fertilisers and crop protection products, as well as through use of professional spraying teams and protective equipment, etc. Much of the cost of BRC is derived from the need of having the HACCP system in place for food-processing companies. Major investments go into air-conditioning and ventilation systems, water purification systems, blast cooler systems, and a wide variety of equipment to attain very high standards of hygiene within the packhouse operations. A few companies have invested in their own on-site laboratories for product and staff health tests.32

Recurring costs are borne over time and include the costs of maintaining regular control systems and laboratory testing programs as well as costs associated with annual verification audits, detailed record-keeping, implementation of traceability systems.33 The auditing costs vary because certification bodies charge differently. Local certifiers are not automatically cheaper; in Africa, quotes can be 1.5 to 4 times more expensive than European certification body quote.

Appendix A shows examples of compliance costs with EurepGAP, and Appendix B, with BRC. Given cross-farm, cross-factory or cross-company variations, these examples should only serve as a reference. It should also be borne in mind that part of the upgrading investment and costs to maintain food safety controls is needed to meet EU requirements or those of Member States in the first place. For instance, in the case of BRC, any cost associated with HACCP systems after primary production is also required under EU law. What really important is to analyse the difference between compliance costs with legal requirements and those with EurepGAP and BRC.34 Admittedly, the extra costs caused by private schemes cannot be observed in both Appendixes.

30 S. Jaffee et al., 2005:13. 31 S. Jaffee et al., 2005:97. 32 S. Jaffee, 2003: 45-6. 33 P. Greenhalgh, T. Wandschneider, J. Orchard, A. Graffham, and C. Coote, 2005:41. 34 This is pointed out by PIP and BRC.

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Technical and administrative complexity35 Aside from economic costs of compliance, technical and administrative complexity of private requirements is another formidable challenge to smallholders in DCs. According to NRI/IIED’s observations of the application of EurepGAP in a couple of DCs, farm infrastructure and basic good agricultural practices on farm are no problem. However, it takes time and staff capacity to train farmers in understanding and implementing compliant record-keeping. Moreover, the real challenge lies in the requirement of an ISO-type QMS.

According to NRI/IIED, Annex II Checklist for Farmer Group QMS is very complex and demanding for small-scale growers. This QMS audit takes about half a day and involves about 400 documents. It requires ability to understand and explain inter-relationships between all documents. Moreover, the main system has about 150 documents, including 36 types of records (35 sets of advice notes for farmers on policies, procedures and actions). Small-scale farmer groups cannot implement this ISO-type document control procedure without extensive external support. Given complexity of the main system and QMS, good technical support is essential for implementation and maintenance of EurepGAP requirements. However, EurepGAP defends that this Checklist is a voluntary document designed by a German Development Agency36 which should assist small-scale farmers to self-assess their operations.

With regards to BRC Global Standard, technical difficulty lies in metal detection, product recalls, low acid canning, pasteurisation, pest control, internal audits, traceability, quality measurement, complaint handling and shelf-life determination.37 The requirements have also expanded from dealing with procedures for product recalls to incident management and internal plant processes. The BRC standards mirror the requirements set out under the EU and UK’s food laws. In some cases, they exceed the legal requirements, especially those relating to traceability. The EU’s food law only requires food companies to know their immediate suppliers and consumers in the food chain whereas BRC also requires that food companies trace produce internally, down to the batch level. Generally, smaller exporters lack finance, infrastructure and personnel capacity to implement BRC successfully.

It is indicated that exporters requiring BRC are typically large well resourced operations which cope easily with BRC.38 If exporters in DCs aim at exporting processed fruits and vegetables to lucrative leading supermarkets in the EU, they may have their pack-house BRC-certified and incur the associated costs. As a representative of BRC puts it, companies in DCs cannot run their business differently from those companies within the EU, and they have legal obligations to meet EU legislation and also customer requirements. Acquisition of BRC certification is after all a business decision of “more or less” profits, but not a matter of “in or out” of European markets. Not set for primary production, BRC has little impact on smallholders in DCs. It could impact on smaller exporters in the future only if asked for more widely. Hence, the following discussion will be focused on EurepGAP.

Corrigendum concerning statement on page 26, footnote 36 "Annex 2 Farmer Group Quality Management Systems" was elaborated by EurepGAP and s part of their normative documents (see EurepGAP General Regulations version 2.1Oct.04). The same applies to the "Quality Management System Checklist for option 2 Version 1.0Sept05". GTZ had and has no role in developing EurepGAP normative documents GTZ has elaborated a manual with guidelines how to implement a quality management system for farmer groups that wish to be certified to EurepGAP option 2.

35 This section is based on the joint presentation by NRI and IIED in the informal seminar on Dec. 7th, 2005. 36 This list was developed by the Deutshce Gesellschaft fuer Technische Zusammenarbeit (GTZ), a German Development Agency. 37 http://www.foodnavigator.com/news/printNewsBis.asp?id=65654 38 NRI/IIED presentation.

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Barriers to trade?39 The impact of EurepGAP on farmers in DCs depend on scale and sophistication of operation. For large commercial operations (100-1000ha), finance, infrastructure and personnel are no problem. In contrast, for small-scale operations (0.1-4.0ha), lack finance and infrastructure as well as personnel shortages and low capacity have rendered compliance with EurepGAP difficult. The majority need donor support to cover initial costs, and some can sustain from farm income. The following table indicates that cost of compliance with EurepGAP might compress the profitability of the export-oriented activities of small-scale growers.Apparently, these costs would further marginalize those small-scale growers without donor support.

Table 6: Cost of Compliance as % of Annual Profit Margin of Each Small-Scale Grower Support from donor subsidised PMO

No support from PMO

Area

hectares Capital cost % Recurring cost % Capital cost %

Recurring cost %

2.0-6.0 2-5 0.4-1 8-23 3-8 1.0-1.8 5-8 1-2 26-41 9-14 0.3-0.8 12-33 3-8 58-160 19-53

Source: Joint presentation “Standards Compliance” by A. Graffham (NRI) and B. Vorley (IIED) in the informal seminar on the 7th of December, 2005.

Given high compliance costs as well as technical and administrative burdens, private foods schemes are often considered as barriers to the EU markets for small-scale farmers or exporters in DCs. EurepGAP has invited most of the concerns in this respect because it is a food scheme for primary production with potential to impact on all growers wishing to export to the EU. In addition, EurepGAP members control 85% of the Western European fresh produce market. Even as a non-member, buyers can ‘free-ride’ on EurepGAP, asking for certification as a proxy for supplier competence, and more importantly, as a due diligence defence, especially for food service customers. The major concern is that wholesale and ethnic markets, which seem to be a good refuge for small-scale producers and traders, could rapidly become consolidated due to the big economies of scale associated with both private standards and new EU regulations. Some smaller importers and wholesalers are asking for EurepGAP as a de facto requirement for market entry.

Since EurepGAP is a set of specific measures to assist DCs in meeting European official standards, its adverse effects on market access for DCs should be weighed against its favourable effects of facilitating trade. What is more worrying, however, is the increasing client requirements on food safety. Most recently, some major German retailers40 required all pineapples producers of Ivory Coast to be EurepGAP-certificated as of January 1st, 2006. These retailers seem to go beyond even EurepGAP’s requirements by requiring that MRLs are one third of EU levels. 41 Adding insult to injury, they require EurepGAP option 1 “Individual Certification” only. Option 2 is “Group Certification” for smallholders. In so doing, they will literally deny smallholders’ production.42 If there is such a trend, this would cause undesirable restriction to supply from DCs and could become de facto barriers to market access for DCs, especially for smallholders.

Last but not least, the role of certification bodies in determining the level of compliance costs should not go unnoticed. NRI/IIED noted that best certification bodies are transparent and charge reasonable fees while worst ones are not transparent, and donor funding can lead to big price hike. Apparently, the costs and benefits of compliance with 39 This section is also based primarily on the joint presentation “Standards Compliance” by NRI and IIED.. 40 Aldi, Lidl, Wal Mart, Metro, Rewe. Letter provided by PIP. 41 PIP points out that this requirement applies to all fresh products they purchase from all countries. 42 PIP.

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private food schemes affect different economic agents, not only farmers, exporters and standard-owners, but also consumers, retailers, certifiers and even donors. Understanding the ways in which the costs and benefits are distributed between supply-chain participants could help to identify where the problems really lie. Therefore, questions of who pays for and who benefits from private food schemes will be addressed in the next chapter.

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VI. Who Pays What and Who Gets What

After examining costs of compliance with private food schemes, among others, EurepGAP and BRC, an intriguing question would be: Who actually pays costs of compliance with these private schemes? Producer? Exporter or importer? Retailer or supermarket? Consumer? Aid-donor? Equally interesting is the question of who benefits from private food schemes. Consumer? Supermarket? Producer? Certification bodies? Looking into these two questions might help to identify where the problems with private food schemes really lie. Who pays for private food schemes? First and foremost, how the system of certification operates is key to understanding the allocation of costs and benefits throughout the supply chain. Certification is a process by which clients assess the compliance with defined standards and is typically undertaken by a third party agency (certification body) that the client recognizes as ‘competent’.43 Industry protocols such as EurepGAP and BRC operate on a business-to-business basis, namely, clients vis-à-vis suppliers. In case supermarkets or retailers ask their suppliers and thus importers for EurepGAP or BRC certification, importers in turn require that exporters and primary producers be EurepGAP- or BRC-certified by an independent certification body. Compliance with private schemes is an addition to the list of services which suppliers are asked to provide as a condition of sustained market access.

This being the case, it is argued that by means of private schemes, supermarkets and retailers transfer the control costs that they formerly assumed towards the grower and the exporter upstream the supply chain. Previously, retailers had their own standards and own inspectors who would be travelling to check suppliers. Since the introduction of EurepGAP, the suppliers must pay FoodPlus and all the auditing bodies such as trainers, inspectors, and certifiers. Suppliers also have to manage the whole certification process whereas retailers just need to require the EurepGAP certification without incurring extra costs. Donors are covering some of the costs of smallholder compliance in Africa in the name of ‘making markets work for the poor’. However, the sustainability of this practice is doubted since there is no evidence of any smallholders being EurepGAP-certified without subsidy. On the other hand, it is argued that overall in the supply chain, the consumer pays for the management of safety in the final purchase price. Consumers should expect safe product, and safety is non-negotiable. The cost of producing a safe product is thus an absolute requirement, and the cost of an audit to validate safety should be incorporated into the total cost of safety. 44 The supplier is totally responsible for supplying safe product, and the validation of safety systems should therefore be viewed as part of this responsibility. Suppliers outside of the EU should provide safe foods, too. Therefore, compliance should not be regarded as a ‘ticket to trade’. However, theoretically, compliance with EU legal requirements alone should guarantee food safety. Why should consumers need another level of reassurance from the private sector? And why should suppliers comply with private schemes in addition to official requirements? These questions lead back to the question: Can the EU’s approach in relation to food of non-animal origin guarantee safety? Who benefits from private food schemes? To start with, there are certainly benefits from private food schemes that accrue to suppliers. As elsewhere discussed in this report, cost of compliance should be weighed against the economic loss for products that fail to meet legal requirements. Avoiding loss associated with

43 S. Jaffe et al., 2005:97. 44 BRC/IFS/GFSI presentation on December 7, 2005 in Brussels.

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failure to meet legal requirements could be considered in its own right as major benefits delivered by private food schemes. Also, investment in private schemes may have enabled them to secure supplier-client relationship and even service new clients. 45 Other than suppliers, many potential benefits of standards compliance accrue to stakeholders who do not incur the associated costs.46 In the rest of this chapter, EurepGAP serves as an example to show how benefits are distributed between different stakeholders in the supply chain.

EurepGAP is a non-profit organisation supported by FoodPLUS GmbH, a German Limited Liability Company. It is funded in two ways. Firstly, it is funded by voluntary membership of retailers, producers, etc. However, non-EurepGAP members can also request certification from their suppliers. Secondly, for those who acquire EurepGAP certification, a fee is payable to EurepGAP to implement its integrity programme designed to register compliant producers into a searchable database and to fund independent checks to ensure the ongoing integrity of the EurepGAP system. Fixed charges for EurepGAP certification are published on its website.47 These administrative fees seem transparent and reasonable.

The real controversy lies with the question how the benefits accrue to food business operators through EurepGAP certification. EurepGAP operates on a business-to-business basis and is not consumer-facing. Final products on the market do not bear any logos to indicate that they are produced on a EurepGAP-certified farm. As such consumers are not necessarily aware of the existence of EurepGAP and do not necessarily pay any price premium for it. Since there is no price premium for compliance with EurepGAP, supermarkets and retailers can well argue that they do not resort to EurepGAP as a marketing strategy to attract consumers. Since non-members can also free-ride on EurepGAP certification, EurepGAP becomes a cheap and convenient “due diligence defence” to protect business operators from liability claims or from NGO campaigns on food safety issues. These food business operators can benefit from EurepGAP without incurring any extra costs.

Furthermore, the benefits that accrue to certification bodies should not go unnoticed. Generally speaking, the certifying body collects fixed certification charges on behalf of EurepGAP and also charges its own fee to cover the cost of the audit.48 NRI/IIED points to the alarming fact that price hike driven by certification bodies is observed due to donor funding. Also, there are serious loopholes detected in auditing,49 which puts the competence of certification bodies in question. If nothing is done on this front, donors’ efforts to help DCs could be compromised by profit-seeking certification bodies without real enhanced controls on food safety which should be expected through private food schemes.

Finally, do consumers benefit from private food schemes? This question relates back to the question why consumers need private food schemes and whether official requirements and controls alone would suffice to guarantee food safety. It also relates back to the question which system could work best to guarantee food safety, i.e. official controls on outcome equivalence or private inspection on system equivalence. All in all, when looking at implications of private food schemes on DCs, private standard-setting organisations should not be the only one to take the flak. All the relevant actors surrounding this issue taken into consideration, we may know better where to start to make it easier for DCs.

45 As BRC points out, the audit report is their property and can be used for purposes such as commercial promotion of their company, proof of safety, etc. 46 S. Jaffe et al., 2005: 19. 47 In 2006 the registration fee per grower was 5 € and the cost for certification, 20 €, amounting to a price of 25 € for a grower going for certification under Option 1 “Individual Certification”. http://www.EUREPGAP.org/documents/webdocs/FEE_TABLE_EUREPGAP_incl_BM_fees_08_03_05.pdf 48 P. Greenhalgh, T. Wandschneider, J. Orchard, A. Graffham, and C. Coote, 2005: 42. 49 In a country with about 90 EurepGAP certified farms, none visited 10 certified farms truly compliant for EurepGAP. (NRI/IIED presentation on Dec. 7th, 2005)

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VII. Comparison between EU Legislation and EurepGAP Control Points The controversy over the impacts of private food schemes on market access for developing countries (DCs) shows no signs of abating. Against the complaint raised in the SPS committee, it is worth exploring if and to what extent EurepGAP requirements are “tougher” than EU food laws and those of the member states as claimed. Where do EurepGAP requirements coincide with EU requirements? Do EurepGAP requirements go beyond EU and member states legislation? Or does EurepGAP only refer to EU standards and those of the member states as explained in the 4th Chapter?

In order to answer these questions, a preliminary comparison is drawn between EU regulations and directives on the one hand, and EurepGAP control points for fruit and vegetables on the other. As indicated in Chapter 3, MRLs, phyto-certificate, marketing standards, food hygiene, additives, materials in contact with food, contaminants etc. may be controlled by competent authorities in member states. EurepGAP requires phyto-certificates for propagation material to ensure good agricultural practices only, but it does not deal with phyto-certificates for end products. EurepGAP does not deal with EU marketing standards, either. Besides, additives and materials in contact with food do not fall within its scope since EurepGAP protocols for fruit and vegetable is a pre-farm gate scheme for fresh produce.

The Commission officials have examined EurepGAP control points on MRLs, contaminants and hygiene. Equally important, the Dutch Produce Association (DPA) provides two one-to-one comparison tables between Regulation EC/852/2004 and the “EurepGAP Control Points and Compliance Criteria, Integrated Farm Assurance.50” EurepGAP does not exceed EU requirements on contaminants. Comparison on MRLs and hygiene requirements are discussed next. Maximum residue levels (MRLs) With regards to MRLs, EurepGAP refers to MRLs set in the country of destination of the produce, normally an EU member state. According to “EurepGAP Guideline: MRL, Crop Protection Product, Water Quality and Traceability Information Sources,” the approval at EU level of an MRL or chemical product does not necessarily mean that there is approval of that product for each individual country. Each country in the EU also has some non-approved crop protection products, and therefore each country must be checked for its MRL.

EurepGAP control points51 in relation to crop protection, namely, the whole Chapter 8, are examined by a Commission official. It is concluded that most of these control points fall within the requirements of existing Directive 91/414 and the forthcoming Regulation 396/05 or eventually within those of national legislation of Member States. Two borderline cases are identified, which could exceed corresponding EU legislation. One refers to third country use of pesticides banned in the EU while the other refers to self-testing of residues by farmers.

The first case is EurepGAP control point 8.2.5. It reads, “Are chemicals, banned in the European Union, not used on crops destined for sale in the European Union?” This requirement prohibits the use of crops banned in the EU. However, Directive 1991/414/EEC does not necessarily prohibit in third countries the usage on crops chemicals banned in the EU. As long as pesticide residues left on imported products do not exceed the EU MRLs, farmers in third countries may use on crops chemicals banned in the EU for reasons other than public health reasons. In this case, traders can request an “import tolerance” for a product treated with an active substance which is no longer or not yet used or not authorized in the EU.

For example, substances could be banned in the EU for environmental reasons. In 50 Only the part related to fruit and vegetables in EurepGAP Integrate Farm Assurance. 51 EurepGAP has different control points and compliance criteria for different products. Here, “EurepGAP Control Points & Compliance Criteria for Fruit and Vegetables, Version 2.1-Oct04” is compared.

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these cases, it may be possible to set MRLs higher than limit of determination (LOD) – effectively close to zero—based on the use outside the EU. The rationale behind is that given different environmental situations, an environmental problem for the EU may not be a problem for a third country.

Case of this kind is but only a theoretical possibility. In practice, chances that shipments or consignments rejected due to the use of banned pesticides in the EU for reasons other than toxicology are extremely low. According to the Commission official, for none of the roughly 20 banned substances, importers will be able to provide enough data to obtain an import tolerance set for the specific pesticides in question. Besides, given that international consensus on substances detrimental for the environment has been converge and consolidated (e.g. POPS convention), different environmental considerations are rarer nowadays. An environmental problem for the EU might also be a problem for a third country in most cases.

On the other hand, “EurepGAP Guideline: MRL, Crop Protection Product, Water Quality and Traceability Information Sources” reads, for MRLs outside EU, EurepGAP requires that where no legislation exists regarding a particular crop protection product and/or crop in the country of destination (the later may happen where the crop protection product is simply left out of the MRL list of the country of destination, because that product for that crop is not used in the country, perhaps due to climate restrictions), reference must be made to the FAO Codex list, or to the EU import tolerance level set if the country of destination is within the EU. It seems that EurepGAP also refers to EU “import tolerance” on crop protection product which is not used in the member states.

The second borderline case is EurepGAP control point 8.7.1. It reads, “Is the farmer or farmer’s customer able to provide current evidence either of annual residue testing or of participation in a third party crop protection product residue monitoring system, which is traceable to the farm and that covers the crop protection products applied to the crop/produce?” Nonetheless, the EU does not require self-testing as such to be done by the farmer himself. As the Commission official puts, in Article 4 of Regulation 854/2004 on food hygiene, sampling and analysis is mentioned as an obligation for food business operators, but this is merely a general provision; criteria requirements and targets must still be filled in. It is unlikely that growers will be obliged to take and analyse samples for pesticides. Perhaps other business operators will do so for other contaminants. The Commission official considers this requirement by EurepGAP as very premature. General hygiene provisions Chapter 9 of EurepGAP control points 52 refers to requirements on hygiene related to harvesting. It corresponds to Annex I of Regulation EC/852/2004 on the hygiene of foodstuffs which contains simplified procedures similar to the hygiene requirements for processed products. EurepGAP control point 9.1.1 reads, “Has a hygiene risk analysis been performed for the harvest and pre-farm gate transport process?” This requirement refers to a risk analysis which is not required for primary production in EU legislation.

In detail, the DPA has made two comparison tables between Regulation EC/852/2004 on the one hand and the “EurepGAP Control Points and Compliance Criteria, Integrated Farm Assurance (IFA), Version 2.0Mar-05” on the other.53 Appendix C is a comparison from Part A of Annex 1 of Regulation EC/852/2004 to EurepGAP IFA. Appendix D is a comparison from EurepGAP IFA to Regulation EC/852/2004. The DPA also specifies where EurepGAP requirements on the hygiene for foodstuffs exceed Regulation EC/852/2004. However, the relevant Commission desk officers may wish to have a look at these comparison tables before 52 EurepGAP Control Points & Compliance Criteria for Fruit and Vegetables, Version 2.1-Oct04. 53 Special thanks to Mr. Ad J. M. Klaassen, Secretary of DPA, who kindly sent thes comparison tables to the Commission for information.

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making any judgement. This information could serve as platform for further discussions between the Commission and EurepGAP. Dimensions beyond food safety According to EurepGAP Terms of Reference 54 , its requirements are set to respond to consumer concerns on food safety, animal welfare, environmental protection as well as worker health, safety and welfare. A representative of EurepGAP conceded that these responses might be additional to regulatory requirements on food safety. Broadly speaking, EU legislation also considers environmental protection, worker safety and animal health. The point is whether EU standards could be imposed on farmers in third countries for crops destined for sale in the EU. Should private food schemes drive social development and environmental measures as well as food safety and quality in DCs?

Due to time constraints, this comparison is not yet completed. It is advisable to identify desk officers in DG ENV and DG AGRI to review other chapters on water quality, on the use of biocide, on good agricultural practices and so on. With the assistance of a comprehensive comparison between EU food legislation and EurepGAP control points, the Commission may wish to consider how to collaborate with EurepGAP in a win-win manner. This point will be further discussed in the last chapter.

54 In “EurepGAP General Regulations for Fruit and Vegetables, Version 2.1-Oct04,” p. 3.

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VIII. Legality of Private Food Schemes in the WTO Among other Commission services, DG TRADE is interested in private food schemes for two reasons. First, DG TRADE is concerned with legality of private standards in the context of the WTO—if the EU can be challenged at the WTO on grounds of EurepGAP, then there is an issue. Second, DG TRADE is concerned with technical assistance for DCs to build their exporting capacity, especially in the post-Doha period. Accordingly, it is important to look closely at the legality of private standards in the context of the WTO before discussing further what the Commission can do to facilitate market access for DCs.

In the SPS Committee in June 2005, St Vincent and the Grenadines, supported by Jamaica, Peru, Ecuador, and Argentina, complained requirements for exporting bananas and other products to European supermarkets. They said that EurepGAP’s SPS and TBT requirements are tougher than the governments’ requirements. This issue was raised again in the SPS Committee in February 2006. Some countries called for Article 13 of the SPS agreement to be clarified. Article 13 says:

“Members are fully responsible under this Agreement for the observance of all obligations set forth herein. Members shall formulate and implement positive measures and mechanisms in support of the observance of the provisions of this Agreement by other than central government bodies. Members shall take such reasonable measures as may be available to them to ensure that non-governmental entities within their territories, as well as regional bodies in which relevant entities within their territories are members, comply with the relevant provisions of this Agreement. In addition, Members shall not take measures which have the effect of, directly or indirectly, requiring or encouraging such regional or non-governmental entities, or local governmental bodies, to act in a manner inconsistent with the provisions of this Agreement. Members shall ensure that they rely on the services of non-governmental entities for implementing sanitary or phytosanitary measures only if these entities comply with the provisions of this Agreement.” (emphasis mine)

Do EurepGAP and other private food schemes fall under the scope of “non-governmental entities”? If yes, the Commission might have a legal base to influence their practices in order to fulfil its international obligations. It is therefore useful to look into the definition of “non-governmental entity” in the SPS Agreement. Non-governmental entity The concept of “non-governmental entities” is not sufficiently defined in the SPS Agreement. The Agreement on Technical Barriers to Trade (TBT Agreement), which is also applicable for agricultural product55, renders a more precise definition of “non-governmental entities.” In Art. 4.1 of the TBT Agreement, in a similar spirit to Art. 13 in the SPS Agreement, speaks of “non-governmental standardizing bodies56”. Here, clearly, “non-governmental entity” means “non-governmental norm-setting organizations.”

In the same spirit, there is a definition of “non-governmental body” in point 8 of Annex 1 to the TBT Agreement, which reads, “Body other than a central government body or a local government body, including a non-governmental body which has legal power to enforce a technical regulation”. Although this definition is rather vague and open-ended, it is possible to argue that, in the light of the context and purpose of the SPS and the TBT agreements, “non-governmental entities” are NOT individual economic operators (or their associations) but rather private entities which have been entrusted by government with the

55 Art 1.3: All products, including industrial and agricultural products, shall be subject to the provisions of this Agreement (TBT Agreement). 56 See also ANNEX 3 to the TBT Agreement on Code of Good Practice.

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performance of certain tasks or which have otherwise a special legal status as regards the development and implementation of SPS/TBT rules.

The EurepGAP system is managed by a non-profit company. EurepGAP standards are set by elected technical standards committees which are composed of 50% retailers and 50% suppliers. Suppliers include farmers, farmer groups, farmer associations, exporters, importers, or their associations. They do not represent their companies or associations but are elected from their constituency to represent their constituency. These committees invite other relevant experts and stakeholders to meetings. Being a voluntary standard, EurepGAP has no legal power, and it is not entrusted by government. In this sense, EurepGAP does not fit into the definition of “non-governmental body” in the TBT Agreement. Intervention or non-intervention If private food schemes, among others, EurepGAP, do not fall within the scope of non-governmental entity, Art. 13 of the SPS Agreement cannot be called upon to regulate what these private organisations are doing. Without referring to international agreements, the Commission is severely constrained in what it can do to influence, much less restrict, what the private sector is doing in the context of global sourcing. After all, these are commercial contracts between two voluntary parties in a free market. Moreover, these private sector organizations say they are reflecting consumer demands. The Commission is in a very difficult position as it can hardly intervene to tell supermarkets or retailers that they cannot insist on such private standards. In a market economy, it would not be reasonable to require business operators to base their sourcing decisions on SPS principles.

However, what will happen if the Commission refrains itself from doing anything with the private sector? SPS and TBT Agreements require equivalence of risk outcome whereas EurepGAP requires demonstration of equivalence of system. Many DCs can prove that their systems can deliver the required equivalence of risk outcome in terms of delivery of safe food using a lower level of resources than those found in richer countries.57 This is not the case with EurepGAP, where equivalence of system is required. Even if EurepGAP refers to the EU and the member states’ legislation, are all the EurepGAP control points really necessary to ensure food safety and GAP on farm? And is compliance with EurepGAP the only way to ensure food safety and GAP on farm? The WTO Agreement on SPS measures requires Members to accept the SPS measures of other members as equivalent to theirs, even if they are not the same, if the exporting Member can show that its own measures achieve the same level of protection as those set by the importing Member.58 Shouldn’t third countries retain their own agricultural practices in the spirit of the SPS Agreement under the WTO?

Furthermore, private food schemes are proliferating. EurepGAP is only one among 400 something schemes. It is indicated that there is an ever-increasing number of NGOs demanding “new” requirements—environmental, social, worker protection, animal welfare etc. All these demands cumulated, it represents a significant additional requirement for third country suppliers, not to mention for DC suppliers. Even so, the EU clients may increasingly not want to contend with such requirements. The case where some German retailers, on top of EurepGAP certification, require of their suppliers one-third the official MRLs indicates such a trend. If nothing is done with this trend, no matter how much the Commission has invested in strengthening capacity for farmers in DCs to export, they still cannot access EU markets controlled by the private sector. This being the case, the Commission’s commitment and efforts in development will be seriously compromised. Hence, some policy options and recommendations are proposed for the Commission in the last chapter.

57 P. Greenhalgh, T. Wandschneider, J. Orchard, A. Graffham, and C. Coote, 2005: 40. 58 SPS & Biotechnology Sector Overview, DG Trade G2, Brussels, August 2004.

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VIIII. Policy Options and Recommendations In the course of the whole analysis, several “realities,” if not facts, have been identified. First, private food schemes may yield beneficial as well as detrimental effects on market access for developing countries (DCs). Second, the role of supermarkets, retailers and certification bodies in compliance with private food schemes should not go unnoticed. Third, EurepGAP refers to EU legislation and that of Member States, but some of its control points do exceed legal requirements. Forth, under the WTO legal framework, the Commission is not obliged to deal with these private food schemes. Finally, if the Commission abstains from dealing with these private food schemes, its investment in building export capacity of DCs could be offset.

Given these realities, what could the Commission possibly do with these private food schemes? What could be the reasonable measures as may be available to the Commission to minimise adverse impact of private food schemes on market access for DC suppliers? Some policy options are proposed in this chapter. We start with legal possibilities and then proceed with political recommendations.

i. Legal Instruments—Regulation EC/882/2004

In order to integrate these private standard-setting organisations into the EC regulatory process, it is reasonable to examine which legal instruments are at the Commission’s discretion. Since EurepGAP claims to be a set of specifications to meet EU food safety standards, could there be a role for EurepGAP in official controls? Regulation EC/882/2004 elaborates on how official controls should be carried out, which is a reasonable place to start. Official controls in theory and in practice Regulation EC/882/2004 sets out the role of the Commission’s Food and Veterinary Office (FVO) in evaluating the performance of national enforcement bodies. The FVO carries out missions in each Member State as well as in third countries in order to gauge their compliance with EU guidelines, evaluate the effectiveness of their residue monitoring program and issue recommendations for improvement.59 The Commission is responsible for requesting third countries intending to export food to the Community to provide accurate and up-to-date information on the general organisation and management of sanitary control systems.60 This is largely the situation at present in relation to food of animal origin. For food of animal origin, the FVO carries out inspections on spot, based on which the FVO writes a report to the Commission. According to the FVO report, the Commission makes a positive list of countries and establishments which are allowed to export to the EU.

However, for food of non-animal origin, the FVO cannot oblige competent authority or producers and farmers in third countries to bring their systems in line with EU requirements. No such positive list of countries and establishments as in the case of food of animal origin is required. The FVO only submits reports to the Commission, and the reports are available to the private sector as well. Based on these reports, the private business operators can decide if they would like to source from certain third counties or establishments.61 In other words, it is unlikely that Regulation EC/882/2004 would impact on suppliers of foods of non-animal origin unless EU decides to extend requirements for approved laboratories and competent authorities to foods of non-animal origins.62 59 S. Jaffee, 2003: 17. 60 European Commission, 2005: 11. 61 Art. 48 opens the possibility for building up a positive list of third countries which want to export food of non-animal origins to the EU. This is not yet the case at present. 62 NRI/IIED presentation on Dec. 7th, 2005.

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In reality, however, the FVO reports indicate that official controls present widely varying practices. For example, in most EU countries the monitoring of pesticide residues is for surveillance purposes only and not linked to direct actions to ensure enforcement. Products with excessive MRLs or detected residues for non-approved pesticide uses are rarely subjected to any official enforcement mechanism.63 Admittedly, with regard to food of non-animal origin, compliance with EU requirements other than phytosanitary certificates has been ensured in most cases by non-governmental bodies, and imports were allowed upon the guarantees offered by the importer of the food into the EU.64 EurepGAP as certification bodies auditing EU standards? In comparison with food of animal origin, there is still room left for official controls on food of non-animal origin to be enhanced. Since EurepGAP appears to be a set of specifications for primary producers to meet EU legislation and that of Member States, and it has an established mechanism of sanction for non-compliance, could EurepGAP serve to certify or audit those farmers/producers who want to export to EU markets?

In principle, Article 5 of Regulation EC/882/2004 allows the competent authority (in member states as well as in third countries) to delegate specific tasks related to official controls to private control bodies. At the same time, it stipulates many requirements for the designation of these tasks. Such control bodies must be well-equipped, sufficiently-staffed and accredited. They must be independent, transparent, impartial and free from conflict of interest. They must have an accurate description of the tasks and laboratories. They must communicate the results of the controls to the competent authority on a regular basis.

The issue is then that EurepGAP is part of company auto-controls (self-regulation). If presented as a control body, EurepGAP does not subscribe to these requirements as set out in Art. 5. Even if EurepGAP fulfilled all these requirements, EurepGAP is a private standard-setting organisation and as such is not a certification body. It does not carry out any auditing itself, and the auditing is delegated to accredited independent certification bodies, such as CMi, EFSIS, Africert, etc. (See Figure 4) Also, EurepGAP is not willing to assume such a role as a control body in third countries. Hence, this does not seem to be a viable option.

Figure 4: Routes of Official and Private Controls

63 This information is drawn from S. Jaffe, 2003: 17. 64 European Commission, 2005: 9. See also S. Jaffee, 2003: 17 for an example in Kenya.

Art. 5 EC 882/2004

Suppliers in third countries

Official Standard-setter: DG SANCO of the Commission

Food and Veterinary Office

National competent authorities in third countries

Private Standard-setting Org., e.g. EurepGAP, BRC, etc.

Accredited Independent Certification Bodies

Accredited private control bodies

Art. 46 EC 882/2004

Accreditation Bodies

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Alternatively, the FVO has had requests from Brazil to take account of EurepGAP. Is it appropriate for the FVO to accept EurepGAP certification systems in third countries as surrogate for inspection and controls by national competent authorities? The main concern is that, is it true that acquiring EurepGAP certification means automatically meeting all the legal requirements? Isn’t there any omission of EU requirements in EurepGAP certification systems? A close examination of the comparison by the Commission officials

In addition, as mentioned previously, some EurepGAP-certified large commercial operations show serious infrastructural non-compliances, which indicates auditor failings. Accordingly, EurepGAP certification does not necessarily guarantee meeting EU legal standards in practice. At the same time, the FVO reported no access to EurepGAP certification progress. If the Commission intervenes, it assumes liability. What if safety-related problems are detected or reported on products produced on a EurepGAP-certified farm? Should the Commission shoulder the responsibility?

There could also be a dimension of domino effects. Why should the Commission accept EurepGAP alone and not any other 400 private food schemes? If the Commission endorses EurepGAP, what if more and more private standard-setting organisations follow suit, asking for recognition? Since any stricter requirements than legal ones could be interpreted as specifications to fulfil EU legal requirements, any official recognition could lead to never-ending escalation. Moreover, if the Commission recognised private food standards, they would have a legal justification for their further developments. When a new risk is identified, will the PS organisations be able to resist increasing the level of protection? The Commission should be the only legal body to set the level of protection. Could its authority be jeopardised by private food schemes? Again, this does not appear to be a desirable policy option.

ii. Political Recommendations When choosing means to ends, sense of proportionality is perhaps what it is all about. If legal instruments to policy objectives would cause undesirable repercussions, alternative political means may appear advisable. In Chapter 6, relevant economic players associated with this issue have been identified. It is worthwhile to start with these economic actors. Dialogues between the Commission and private standard-setting organizations Admittedly, private organisations are perfectly within their rights to set their standards, and the Commission is not in the position to intervene. However, the Commission could ensure that the private sector does not establish standards in a void without taking account of the wider implications, including on trade with DCs. As a minimum both should talk to each other and perhaps share the platform when discussing with third countries. The informal seminar on Dec. 7th, 2005 is a place to start. Dialogues between both sides could be continued in forms of working groups, advisory committee etc. Both sides could perhaps also discuss how to bring costs of compliance down, if possible.

With the comparison tables provided in this report, the Commission desk officers in charge of different parts of EU food laws can be identified to examine the comparison and then have a discussion with EurepGAP. EurepGAP welcomes such a gap analysis with the Commission experts to identify any material differences between EU Regulations and EurepGAP. BRC is also open to discussing with the Commission on issues related to market access for DCs. BRC is sending its senior trainer to Kenya on 27-30 March 2006 to train local auditors of Africert. In so doing, BRC hopes to perform evaluations locally soon and possibly train food safety courses in the future. It is therefore sensible that the Commission makes the best of these good wills to find a political solution to this issue raised in Geneva.

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Dialogues among the Commission, supermarkets/retailers and NGOs In addition to private standard-setting organizations, dialogues between the Commission and supermarkets/retailers should be initiated. It is after all supermarkets and retailers that require private certification and impose additional requirements upon their suppliers, such as lower MRLs, no smallholders etc. Their requirements make it a more difficult and perhaps expensive business for DCs to send compliant products onto the EU market. It is worrying if, as seems to be the case in Germany in respect of pineapples, a consortium of retailers establishes a more rigorous standard on MRL than the EU one that, in effect, closes the German part of the internal market to certain products from certain traditional suppliers.

Politically, it might not be particularly comfortable for the Commission to argue that supermarkets must accept products with more pesticide in order to please third countries. But the point is, if products from DCs meet the established science-based safety standards at the EU level, these products ARE safe. The imposition of a more rigorous MRL than EU ones caused DC producers extra cost, only to serve supermarkets’ interest in due diligence defence. It is also suggested that cost transfer and benefit sharing along the supply chain should be more transparent. If there is evidence that the retailers pass the benefit they get from price premium onto the suppliers in DCs, some consumers might be more willing to pay extra in order to help suppliers in DCs. This could be achieved by setting a corner or shelves dedicated to products from DCs, labelled with “fair-trade products.”

Perhaps the supermarkets and retailers are not really aware of specific problems they may cause DCs. As pointed out by EurepGAP, the retailers do what they do because they believe that is what their customers want, and if they please their customers they will sell more products which is good for everyone. The Commission could sensitize the supermarkets and retailers to specific concerns in relation to their individual requests. The Commission could invite major European supermarkets and retailers as well as representatives from PIP, COLEACP, ACP countries or NGOs advocating “fair-trade” etc. to discuss together. PIP, COLEACP, ACP countries and NGOs could present the difficult situations that suppliers in DCs are confronted with. The Commission can also discuss with supermarkets and retailers on issues related to “fair trade” or “ethical trading” initiative. Enhance supervision of certification bodies As mentioned before, significant loopholes in auditing have been frequently detected, which implies incompetence of some certification bodies. Besides, price hike driven by certification bodies is observed owing to donor funding. Quality of audits is a key element for the integrity of any standards. Since certification bodies are accredited by accreditation bodies, good accreditation is a pre-requisite for successful auditing. The supervision of the performance of certification bodies as well as the work of accreditation bodies should be strengthened. Making use of EurepGAP in technical assistance for DCs Technical assistance for DCs to upgrade their systems to meet the EU standards can serve as a remedial measure. Most national schemes in DCs lack the necessary infrastructure and thus are unable to demonstrate equivalence of system. For them, adoption of an off-the-shelf scheme with established international credibility, such as EurepGAP, is an easier route than attempting to develop a national scheme and trying to get European retailers to have confidence in its operation.65

Again, it would not be politically correct for the Commission to formally sponsor farmers in DCs to meet EurepGAP requirements. It might not appear legitimate to use EU taxpayers’ money to help DCs meet more expensive private food standards. However, given

65 P. Greenhalgh, T. Wandschneider, J. Orchard, A. Graffham, and C. Coote, 2005: 40.

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that EurepGAP is the only available scheme with clear guidance to meet EU standards, and given that EurepGAP has become de facto entry permission to EU markets, the Commission might think of a way to make use of EurepGAP on the front of technical assistance. NRI and PIP (funded by the Commission) have provided technical assistance for DCs to meet EurepGAP since it appears to be the easiest way for suppliers in DCs to access EU markets. The Commission on the board of EurepGAP? Finally, one fresh produce association suggested that the Commission sits on the board of EurepGAP. The Commission will then have a vote in EurepGAP technical standards committees and can thus have a say in EurepGAP standard-setting process. Given that EurepGAP is applied industry-wide in Europe as a minimum requirement, it is further suggested that if there will be a harmonised official food scheme at the EU level, much duplication could be avoided when this official scheme is benchmarked against EurepGAP. This being the case, the industry does not have to adjust to a completely new scheme. Although this proposal makes sense in practice, the Commission should be cautious about the way it collaborates with the private sector as this would again be a sign of endorsing EurepGAP. Evidently, it is in the interest of the industry to make such a proposal, but it does not necessarily reflect the Commission’s interest. Ensuing repercussions of such a policy should be weighed against the benefit it may bring.

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Conclusion To approach private food schemes and their impacts on developing countries (DCs), it is important to understand how they relate to compliance with regulatory requirements. Two dimensions are brought to attention. First, EU legislation on food safety stipulates legal requirements for suppliers in third countries to observe; however, it does not specify how to meet those legal standards. This is where private food schemes cut in. They set out specific measures with reference to EU legislation and that of Member States to ensure products imported to the EU to be legally-compliant. As means to ends, they claim to assist DC suppliers in legal compliance who otherwise would have to struggle with complicated EU legislation on food safety and that of Member States.

Second, the EU requires “equivalence of risk outcome” as required by SPS and TBT. For food of non-animal origin, official controls are only conducted on the final products imported to the EU. The production process in the country of origin is not checked. Competent authorities in third countries are relied on to carry out inspections on farm. However, for horticultural products, no positive lists of countries or establishments which are allowed to export to the EU are required. The FVO cannot oblige competent authorities in third countries to bring their systems in line with EU ones. There is no way to verify effective official controls of competent authority in third countries. Many DCs do not have sound national food safety systems, and some of them do not even have functioning competent authorities. This renders EU business operators a justification to resort to private certification, if only allowing them to show due diligence and to protect themselves from legal claims.

The question boils down to whether it is necessary to go further than “equivalence of risk-outcome” to require “equivalence of system” from third countries if controls on risk-outcome alone should perfectly ensure food safety. In the spirit of the SPS Agreement, the EU cannot impose its food safety systems onto third countries. Nevertheless, the SPS Agreement can only oblige its Members, and as such business operators are not subject to this Agreement. In addition, private schemes are required as part of a commercial contract between suppliers in DCs and retailers/supermarkets in the EU. The latter can well argue that they do not “impose” private standards onto DCs since it is a voluntary business decision. These business operators often argue that they require private certification to ensure food safety and reflect consumer concerns. This being the case, the powers of the Commission to intervene in any free market operation are actually very restricted.

Regulation EC/882/2004 does open the possibility for public-private collaboration on controls of food safety. It is but not advisable for the Commission to recognise any private food schemes because if the Commission did, it would assume liability for what the private sector is doing—or doing wrong. However, the Commission may wish to continue dialogues with private standard-setting organisations as well as to initiate conversation with retailers and supermarkets, if only to sensitise them to the specific concerns of DC suppliers. The Commission should also pay attention to the market of certification bodies to avoid price hike undermining donors’ efforts in assisting DCs. On the front of technical assistance, the Commission may wish to make use of EurepGAP specifications to help DCs upgrade their systems to meet EU standards on food safety, without explicitly referring to EurepGAP.

Due to time constraints, some relevant perspectives are not included in this report. Perspectives from European supermarkets and those from certification bodies are missing. European importers and wholesale markets are not consulted. DG TRADE desk officers dealing with ACP countries and Economic Partnership Agreements are not sufficiently consulted. DG Competition is consulted, but its reply has been expected. Any follow-up to this report may wish to consult with these stakeholders in order to gain a comprehensive understanding of developments of private food scheme:

42

REFERENCES Literature: European Commission (2005) “Guidance Document on certain key questions related to import requirements and the new rules on food hygiene and on official food controls.” G.. Jahn, M. Schramm and A. Spiller (2005) “Differentiation of Certification Standards: the Trade-Off between Generality and effectiveness in Certification Systems,” Institute of Agricultural economics, University of Goettingen. G. Stinglhamber (2005) “Maintaining ACP Outgrowers in Fruit and Vegetable Exporting given the New Food Safety Requirements,” PIP/COLEACP. L. Fulponi (2004) “Private Standards and the Shaping of the Agro-Food System,” Working Party on Agricultural Policies and Markets, AGR/CA/APM (2004) 24, OECD. P. Greenhalgh, T. Wandschneider, J. Orchard, A. Graffham, and C. Coote (2005) “Market Access Manual to Facilitate the Growth of Mozambique’s Horticultural Exports into European and Middle east Markets,” PoDE Sector Strategic Initiative Project, Natural Resources Institute. S. Jaffee (2003) “From Challenge to Opportunity: Transforming Kenya’s Fresh Vegetable Trade in the Context of Emerging Food Safety and Other Standards in Europe,” Agriculture and Rural Development Discussion Paper 1, World Bank. S. Jaffee and S. Henson (2004) “Standards and Agro-Food Exports from Developing Countries: Rebalancing the Debate,” World Bank Policy Research Paper No. 3348. World Bank. S. Jaffee et al. (2005) “Food Safety and Agricultural Health Standards: Challenges and Opportunities for Developing Country Exports,” Report no. 31207, Poverty Reduction & Economic Management Trade Unit and Agriculture and Rural Development Department, World Bank. S. Williams, E. Roth, and J. van Roekel (2005) “Changing Public and Private Food Safety and Quality Requirements in Europe: Challenges for Fresh Produce and Fish Exporters in Developing Countries,” Agriculture and Rural Development Discussion Paper 15: Cost of Compliance with SPS Standards, World Bank. W. van Plaggenhoef, M. Batterink and J. H. Trienelkens (2002) International Trade and Food Safety: Overview of Legislation and Standards,” Global Food Network Documents: SPS & Biotechnology Sector Overview, DG Trade G-2, August 2004. EurepGAP Control Points & Compliance Criteria for Fruit and Vegetables, Version 2.1-Oct04, Koeln. (Valid from 29th Oct., 2004; compulsory from 1st, May, 2005)

43

EurepGAP General Regulations for Fruit and Vegetables, Version 2.1-Oct04, Koeln. (Valid from 29th Oct., 2004; compulsory from 1st, May, 2005) EurepGAP Guideline: MRL, Crop Protection Product, Water Quality and Traceability Information Sources, Updated: 28 February 2005, Koln. “Managing the Food Safety Circle—Executive Summary of International food safety Conference,” Rome, 3rd and 4th February, 2005. GFSI Yearbook 2004 Presentations: Nigel Garbutt (EurepGAP), “An Introduction to EurepGAP: Facilitating Trade through safe and Sustainable Agriculture,” Informal seminar, EU-Brussels, Dec. 7th, 2005. Catherine Francois (GFSI), Kevin Swoffer (BRC), and Alexander Rogger (IFS), “Retailer Food safety Management Standards,” Informal seminar, EU-Brussels, Dec. 7th, 2005. Stephanie Williamson (PANUK), “Food & Fairness: Changing Supply Chains for African Livelihoods and Environment,” Informal seminar, EU-Brussels, Dec.7th, 2005. Andrew Graffham (NRI) and Bill Vorley (IIED), “Experience of Impact of EU Private & Public sector standards on Fresh produce Growers & Exporters in Sub-Saharan Africa,” Informal seminar, EU-Brussels, Dec. 7th, 2005. Hans Jürgen Matern (Metro Group) “Assuring the Whole Chain,” EurepGAP Annual Conference, Amsterdam 2004. Hermann-Josef Nienhoff (QS GmbH) “The QS System: a Cross-Border Voluntary System for Certified Quality Assurance,” Expert workshop, EU-Brussels, 7th April 2005. Marie-Hélène Jouin-Mouline, “Food Quality Assurance and Certification Schemes Managed within an Integrated Supply Chain- Presentation of the French Label Rouge,” Expert workshop, EU-Brussels, 7th April 2005. Web sites: British Retail Consortium: www.brc.org.uk The Food Business Forum: www.ciesnet.com EurepGAP: www.eurep.org EC regulations and directives: http://www.europa.eu.int/eur-lex/en/index.html DG AGRI and DG JRC Pilot Project: http://foodqualityschemes.jrc.es/en/index.html The Global Food Safety Initiative: www.globalfoodsafety.com

44

The International Standard Organisation: www.iso.org The Safety Quality Food Initiative: www.sqfi.com The World Trade Organisation: www.wto.org International Food Standards: www.foodcare.info TESCO: www.tescofarming.com Marks and Spencer: www.marksandspencer.com VLAM:http://www.vlam.be/index.php?taal=uk&productid=5&page=&home=&item=kwaliteitslabels PIP/COLEACP: http://www.coleacp.org/ Contact persons for further information: EurepGAP: Nigel Garbutt (garbutt@Foodplus.org and nigelgarbutt@btinternet.com) BRC: Kevin Swoffer (kswoffer@yahoo.co.uk and kevin.swoffer@brc.org.uk) PIP: Guy Stinglhamber (Guy.Stinglhamber@coleacp.org) Dutch Produce Association: Ad Klaassen (A.Klaassen@thegreenery.com)

45

Appendix A: Examples of Compliance Costs of EurepGAP EXAMPLE 1: Compliance cost with EurepGAP reported by NRI EUREPGAP has fixed charges for certification. In 2004 the registration fee per grower was 5€ and the cost for certification 20€, giving a price of 25€ (US$30) for a grower going for certification under Option 1. For EUREPGAP Option 2, costs are related to the number of growers in the scheme. Some costs were obtained from a pineapple outgrower scheme in Ghana. Thus, for an Option 2 scheme involving 32 outgrowers, the following fees applied: 5€ per registered grower x 32 growers = 160€ 20€ for PMO system check = 20€ 20€ per audited grower, where take √32 = 5 x 20 = 100€ Total fee for EUREPGAP = 280€ (US$336) The certifying body collects this fee on behalf of EUREPGAP and also charges its own fee to cover the cost of the audit. For the group of 32 growers, a Ghana-based certifying body charged US$3,500 for a 6-day audit and US$1,900 each for 2 preaudits of 2 days duration, giving a total of US$7,300. The same certifying body charged US$1,155 (US$30 for EUREPGAP) to carry out a 1-day audit on a large commercial farm under Option 1. A South African based auditing company charged US$3,650 (US$30 for EUREPGAP) for a 2 day pre-audit and 1-day external audit of an Option 1 grower in Ghana. Thus, the day rates for the Ghana and South African-based certifying bodies were US$1,125 and US$1,207 respectively. A European-based certifying body was asked to quote for the audits described above; the day rate given was US$900. For the Option 2 scheme only 3 days would be required for the audit (a realistic figure), giving a total of US$3,036 (US$336 for EUREPGAP), as compared to US$3,500 for the Ghana-based company. Source: P. Greenhalgh, T. Wandschneider, J. Orchard, A. Graffham, and C. Coote (2005) “Market Access Manual to Facilitate the Growth of Mozambique’s Horticultural Exports into European and Middle east Markets,” PoDE Sector Strategic Initiative Project. Natural Resources Institute, p. 42-3.

46

Appendix B: Examples of Cost of Compliance with BRC Cost of auditing standards for fruits and vegetables sector: BRC certification Direct costs External advisory cost (one-time) € 6, 000 - € 8, 000 (depending on company size) Annual Certification € 850 - € 1200 (first year is the most expensive) Cost of material Cost to adjust the interior (e.g. proper lighting) Tests of samples – greater than € 250/sample Annual water sample tests Training quality managers - € 500/training Source: S. Willems, E. Roth and J. van Roekel (2005) Changing Public and Private Food Safety and Quality Requirements in Europe, the World Bank. Costs associated with building up a HACCP system: The design process itself requires months of senior management time plus (usually) input from an array of consultants. One relatively large company, which doesn’t now have an HACCP system, estimates that over the next three years it will cost it some $50,000-70,000 (in managers’ time, training, and consultant’s fees) to put such a system in place. Another large company estimates that the combined annual food safety management costs for its premium and high care lines of business is about $300,000, or 3 percent of its annual turnover of just under $10 million. This includes the pertinent technical staff, cleaning chemicals, the operation of a water filtration system, and health testing of staff. At present, these overhead costs are substantially higher for the ‘high care’ business (i.e. 5 percent of turnover) than for the premium packing business (2 percent of turnover), although this may change as the former continues to grow. Source: S. Jaffee (2003) From Challenge to Opportunity: Transforming Kenya’s Fresh Vegetable Trade in the Context of Emerging Food Safety and Other Standards in Europe, the World Bank. Costs for firms to prepare for certification under the BRC Food Technical Standard: Firms estimate that the preparatory process requires three months of nearly fulltime effort by a senior manager followed by a further one day per week input over six months by the same manager. That level of effort is equivalent to a cost of some $12,000. The audit itself cost about $1,500 per packhouse site. A few firms have several different sites that need to be audited especially if they pack some produce on their own farms. A considerable amount of additional documentation is also required for attaining and maintaining BRC certification. Firms estimate that the additional cost is approximately $200 per month because more office staff is needed. Source: S. Jaffee (2003) From Challenge to Opportunity: Transforming Kenya’s Fresh Vegetable Trade in the Context of Emerging Food Safety and Other Standards in Europe, the World Bank, p. 49.

47

Costs associated with upgrading for BRC: One firm recently undertook a feasibility study that determined that the firm would need to invest just under $150,000 in pack-house modifications and equipment to reach the necessary standard. Such investment would involve: (1) the installation of temperature control equipment in the packing area ($40,000); (2) the partitioning of cold rooms to accommodate pre-cooling, cold storage of un-graded produce and storage of graded produce, all entailing new equipment ($38,000); (3) the installation of produce washing and drying equipment ($35,000); and (4) the lining of the packing area and cold rooms and ceilings with panels coated with food grade materials ($19,000). Several other measures would also be required, including the development of an appropriate documentation system. The firm would also need to hire the necessary food technology staff, develop a HACCP system, and develop an effective system of traceability for its produce. This will cost some additional tens of thousands of dollars. Source: S. Jaffee (2003) From Challenge to Opportunity: Transforming Kenya’s Fresh Vegetable Trade in the Context of Emerging Food Safety and Other Standards in Europe, the World Bank, p. 50

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Appendix C: Comparison between Regulation EC/852/2004 and EurepGAP Control Points for IFA, made by DPA

Regulation EC/852/2004 on the hygiene of foodstuffs

ANNEX 1 PART A: GENERAL HYGIENE PROVISIONS FOR PRIMARY PRODUCTION AND ASSOCIATED OPERATIONS

EUREPGAP Integrated Farm Assurance

EurepGAP Integrated Farm Assurance

Section Content Control Points I. SCOPE Major/Minor Must Recommendation

1 This Annex applies to primary production and the following associated operations:

1.a the transport, storage and handling of primary products at the place of production, provided that this does not substantially alter their nature;

1.b the transport of live animals, where this is necessary to achieve the objectives of this Regulation; and

Not Applicable Not Applicable

1.c

in the case of products of plant origin, fishery products and wild game, transport operations to deliver primary products, the nature of which has not been substantially altered, from the place of production to an establishment.

II. HYGIENE PROVISIONS

2. As far as possible, food business operators are to ensure that primary products are protected against contamination, having regard to any processing that primary products will subsequently undergo.

1.2.1.1, 2.4.5, 2.6.5, 2.7.1, 4.7.1.6, 4.7.1.7, 4.8.1.1, 4.8.3.5,

4.7.2.1, 4.8.3.1, 4.8.3.6, 4.9.1.4

3.

Notwithstanding the general duty laid down in paragraph 2, food business operators are to comply with appropriate Community and national legislative provisions relating to the control of hazards in primary production and associated operations, including:

1.4.3.2, 1.4.3.4, 2.4.5

3.a

measures to control contamination arising from the air, soil, water, feed, fertilisers, veterinary medicinal products, plant protection products and biocides and the storage, handling and disposal of waste;

1.2.1.1, 1.2.1.4, 1.5.3.3, 2.4.1, 2.4.4, 2.5.1.1, 2.5.1.2, 2.6.4, 2.6.6, 2.6.8, 2.6.9, 2.6.10, 3.2.1.1, 3.2.1.2, 4.2.1, 4.3.1.1, 4.4.1.1, 4.4.2,

1.2.2, 1.5.3.4, 2.6.8.9, 3.2.1.3, 4.3.1.2, 4.4.1.2, 4.4.2.1, 4.5.3, 4.8.3.3,

3.b

measures relating to animal health and welfare and plant health that have implications for human health, including programmes for the monitoring and control of zoonoses and zoonotic agents.

1.2.3.3, 3.1.1, 3.1.2, 4.1.2, 4.1.3.1, 4.1.3.3 t/m 4.1.3.5, 4.3.2.2, 4.3.2.3

4.1.2.1, 4.1.3.2, 4.3.1.2, 4.3.2.4

4 Not Applicable (Food business operators rearing, harvesting or hunting animals or producing primary products of animal origin are to take adequate measures, as appropriate.)

Not Applicable Not Applicable

5 Food business operators producing or harvesting plant products are to take adequate measures, as appropriate:

as below as below

5.a

to keep clean and, where necessary after cleaning, to disinfect, in an appropriate manner, facilities, equipment, containers, crates, vehicles and vessels;

1.2.1.1, 1.2.3.1, 1.2.3.2, 1.2.3.3, 1.3.1,1.2.3.5, 1.3, 2.8.1.1, 3.5.1, 4.4.1, 4.7.1.3, 4.7.1.4. 4.7.1.5

2.7.3.7, 2.7.3.8, 3.5.1.3

5.b to ensure, where necessary, hygienic production, transport and storage conditions for, and the cleanliness of, plant products;

1.2.1.1,1.2.3.5, 2.4.4, 2.4.5, 2.6.8, 2.6.9, 2.7.1, 2.7.3, 3.3.3, 3.4.1.2, 3.5.1.1, 3.5.1.2, 3.5.1.5, 3.5.2.1, 4.3.2.2, 4.3.2.3, 4.7.1

3.5.1.3, 4.3.2.4

5.c to use potable water, or clean water, whenever necessary to prevent contamination; 4.8.2.1, 4.8.2.2

49

5.d to ensure that staff handling foodstuffs are in good health and undergo training on health risks;

1.4.1.3, 1.4.1.4, 1.4.2.1, 1.4.2.2, 1.4.2.3, 1.4.3.4, 2.8.1, 3.3.3, 3.4.1, 4.7.1.6, 4.7.1.7, 4.8.1

5.e as far as possible to prevent animals and pests from causing contamination;

1.2.3.1, 1.2.3.2, 1.2.3.3, 2.7.3.2 5.3.1.3

5.f to store and handle wastes and hazardous substances so as to prevent contamination;

1.2.3.5, 1.5.3.3, 2.4.4.3 t/m 2.4.4.8, 2.6.8, 2.6.9, 4.9.2.3

1.5.3.1, 1.5.3.2, 1.5.3.4, 2.6.8.9, 4.3.2.1, 4.8.3.3, 4.8.3.4

5.g

to take account of the results of any relevant analyses carried out on samples taken from plants or other samples that have importance to human health; and

2.6.7.1, 2.6.7.4, 2.7.2.15 2.6.7.3, 4.8.2.3

5.h to use plant protection products and biocides correctly, as required by the relevant legislation.

2.8.1, 1.4.2, 1.4.3.4, 2.6.1.1, 2.6.1.3, 2.6.2, 2.6.4, 2.6.5, 2.6.6.1, 2.6.10.1, 2.7.2.1 t/m 2.7.2.6, 2.8.1.2 t/m 2.8.1.4, 3.3.2.1, 4.6.1, 4.6.3, 4.9.3.1, 4.9.4

2.6.1.2, 2.6.6.2, 2.6.6.3, 3.3.1.1

6 Food business operators are to take appropriate remedial action when informed of problems identified during official controls.

1.1.2 t/m 1.1.5, 2.6.7.2

III RECORD-KEEPING

7

Food business operators are to keep and retain records relating to measures put in place to control hazards in an appropriate manner and for an appropriate period, commensurate with the nature and size of the food business. Food business operators are to make relevant information contained in these records available to the competent authority and receiving food business operators on request.

1.1.1, 1.2.1.3, 1.2.1.4, 1.2.3.2, 1.2.3.4, 2.4.2, 2.5.1.3, 2.6.7.2, 2.6.8.15, 4.2.2.1

1.2.1.2

8 Not Applicable (Food business operators rearing animals or producing primary products of animal origin.)

Not Applicable Not Applicable

9 Food business operators producing or harvesting plant products are, in particular, to keep records on: as below as below

9.a any use of plant protection products and biocides;

2.6.3, 2.6.4, 2.7.2.2, 2.7.2.3, 2.7.2.7 t/m 2.7.2.14, 3.5.1.4, 4.1.3.5, 4.3.2.2, 4.3.2.3

3.3.1.1

9.b any occurrence of pests or diseases that may affect the safety of products of plant origin; and 1.2.3.4, 2.6.3.6

9.c the results of any relevant analyses carried out on samples taken from plants or other samples that have importance to human health.

2.6.7.1, 2.6.7.4, 2.7.2.15 2.6.7.3, 4.8.2.3

10 The food business operators may be assisted by other persons, such as veterinarians, agronomists and farm technicians, with the keeping of records.

2.4.1.1, 2.4.1.2

Source: The Dutch Produce Association

50

Appendix D: Comparison between EurepGAP Control Points for IFA and Regulation EC/852/2004, made by Dutch Produce Association

Regulation EC/852/2004

Nº Control Points

Compliance Criteria Level Postscript

BW

=bey

ond

Ref

eren

ce 1 ALL FARM BASE MODULE

the

law

sect

ion

1.1 RECORD KEEPING AND INTERNAL SELF-ASSESSMENT

7 1.1.1 Are all records requested during the inspection accessible and kept for a minimum period of time of two years unless longer requirement stated in specific control points?

Farmers keep up to date records for a minimum of two years, unless legally required to do so for a longer period. Retrospective records are not requested prior to application for EUREPGAP registration. New applicants must have full records for at least three months prior to the date of inspection. No N/A. (Cross check with 5.3.2, 8.1.3 and 8.4.3, 3 years)

Minor

BW *6 1.1.2 Does the farmer undertake a minimum of one internal self-assessment per year against the EUREPGAP Standard?

There is documentary evidence that the EUREPGAP internal selfassessment has been carried out annually. No N/A.

Major

Alle van toepassing zijnde controlepunten inclusief de Recommendationen moeten zijn ingevuld. Als interne audit niet is uitgevoerd, dan inspectie afbreken en na 3 maanden terugkomen.

BW *6 1.1.3 Has the internal self-assessment been documented and recorded?

The EUREPGAP Checklist has been completed and documented. No N/A. Major

6 1.1.4 Are effective corrective actions taken as a result of non-conformances detected in the internal self-assessment?

Effective corrective actions are documented and have been implemented. No N/A Major

51

6 1.1.5 Have any minor must non-compliances that were detected externally in the previous inspection been addressed through the application of a corrective action plan designed to correct them?

The farmer shows evidence that a plan has been designed and implemented for addressing the issues that led to the minor must noncompliance being raised in the previous external inspection and an improvement in the compliance of the respective points has resulted. Where the cause of the non-compliance is external to the farmer, he must show evidence of continued efforts to find a solution. No N/A unless this is the first inspection

Major

1.2 SITE HISTORY AND SITE MANAGEMENT This section is intended to ensure that the land, buildings and other facilities, which constitute the fabric of the

farm, are properly managed to ensure the safe production of food and protection of the environment. Principe

1.2.1 SITE HISTORY 2,

3a,5a,5b 1.2.1.1 Are farms and other facilities suitable for the intended

purpose, maintained in good repair and used so as to achieve the objectives of this standard?

There must be a visual assessment to make sure that the facilities are suitable for the intended purpose, maintained and in good repair. This include assessment of the premises for example soil structure drainage and climate for outdoor livestock. Water and feed equipment suitable for stock and type. No N/A.

Minor

7 1.2.1.2 Is a recording system established for each unit of production or other area/location to provide a permanent record of the livestock production and/or other agronomic activities undertaken at those locations? Are these records kept in an ordered and up-to-date fashion?

Current records should provide a history of production of all fields (going back at least one rotation) and buildings (going back at least 5 years).

Recommendation

7 1.2.1.3 Is reference system for each field, yard, plot, livestock building or other area/location used in production established and referenced on a farm plan or map?

Compliance must include visual identification in the form of a physical sign at each fields/plots/buildings/pens etc. or a farm plan or map that could be cross referenced to the identification system. No N/A.

Minor

52

7 1.2.1.4 Where there is a change of site (i.e. crop or livestock enterprise), is a risk assessment undertaken, taking into account the prior use of the land or site and all potential impacts of the production on adjacent crops, livestock production and other areas?

A documented risk assessment (verbal is enough) must be carried out when new crops or livestock enterprises are to be introduced onto existing sites or new sites are to be cropped/stocked. The risk assessment must take account of site history (crops/stocking) and consider impact of proposed enterprises on adjacent stock/crops/environment (see EurepGAP Guidelines for Risk Assessment for new sites)

Minor

1.2.2 Site Management

BW *3a 1.2.2.1 Has a management plan been developed setting out strategies to minimise all identified risks, such as pollution or water table contamination? Are the results of this analysis recorded and used to justify that the site in question is suitable?

A management plan that has implemented strategies to meet the objectives of this specific control point.

Recommendation

BW *3a 1.2.2.2 Does the management plan include planned rotations which are designed to minimise the reliance on Crop Protection Products, optimise the use of artificial and organic fertiliser, maintain soil structure and condition and to minimise the use of livestock health products, consistent with the maintenance of good livestock welfare?

A management plan that has implemented strategies to meet the objectives of this specific control point. Compliance with requirements of environmental plan if required by law can be used as evidence.

Recommendation

1.2.3 Pest Control 5e 1.2.3.1 Are all entry points to buildings containing propagation

material, harvested crops, livestock, feed or equipment that may come in contact with them suitably protected to prevent, whenever possible, the ingress of animal pests?

Visual assessment. No N/A unless extensive large animal production situations.

Minor

5e,7 1.2.3.2 Are there site plans with bait points? Site plan showing bait points must exist. No N/A unless there are no baits used for pest control is justification for not using bait on farm (i.e. in extensive large animal production situations).

Minor

3b, 5e 1.2.3.3 Are baits placed in such a manner that non-target species do not have access?

Visual observation. Non-targeted species must not have access to the bait.

Minor

53

7, 9b 1.2.3.4 Are detailed records of animal pest control inspections and necessary actions taken kept?

Records of pest control inspections and follow up action plan(s). The farmer can have his own records. Inspections must take place whenever evidence of pests present. In case of vermin must have a contact number or evidence of in-house capability to control pests. (Cross check Pigs (8.9.1) and Poultry (9.9.11))

Minor

5f (5a,b) 1.2.3.5 To avoid establishing a breeding ground for pests and disease, are farms clear of litter and waste and are there adequate provisions for waste disposal?

Visual assessment that there is no evidence of breeding grounds in areas of waste/litter in the immediate vicinity of the production or storage buildings.

Major

1.3 MACHINERY AND EQUIPMENT 5a 1.3.1 Are lorries/trucks and trailers carrying crops or stock

feed clean and fit for the purpose of carrying raw materials entering into the food chain, with particular care given to the cleanliness of dual purpose trailers to prevent contamination?

Workers to demonstrate awareness at interview and visual assessment of transport vehicles. No N/A unless no crops and no supplement feeding of livestock on farm.

Major

5a 1.3.2 Are all bulk loaders used for loading crops or stock feed cleaned prior to use, with particular care given to the cleanliness of dual purpose loaders, to prevent contamination?

Visual assessment that bulk loaders are kept in a clean, dry and fit state to avoid harm to the goods being carried inside.

Major

5a,b 1.3.3 Is crop or forage conditioning equipment serviced and cleaned in accordance with manufacturers� instructions and are records maintained?

Records must be available, together with manufacturers� instructions. N/A if no relevant equipment.

Minor

1.4 WORKER HEALTH, SAFETY AND WELFARE People are key to the safe and efficient operation of any

farm. This section is intended to ensure safe practice in the work place and that all workers: understand, and are competent to perform their duties; are provided with proper equipment to allow them to work safely; and that, in the event of accidents, proper and timely assistance can be obtained.

Principe

54

1.4.1 Worker Health and Safety BW 1.4.1.1 Do farms with more than 5 workers have a full health

and safety policy based upon a full, written risk assessment? The policy must cover all substances and situations that may be hazardous to health and include all aspects of the farm. The risk assessment and policy must be reviewed and updated whenever any significant changes occur and at least annually.

Where there are 5 full-time or part-time workers including the owners, there must at least be a written Farm Health and Safety policy available. The full written risk assessment can be a generic one. N/A only where less than 5 workers.

Minor

BW 1.4.1.2 Do all farms have a full health and safety policy based upon a full, written risk assessment. The policy should cover all substances and situations that may be hazardous to health and include all aspects of the farm. The risk assessment and policy should be reviewed and updated at least annually.

On all farms there should at least be a written Farm Health and Safety policy available. The full written risk assessment can be a generic one.

Recommendation

BW *5d 1.4.1.3 The health and safety policy must include details of: - Management of Health and Safety issues; - Procedures for reporting accidents; - Locations of the First Aid Kits and Accident and Dangerous Incidents Book; - worker training requirements; - Safety equipment and protective clothing; - Preventative measures to reduce the exposure of workers to dust, noise, harmful gases and other hazards. - to whom accidents and dangerous incidents should be reported; - how and where to contact the local Doctor, Hospital and other emergency services.

The Farm Health and Safety policy scope complies with the Control point items. N/A only where less than 5 workers as described in 1.4.1.1

Minor

BW 1.4.1.4 All workers must be made aware of, and comply with, the requirements of the Farm health and safety policy.

Worker to demonstrate awareness at interview. N/A only where less than 5 workers as described in 1.4.1.1

Minor

BW 1.4.1.5 Is all health and safety information provided and/or displayed in a language that is appropriate to the nationality of the worker employed/ spoken by the worker?

Information to be available in languages spoken. Worker also to demonstrate awareness at interview. No N/A.

Minor

55

BW 1.4.1.6 Is there an Emergency Board situated in a visible location close by the telephone giving details of: - Farm�s map reference? - Directions from nearest fire station? - Location of fire extinguishers? - Location of water sources for fire fighting? - Location of emergency cut-offs for electricity, gas and water supplies? - Emergency telephone number of electricity supplier? - Emergency telephone number of water supplier?

Board sited in a visible location close by the telephone and contains all the required information. No N/A

Recommendation

1.4.2 Training 5d, 5h 1.4.2.1 Are all workers adequately trained and instructed

commensurate with their activity? All workers performing tasks, including making management decisions and undertaking operations, which can have a significant impact on the consumer, operator, environment and the livestock or crop, must be competent on the basis of the following: appropriate education, training, acquired knowledge and/or experience (acquired knowledge and/or experience only for farms with less than 5 workers). Areas covered include for livestock: - Animal welfare - Appropriate medicine usage - Animal nutrition - Farm waste (The criteria above are covered in both the Pig EUREPGAP Standardclause 8.10.1 and the Poultry EUREPGAP Standard clause 9.14.1 ) Areas covered include for Combinable crops: - Use of pesticides - Use of fertilizers The above compliance criteria are referred throughout the Eurepgap Combinable Crops and Fruit and Vegetables Modules. The objectives of this standard/protocol should be communicated to each workers.

Workers to have their responsibilities and tasks identified, demonstrate competence at interview and on the basis of inspection. For farms which do not have more than 5 full-time or part-time workers including the owners at any time of the year, competence can be demonstrated through acquired knowledge and/or experience only. No N/A.

Minor

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5d, 5h 1.4.2.2 All workers handling and/or administering medicines, chemicals, disinfectants or other hazardous substances and all workers operating dangerous or complex equipment must have certificates of competence, and/or details of other such qualifications when required by local law for particular tasks.

Workers who carry out such tasks must be identified, their records scrutinised for relevant national certificates, training and evidence of competence together with authorisation to carry out tasks. No N/A

Minor

5d 1.4.2.3 The farm�s hygiene standards must be documented and adopted by workers on farms with more than 5 workers and no poultry (specifically covered in the poultry module) Workers must receive basic training in the farm�s hygiene requirements. Examples of training subjects are: - the need for hand cleaning; - the covering of skin cuts; - confinement of smoking, eating and drinking to the appropriate areas; - notification of any relevant infections or conditions; - �the use of suitable protective clothing.

All workers on farms with no poultry and more than 5 full-time or part-time workers including the owners at any time of the year have reviewed and signed for the farm�s hygiene standard which must cover subjects listed in the Control Point. Workers must demonstrate awareness at interview. No N/A unless less than 5 workers and no poultry. Cross check with 9.9.5

Minor

1.4.3 Hazards, First Aid, Data Sheets, Protective Clothing/Equipment BW 1.4.3.1 Are manufacturers� data sheets or other applicable

information held for all substances used that are hazardous to worker health.

Data sheets or demonstrate availability through agreement with a responsible organisation must be available.

Minor

BW *3 1.4.3.2 Are First Aid boxes present at all permanent sites and in the vicinity of fieldwork?

First aid box must be at all sites, contents checked, in field where appropriate. No N/A.

Minor

BW 1.4.3.3 Are hazards clearly identified by warning signs and placed where appropriate.

Warning signs must be present. No N/A. Minor

BW *3,5d,5h 1.4.3.4 Is protective equipment available where necessary to all workers (including subcontractors)? Do workers wear appropriate respiratory, ear and eye protection devices where necessary?

Availability of equipment and use, where appropriate. worker to demonstrate awareness at interview. No N/A.

Minor

1.4.4 Worker Welfare BW 1.4.4.1 Do all farms with more than 5 workers have a member

of management who is clearly identifiable as responsible for worker, health, safety and welfare issues?

Where a farm has 5 full-time or part-time workers including the owners at any time during the year, (all farms for Fruit and Vegetable Scope) there must be a member of management responsible for worker health, safety and welfare. It must be detailed in contractual agreements with workers, where outside workers are employed by the farm.

minor

57

BW 1.4.4.2 Are, on all farms with more than 5 workers, management of the site encouraged to hold regular, two-way communication meetings with their workers where issues affecting the business or related to worker health, safety and welfare can be discussed openly? Are records from such meeting available as proof that management is listening to workers concerns?

Where a farm has 5 full-time or part-time workers including the owners at any time during the year, (all farms for Fruit and Vegetable Scope) there should be at least two meetings a year held and planned between management and workers of the site, at which matters related to the business and worker health, safety or welfare can be discussed openly (without fear or intimidation or retribution). Records from such meetings are kept as proof that the meetings have taken place and the concerns of the worker about health safety and welfare are being recorded. The auditor is not required to make judgements about the content accuracy or outcome of such records.

Recommendation

BW 1.4.4.3 Are on site living quarters habitable and have the basic services and facilities?

The living quarters for the workers on farm are habitable, sound roof, windows and doors, and have the basic services of running water, toilets, drains.

Minor

1.5 WASTE AND POLLUTION MANAGEMENT, RECYCLING AND RE-USE 1.5.1 Energy Efficiency BW 1.5.1.1 Do all farms take measures to optimise energy use and

minimise waste? All farms should have an energy policy (which does not necessarily have to be documented) and should demonstrate steps taken to ensure energy efficiency to include maintenance schedules.

Recommendation

1.5.2 Identification of Waste and Pollutants BW 1.5.2.1 Do all farms have a written Farm Waste Management

Plan to prevent the contamination of the air, soil and/or water with harmful pollutants?

A written farm waste management plan should be available that considers air, soil and water contamination.

Recommendation

BW 1.5.2.2 Have all possible waste products been identified in all areas of the business?

All possible waste products (such as paper, cardboard, plastic, oil, etc) produced by the farm processes have been catalogued and documented.

Recommendation

BW 1.5.2.3 Have potential sources of pollution been identified?

Potential sources of pollution (e.g. fertiliser excess, exhaust smoke, oil, fuel, noise, effluent, chemicals, sheep-dip, etc) have been catalogued and documented for all the farm processes.

Recommendation

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1.5.3 Waste and Pollution Action Plan BW *5f 1.5.3.1 Is there a documented plan to avoid or reduce wastage

and pollution and avoid the use of landfill or burning, by waste recycling? Are organic wastes composted on the farm and utilised for soil-conditioning, provided there is no risk of disease carry-over?

A comprehensive, current, documented plan that covers wastage reduction, pollution and waste recycling is available.

Recommendation

BW *5f 1.5.3.2 Has this waste management plan been implemented? There are visible actions and measures on the farm that confirm that the objectives of the waste and pollution action plan are being carried out.

Recommendation

3a, 5f 1.5.3.3 Are the farm and premises clear of litter and waste? Incidental and insignificant litter and waste on the designated areas are acceptable as well the waste from the current day�s work. All other litter and waste has been cleared up. Areas where produce is handled indoors are cleaned at least once a day.

Minor

3a,5f 1.5.3.4 Do the premises have adequate provisions for waste disposal?

Farms have designated areas to store litter and waste. Different types of waste are identified and stored separately. Cross check with 1.2.3.5

Recommendation

1.6 ENVIRONMENT ISSUES 1.6.1 Impact of Farming on the Environment BW 1.6.1.1 Does the farmer understand and assess the impact of

farming activities on the environment? The farmer is able to demonstrate his/her knowledge and competence with regards to minimising the potential negative impact, such as nutrient loss, of the farming activity on the local environment.

Minor Teler moet op de hoogte zijn van wetgeving op milieugebied (=verplicht) en ontwikkelingen volgen. Kan o.a. met informatie uit vakbladen, van landbouworganisaties, gemeenten.

BW 1.6.1.2 Has the farmer considered how he/she can enhance the environment for the benefit of the local community and flora and fauna?

There should be tangible actions and initiatives that can be demonstrated by the farmer either on the farm or by participation in a group that is active in environmental support schemes.

Recommendation

Voldoet als er een milieubeleidsplan (individueel of regionaal) is of milieumaatregelen zijn uitgevoerd.

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BW 1.6.1.3 To protect the environment, is no water abstracted from unsustainable sources?

Sustainable sources are sources that supply enough water under normal (average) conditions.

Recommendation

Voldoet als er een milieubeleidsplan (individueel of regionaal) is of milieumaatregelen zijn uitgevoerd.

BW 1.6.1.4 Has advice on abstraction been sought from water authorities?

There must be written communication from the water authority on this subject (letter, license, etc).

Minor Vergunning aanwezig bij bronnen.

1.6.2 Wildlife and Conservation Policy BW 1.6.2.1 Is a key aim the enhancement of the environment and

biodiversity on the farm through a conservation management plan, either as a regional activity or an individual one?

A formal conservation management plan should be implemented.

Recommendation

Een beleidsplan natuurbeheer (individueel of regionaal) moet aanwezig zijn.

BW 1.6.2.2 Does each farmer have a management of wildlife and conservation policy plan for his/her enterprise?

There must be an action plan (verbal or written) which aims to enhance habitats and increase biodiversity on the farm.

Minor

BW 1.6.2.3 Is this policy compatible with sustainable commercial agricultural production and does it minimise environmental impact of the agricultural activity?

The contents and objectives of the conservation plan imply compatibility with sustainable agriculture and demonstrate a reduced environmental impact.

Recommendation

BW 1.6.2.4 Does the plan contemplate the undertaking of a baseline audit to understand existing animal and plant diversity on the farm?

There is a commitment within the conservation plan to undertake a base line audit of the current levels, location, condition etc. of the fauna and flora on farm so as to enable actions to be planned.

Recommendation

BW 1.6.2.5 Does the plan contemplate taking action to avoid damage and deterioration of habitats on the farm?

Within the conservation plan there is a clear list of priorities and actions to rectify damaged or deteriorated habitats on the farm.

Recommendation

BW 1.6.2.6 Does the plan contemplate the creation of an action plan to enhance habitats and increase bio-diversity on the farm?

Within the conservation plan there is a clear list of priorities and actions to enhance habitats for fauna and flora where viable and increase biodiversity on the farm.

Recommendation

1.6.3 Unproductive Sites BW 1.6.3.1 Has consideration been given to the conversion of

unproductive sites (e.g. low lying wet areas, woodlands, headland strip or areas of impoverished soil) to conservation areas for the encouragement of natural flora and fauna?

There should be a plan to convert unproductive sites into conservation areas where viable.

Recommendation

Indien niet uitvoerbaar dan NVT

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1.7 COMPLAINTS BW 1.7.1 Is there a complaint form available relating to issues

of compliance with EUREPGAP standard? There must be on the farm, and available on request, a clearly identifiable document for complaints relating to issues of compliance with EUREPGAP. No N/A.

Major

BW 1.7.2 Does the complaints procedure ensure that complaints are adequately recorded, studied and followed up including a record of actions taken?

There are documents of the actions taken with respect to such complaints regarding EUREPGAP standard deficiencies found in products or services. No N/A.

Major Klachtenregistratie beoordelen. Indien geen klachten zijn waargenomen dan als Voldoet beoordelen.

2 CROPS BASE MODULE 2.1 TRACEABILITY BW 2.1.1 Is EUREPGAP registered product traceable back

to and trackable from the registered farm where it has been grown?

There is a documented traceability system that allows EUREPGAP registered product to be traced back to the registered farm or, in a Farmer Group, group of registered farms, and tracked forward to the immediate customer. No N/A.

Major Er moet een document aanwezig zijn waar minimaal opstaat dat de afleveringsbonnen bewaard worden en dat op de afleveringsbonnen de NAW-gegevens van de teler staan én de rasnaam eventueel met perceelscodering bij meerdere partijen van hetzelfde ras.

2.2 VARIETIES, SEEDS AND ROOTSTOCKS 2.2.1 Pest and Disease Resistance BW 2.2.1.1 Do the varieties grown have resistance/tolerance to

commercially important pests and diseases?

The farmer is able to justify that varieties grown have disease resistance or tolerance when they are available.

Recommendation

Een rassenlijst, rasomschrijving of informatie van het handelshuis moet aanwezig zijn.

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2.2.2 Seed Treatments and Dressings BW 2.2.2.1 Is the use of seed treatments recorded? When the seed or rootstock has been treated, there

are records with the name of the product(s) used and its target(s) (pests and/or diseases).

Minor Indien het behandelde zaad wordt aangeleverd door derden dan moet het gebruikte middel(en) op de leveringsbon, of ander document vermeld staan. Bij eigen vermeerdering moet zaadbehandeling in teelt- of productregistratie zijn opgenomen.

2.2.3 Sowing/Planting

BW 2.2.3.1 Does the farmer keep records on sowing/planting methods, seed/planting rate, and sowing/planting date?

Records of sowing/planting method, sowing/planting rate and date should be kept and should be available .

Recommendation

2.2.4 Genetically Modified Organisms BW 2.2.4.1 Does the planting of GMO's comply with all

applicable legislation in the country of production?

The registered farm or group of registered farms have a copy of the legislation applicable in the country of production and comply accordingly. Records must be kept of the specific modification and/or the unique identifier. Specific husbandry and management advice must be obtained. Unless no GMO varieties are used, no N/A.

Major Indien het gebruik van GGO-rassen van toepassing kan zijn (zoals bijvoorbeeld uien en maïs) moet duidelijk worden aangegeven (bv met certifcaat) of er wel of niet gebruik wordt gemaakt van de GGO-rassen gewassen.

BW 2.2.4.2 Is there documentation available of any planting, use or production of registered products derived from genetic modification?

If GMO cultivars and/or products derived from genetic modification are used, documented records of planting, use or production of GMO cultivars and/or products derived from genetic modification are available.

Minor

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2.3 SOIL AND SUBSTRATE MANAGEMENT 2.3.1 Soil Mapping BW 2.3.1.1 Have soil maps been prepared for the farm? The type of soil is identified for each site, based on

a soil profile or soil analysis or local (regional) cartographic soil-type map.

Recommendation

Bodemkaart of analyse van algemeen bouwlandonderzoek.

2.3.2 Cultivation BW 2.3.2.1 Have techniques been used that are proven to

improve or maintain soil structure, and to avoid soil compaction?

Techniques applied are suitable for use on the land. Recommendation

Beoordelen op basis van mondelinge informatie teler.

2.3.3 Soil Erosion BW 2.3.3.1 Are field cultivation techniques used to reduce

the possibility of soil erosion? There is visual or documented evidence of cross line techniques on slopes, drains, sowing grass or green fertilizers, trees and bushes on borders of sites, etc.

Minor Dit punt is alleen van toepassing in erosiegebieden genoemd in de HPA-verordening, anders NVT

2.4 FERTILISER USE 2.4.1 Advice on Quantity and Type of Fertiliser BW *3a, 10 2.4.1.1 Are recommendations for application of fertilisers

(organic or inorganic) given by competent, qualified advisers holding a recognised national certificate or similar? Do farmers who use outside professional help (advisers and consultants) regarding the use of fertilisers satisfy themselves that the people on whom they rely are competent to provide that advice?

Where the fertiliser records show that the technically responsible person making the choice of the fertiliser (organic or inorganic) is an external adviser, training and technical competence must be demonstrated via official qualifications or specific training courses, unless employed for that purpose by an official organisation.

Minor Er is schriftelijk bewijs van een agrarische opleiding/cursus/ en/of 5 jaar relevante werkervaring (verantwoordelijk voor bemesting) in combinatie met het gebruik van onderzoek en analyses.

BW *3a, 10 2.4.1.2 Where such advisers are not used, are farmers able to demonstrate their competence and knowledge?

Where the fertiliser records show that the technically responsible person determining quantity and type of fertiliser (organic or inorganic) is the farmer, technical competence must be demonstrated via technical documentation (i.e. product technical literature, specific training course attendance, etc.) or the use of tools (software, on farm detection methods, etc.).

Minor

63

2.4.2 Records of Application 7 2.4.2.1 Have all applications of soil and foliar fertilizers,

both organic and inorganic, been recorded including field, orchard or greenhouse reference?

Records are kept of all fertilizer applications, detailing the geographical area, the name or reference of the field, orchard or greenhouse where the registered product crop is located. No N/A.

Minor Registratie bemesting aanwezig (incl. organische bemesting). Alleen MINAS-bonnen per bedrijf en of per teeltjaar is onvoldoende.

7 2.4.2.2 Have all application dates of soil and foliar fertilizers, both organic and inorganic, been recorded?

Detailed in the records of all fertilizer applications are the exact dates (day/month/year) of the application. No N/A.

Minor

7 2.4.2.3 Have all applications of soil and foliar fertilizers, both organic and inorganic, been recorded including applied fertilizer types?

Detailed in the records of all fertilizer applications are the trade name, type of fertilizer (e.g. N, P. K) or concentrations (e.g. 17-17-17). No N/A.

Minor In registratie moet minimaal handelsnaam worden vermeld. Teler moet aantonen dat hij type meststof en concentratie kan herleiden op basis van handelsnaam.

7 2.4.2.4 Have all applied quantities of soil and foliar fertilizers, both organic and inorganic, been recorded?

Detailed in the records of all fertilizer application is the amount of product to be applied in weight or volume. No N/A.

Minor

7 2.4.2.5 Have all applications of soil and foliar fertilizers, both organic and inorganic, been recorded including the method of application?

Detailed in the records of all fertilizer applications are the application machinery type used and the method (e.g. via the irrigation or mechanical distribution). No N/A.

Minor Methode van toepassing en/of apparatuur mag éénmalig worden vastgelegd + alle uitzonderingen hierop.

7 2.4.2.6 Have all applications of soil and foliar fertilizers, both organic and inorganic, been recorded including the operator details?

Detailed in the records of all fertilizer applications is the name of the operator who has applied the fertilizer. No N/A.

Minor Naam van toepasser mag éénmalig worden vastgelegd + alle uitzondering hierop.

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2.4.3 Application Machinery 5a 2.4.3.1 Is fertilizer application machinery kept in good

condition? There are maintenance records (date and type of maintenance) or invoices of spare parts of both the organic and inorganic fertilizer application machinery available on request.

Minor Keuringsbewijs of facturen van onderdelen of onderhoud aanwezig of onderhoudsregistratie (bv. in agenda, logboek, onderhoudslijst). Visuele inspectie op onderhoud, o.a. loszittende of verbogen onderdelen.

5a 2.4.3.2 Is inorganic fertilizer application machinery verified annually to ensure accurate fertilizer delivery?

Daily calibration verification is allowed. There must, as a minimum, be documented records stating that the verification of calibration has been carried out by a specialised company, supplier of fertilization equipment or by the technically responsible person within the last 12 months. Verification of calibration covers the quantity per time and per area.

Minor Kalibratie mag plaatsvinden door middel van een afdraaitest en/of computergestuurde toediening

2.4.4 Fertiliser Storage BW *7 2.4.4.1 Is there an inorganic fertilizer stock inventory up

to date and available on the farm? A stock inventory which indicates the contents of the store (type and amount) is available and it is updated at least every 3 months.

Minor Voor kortdurige (< 3 maanden) werkvoorraad NVT. Voor restanten (< 500 kg of 1 big bag) NVT.

3a 2.4.4.2 Are inorganic fertilizers stored separately from crop protection products?

The minimum requirement is an air space separated from crop protection products storage facilities, to prevent cross contamination between fertilizers and crop protection products.

Minor Bladmeststoffen in gwb-kast mag, mits apart (niet op dezelfde plank)

3a,5b,5f 2.4.4.3 Are inorganic fertilizers stored in a covered area? The covered area is suitable to protect all inorganic fertilizers, i.e. powders, granules or liquids, from atmospheric influences like sunlight, frost and rain.

Minor Vorstvrij alleen als dit volgens een aanduiding op de verpakking noodzakelijk is. Buitenopslag van big bags voldoet niet.

65

3a,5b,5f 2.4.4.4 Are inorganic fertilizers stored in a clean area? Inorganic fertilizers, i.e. powders, granules or liquids, are stored in an area that is free from waste, does not constitute a breeding place for rodents, and where spillage and leakage is cleared away.

Minor

3a,5b,5f 2.4.4.5 Are inorganic fertilizers stored in a dry area? The storage area for all inorganic fertilizers, i.e. powders, granules or liquids, is well ventilated and free from rainwater or heavy condensation.

Minor Buitenopslag van big bags voldoet niet.

5f, 3a,5b 2.4.4.6 Are inorganic fertilizers stored in an appropriate manner, which reduces the risk of contamination of water courses?

All inorganic fertilizers, i.e. powders, granules or liquids are stored in a manner which poses minimum risk of contamination to water sources, i.e. liquid fertilizer stores must be bunded (according to national and local legislation, or capacity to 110% of the biggest container if there is no applicable legislation), and consideration has been given to the proximity to water courses and flood risks, etc.

Minor Voor vaten en/of containers waarbij de kans op lekkage nihil is of een sterktecertificaat aanwezig is, is geen opvang nodig.

3a,5b,5f 2.4.4.7 Are inorganic and organic fertilizers stored separate from produce and plant propagation material?

Fertilizers are not stored with produce and plant propagation material.

Major Ingeval van permanente opslag van meststoffen (>24 uur) moeten de meststoffen worden afgedekt en moet bij opslag in dezelfde ruimte minimaal 2 meter tussen de meststoffen en het product worden aangehouden.

66

5f, 3a,5b 2.4.4.8 Are inorganic and organic fertilizers stored in an appropriate manner, which reduces the risk of contamination of the environment?

1. All inorganic and organic fertilizers are stored in a manner which poses minimum risk of contamination to water sources and groundwater. They must be stored: a. On level ground, free from protruding stones b. At least 25 metres away from water courses c. At least 50 metres away from sensitive areas, such as boreholes, wells, springs, soakaways, quarries, etc. 2. Inaccessible by members of the public, children and livestock. 3. In secure storage to minimise risk of interference and vandalism. 4. In an area where there is easy access for delivery and emergency vehicles.

Minor

2.4.5 Organic Fertiliser 2,3,5b 2.4.5.1 Is human sewage sludge not used on the farm? No human sewage sludge is used on the farm. No

N/A. Major

2,3,5b 2.4.5.2 Has a risk assessment been carried out for organic fertilizer which considers its source and characteristics, before application?

Documentary evidence is available to demonstrate that the following potential risks have been considered: disease transmission, weed seed content, method of composting etc.

Minor BRL-analyse bij compost voldoet.Minimaal moet standaard risico-analyse zijn ingevuld.

BW *2,3,5b 2.4.5.3 Has account been taken of the nutrient contribution of organic fertilizer applications?

An analysis is carried out, which takes into account the contents of N·P·K nutrients in organic fertilizer applied.

Recommendation

2.5 IRRIGATION/FERTIGATION 2.5.1 Quality of Irrigation Water 3a 2.5.1.1 Is or has untreated sewage water not been used

for irrigation/fertigation? Untreated sewage water is not used for irrigation/fertigation. Where treated sewage water is used, water quality complies with the WHO published Guidelines for the Safe Use of Wastewater and Excreta in Agriculture and Aquaculture 1989. No N/A.

Major

3a 2.5.1.2 Has an annual risk assessment for irrigation/fertigation water pollution been completed?

The risk assessment must consider potential microbial, chemical or physical pollution of all sources of irrigation/fertigation water.

Minor

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7 2.5.1.3 Are records of irrigation water usage maintained?

Records are kept which indicate the date and volume per water meter or per irrigation unit. If the farmer works with irrigation programmes, the calculated and actual irrigated water should be written down in the records.

Minor Registratie aanwezig met datum en hoeveelheid. Zowel watermeter (m3) of neerslagmeter (mm) zijn toegestaan. Bij gebruik van bronnen moet vergunning of melding aanwezig zijn.

2.6 CROP PROTECTION 2.6.1 Basic Elements of Crop Protection BW *5h 2.6.1.1 Has the protection of crops against pests,

diseases and weeds been achieved with the appropriate minimum crop protection product input?

All crop protection product inputs are documented and include written justifications, target and intervention thresholds. No N/A.

Minor Gewasbeschermingsjaarplan en logboek of -registratie moeten aanwezig zijn met vermelding van uitsluitend toegelaten middelen in toegelaten doseringen. Onderbouwing, doel en actiedrempels mogen aantoonbaar herleidbaar zijn, bv naar DLV-gids, CTB-site, ….

BW *5h 2.6.1.2 Do farmers apply recognised IPM techniques? Evidence is available to prove implementation of IPM techniques, where technically feasible.

Recommendation

IPM technieken moeten zijn vastgelegd, bv in gewasbeschermingsplan, teeltregistratie.

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5h 2.6.1.3 Have anti-resistance recommendations been followed to maintain the effectiveness of available crop protection products?

When the level of a pest, disease or weed requires repeated controls in the crops, there is evidence that anti-resistance recommendations are followed if specified by the product label.

Minor Bijvoorbeeld het toepassen van verschillende middelen tegen een bepaalde plaag en/of gewasbeschermingsadviezen opvolgen.

2.6.2 Choice of Chemicals 5h 2.6.2.1 Is the crop protection product applied appropriate

for the target as recommended on the product label?

All the crop protection products applied to the crop are suitable and can be justified (according to label recommendations or official registration body publication) for the pest, disease, weed or target of the crop protection product intervention. No N/A

Major

5h 2.6.2.2 Do farmers only use crop protection products that are registered in the country of use for the target crop where such official registration scheme exists?

All the crop protection products applied are officially registered or permitted by the appropriate governmental organisation in the country of application. Where no official registration scheme exists, refer to the EUREPGAP guideline on this subject and FAO International Code of Conduct on the Distribution and Use of Pesticides. No N/A.

Major

BW *5h 2.6.2.3 Is a current list kept of Crop Protection Products that are used and approved for use on crops being grown?

An up to date documented annual list is available of the commercial brand names of crop protection products (including their active ingredient composition, or beneficial organisms) that are used on crops being, or which have been, grown on the farm under EUREPGAP within the last 12 months. No N/A.

Minor Er moet een lijst aanwezig zijn met alle toegelaten middelen die gebruikt worden (minimaal m.b.t. de Eurepgap-gewassen) of deze gegevens moet aantoonbaar geraadpleegd kunnen worden met een bedrijfsmanagementprogramma of op internet.

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BW *5h 2.6.2.4 Does this list take account of any changes in local and national crop protection product legislation?

The up to date documented list of all commercial brands of crop protection products that are used and officially registered for use on crops being currently grown on farm or which have been grown under EUREPGAP within the last 12 months has been updated according to all the applicable latest changes in crop protection product legislation re crop approvals, harvest intervals, etc. No N/A.

Minor Op de lijst moeten recente toelatingswijzigingen aangegeven zijn. Managementprogramma's of websites moeten aantoonbaar regelmatig ge-update zijn.

BW *5h 2.6.2.5 Are chemicals, banned in the European Union, not used on crops destined for sale in the European Union?

The documented crop protection product application records confirm that no crop protection product has been used within the last 12 months on the crops grown under EUREPGAP destined for sale within the E.U., having been prohibited by the E.U. (i.e. EC Prohibition Directive List - 79/117/EC and amendments).

Major Voldoet in EU-landen als 8.2.2 voldoet

BW *5h 2.6.2.6 If the choice of crop protection products is made by advisers, can they demonstrate competence?

Where the crop protection product records show that the technically responsible person making the choice of the crop protection products is a qualified adviser, technical competence can be demonstrated via official qualifications or specific training course attendance certificate.

Major De technische competentie mag worden aangetoond door middel van een spuitlicentie en/of offiële diploma's of certificaten die na afloop van een cursus uitgereikt worden. Als teler de beslisser is dan NVT.

BW *5h 2.6.2.7 If the choice of crop protection products is made by the farmer, can competence and knowledge be demonstrated?

Where the crop protection product records show that the technically responsible person making the choice of crop protection products is the farmer, technical competence can be demonstrated via technical documentation, i.e. product technical literature, specific training course attendance, etc.

Major De teler moet een geldige spuitlicentie tonen.

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5h,9a 2.6.2.8 Is the correct application rate of the crop protection product for the crop to be treated accurately calculated, prepared and recorded, following label instructions?

There is documented evidence that shows that the correct application rate of the crop protection product for the crop to be treated has followed label instructions and has been accurately calculated, prepared and recorded. No N/A.

Minor Dosering moet zijn vastgelegd in de registratie. Teler moet mondeling toelichten hoe dosering berekend wordt en etikettekst wordt opgevolgd. Het toepassen van een lagere dosering moet onderbouwd zijn, bv door externe adviezen.

2.6.3 Records of Application 9a 2.6.3.1 Have all the crop protection product applications

been recorded including the crop name and variety?

All crop protection product application records specify the name, and variety of crop treated. No N/A.

Major Als rasnaam herleidbaar is via gewasnaam en perceelscode kan deze achterwege blijven.

9a 2.6.3.2 Have all the crop protection product applications been recorded including the application location?

All crop protection product application records specify the geographical area, the name or reference of the farm, and the field, orchard or greenhouse where the crop is located. No N/A.

Major Perceelsnaam of -code moet geregistreerd zijn. Als 4.2.2. voldoet hoeft geografische ligging en bedrijfsnaam of referentie niet aangegeven te worden.

9a 2.6.3.3 Have all the crop protection product applications been recorded including application date?

All crop protection product application records specify the exact dates (day/month/year) of the application. No N/A.

Major

9a 2.6.3.4 Have all the crop protection product applications been recorded including the product trade name and active ingredient(s)?

All crop protection product application records specify the trade name and active ingredient(s) or beneficial insect. No N/A.

Major Voor alle toepassingen moet de handelsnaam geregistreerd worden.M.b.t. de actieve stof(fen) of biologische bestrijders kan gebruik gemaakt worden van een direct opvraagbare GBM-lijst.

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BW *9a 2.6.3.5 Has the operator been identified for crop protection product applications?

The operator applying crop protection products has been identified in the records. No N/A.

Minor Naam van toepasser mag éénmalig worden vastgelegd + alle uitzondering hierop.

BW *9a,9b 2.6.3.6 Have all the crop protection product applications been recorded including justification for application?

The common name of the pest(s), disease(s) or weed(s) treated is documented in all crop protection product application records. No N/A.

Minor Dit is herleidbaar en voldoet met het gewasbeschermingsmiddelenplan.

BW *9a 2.6.3.7 Have all the crop protection product applications been recorded including the technical authorisation for application?

The technically responsible person making the crop protection product recommendation has been identified in the records. No N/A.

Minor Hoeft alleen te worden vastgelegd als de technisch verantwoordelijke een ander is dan de toepasser. Mag éénmalig worden vastgelegd + alle uitzonderingen hierop.

9a 2.6.3.8 Have all the crop protection product applications been recorded including appropriate information to identify the product quantity applied?

All crop protection product application records specify the total amount of product to be applied in weight or volume, or the total quantity of water (or other carrier medium), and dosage in g/l or internationally recognised measures for the crop protection product. No N/A.

Minor De totale hoeveelheid middel moet zijn vastgelegd óf de dosering per ha. wanneer bij de perceelsbeschrijving of plattegrond ook de perceelsoppervlakte is vastgelegd, zodat de totale hoeveelheid herleidbaar is.

BW *9a 2.6.3.9 Have all the crop protection product applications been recorded including the application machinery used?

The application machinery type, for all the crop protection products applied (if there are various units, these are identified individually), and the method used (i.e. knapsack, high volume, U.L.V., via the irrigation system, dusting, fogger, aerial, or another method), are detailed in all crop protection product application records. No N/A.

Minor De apparatuur mag éénmalig worden vastgelegd + alle uitzonderingen hierop.

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BW *9a 2.6.3.10 Have all the crop protection product applications been recorded including the pre-harvest interval?

The pre-harvest interval has been recorded for all crop protection product applications. No N/A.

Major De veiligheidstermijn mag ook worden aangeduid met de eerst volgende mogelijke oogstdatum.

2.6.4 Pre-Harvest Interval 3a,5h,9a 2.6.4.1 Have the registered pre-harvest intervals been

observed? The farmer can demonstrate that all pre-harvest intervals have been observed for crop protection products applied to the crops, through the use of clear documented procedures such as crop protection product application records and crop harvest dates from treated locations. Specifically in continuous harvesting situations, there are systems in place in the field, orchard or greenhouse, e.g. warning signs etc., to ensure fail safe compliance.

Major Datum aanvang oogst moet zijn vastgelegd en voldoen aan de veiligheidstermijn zoals aangegeven op het etiket van de toegepaste middelen. Wanneer een perceel gedeeltelijk wordt behandeld om het andere deel eerder te kunnen oogsten moet uit de registratie d

2.6.5 Application Equipment 2,5a,5h 2.6.5.1 Is application equipment kept in good condition? The crop protection product application machinery is

kept in a good state of repair with documented evidence of up to date maintenance sheets for all repairs, oil changes, etc. undertaken. No N/A.

Minor Facturen van onderdelen of onderhoud aanwezig, óf keuringsbewijs, óf onderhoudsregistratie (bv. in agenda, logboek, onderhoudslijst). Bij meerdere spuiten per apparaat registreren. Visuele inspectie op o.a. lekkage, slangbreuk, -knikken.

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2,5a,5h 2.6.5.2 Is the application equipment verified annually? The crop protection product application machinery has been verified for correct operation within the last 12 months and this is certified or documented either by participation in an official scheme or by having been carried out by a person who can demonstrate their competence. No N/A

Minor Indien van toepassing moet hier gebruik worden gemaakt van de wettelijke kalibratie (SKL-keuring). Daarnaast moet diegene met een spuitlicentie één maal per jaar de apparatuur controleren en de gegevens noteren.

5h 2.6.5.3 When mixing crop protection products, are the correct handling and filling procedures, followed as stated on the label?

Facilities, including appropriate measuring equipment, must be adequate for mixing crop protection products, so that the correct handling and filling procedures, as stated on the label, can be followed. No N/A.

Minor Bij gebruik poeders en granulaten moet weegschaal aanwezig zijn, bij vloeistoffen een maatbeker. Menging in tank is beoordeeld bij 8.5.1 en 8.5.2

2.6.6 Disposal of Surplus Application Mix 3a,5h 2.6.6.1 Is surplus application mix or tank washings

disposed of according to national or local law, where it exists, or in its absence according to points 2.6.6.2 and 2.6.6.3, either of which in this case must be complied with in order to comply with this minor must?

Surplus mix or tank washings are disposed of according to the national or local legislation or, in its absence, according to points 2.6.6.2 and 2.6.6.3. No N/A.

Minor Mondelinge toezegging dat restant opgespoten wordt is voldoende.

3a,5h 2.6.6.2 Is surplus application mix or tank washings applied over an untreated part of the crop, as long as the recommended dose is not exceeded and records kept?

When surplus application mix or tank washings are applied over an untreated part of the crop, there is evidence that the recommended doses (as stated on the label) have not been exceeded and all the treatment have been recorded in the same manner and detail as a normal crop protection product application.

Recommendation

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3a,5h 2.6.6.3 Are surplus application mixes or tank washings applied onto designated fallow land, where legally allowed, and records kept?

When surplus application mix or tank washings are applied onto designated fallow land, it can be demonstrated that this is legal practice and all the treatments have been recorded in the same manner and detail as a normal crop protection product application, and avoiding risk of surface water contamination.

Recommendation

In Nederland NVT

2.6.7 Crop Protection Product Residue Analysis 5g,9c 2.6.7.1 Are the farmer and/or supplier able to provide

evidence of residue testing? Frequency of residue testing must be based on risk assessment, taking into account the crop produced, crop protection products used and market requirements. No N/A

Major Analyseresultaten per gewas zijn voldoende. Of deelname aan residumonitoringsprogramma, wat erkend is door CI.

6,7 2.6.7.2 Is an action plan in place in the event of a maximum residue level (MRL) being exceeded, either of the country of production or of the countries where produce is intended to be traded in?

There is a clear documented procedure of the remedial steps and actions, (this will include communication to customers, product tracking exercise, etc.) to be taken where a crop protection product residue analysis indicates an MRL (either of the country of production or of the countries where his produce is intended to be traded in if different) is exceeded.

Major Actieplan moet aanwezig zijn, of aantoonbaar onderdeel zijn van het monitoringsprogramma. Dit is bij alle residumonitoringsprogramma's die erkend zijn door CI.

5g,9c 2.6.7.3 Are the correct sampling procedures followed? Documentary evidence exists demonstrating compliance with applicable sampling procedures. Sampling can be carried out by the laboratory or by the grower providing the procedure is adhered to.

Recommendation

Voldoet bij residumonitoringsprogramma die erkend zijn door CI. Bij eigen analyses moet het bemonsteringsvoorschrift aanwezig zijn.

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5g,9c 2.6.7.4 Is the laboratory used for residue testing accredited by a competent national authority to ISO 17025 or equivalent standard?

There is clear documented evidence either on the letter headings or copies of accreditations etc. that the laboratories used for crop protection product residue analysis have been accredited to the applicable scope by a competent national authority to ISO 17025 or an equivalent standard (in which case evidence of participation in proficiency tests, e.g. FAPAS is available)

Minor Voldoet bij residumonitoringsprogramma die erkend zijn door CI. Bij eigen analyses moet dit op analyseuitslagen vermeld zijn.

2.6.8 Crop Protection Product Storage and Handling 3a,5b,5f 2.6.8.1 Are crop protection products stored in

accordance with local regulations? The crop protection product storage facilities comply with all the appropriate current national, regional and local legislation and regulations.

Major AMvB-bewijs, Milieuvergunning, keuringsbewijs locale overheid of van AID voldoen.

3a,5b,5f 2.6.8.2 Are crop protection products stored in a location that is sound?

The crop protection product storage facilities are built in a manner which is structurally sound and robust. No N/A.

Minor Visuele inspectie, geen kapotte delen aanwezig.

3a,5b,5f 2.6.8.3 Are crop protection products stored in a location that is secure?

The crop protection product storage facilities are kept secure under lock and key. No N/A.

Minor Sleutel moet uit zicht zijn op kindveilige plaats. Alleen bij gebruik of bij aanvoer van middelen mag kast van slot zijn.

3a,5b,5f 2.6.8.4 Are crop protection products stored in a location that is appropriate to the temperature conditions?

The crop protection product storage facilities are built of materials or located so as to protect against temperature extremes. No N/A.

Minor Vorstvrij bij opslag vloeibare middelen in wintermaanden. Metalen kast uit directe zon.

3a,5b,5f 2.6.8.5 Are crop protection products stored in a location that is fire-resistant?

The crop protection product storage facilities are built of materials that are fire resistant (Minimum requirement RF 30: 30 minutes resistance). No N/A.

Minor Van metaal, steen, stevige planken, stevig plaatwerk, of vuurbestendig kunststof (met verklaring)

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3a,5b,5f 2.6.8.6 Are crop protection products stored in a location that is well ventilated (in case of walk-in storage)?

The crop protection product storage facilities have sufficient and constant ventilation of fresh air to avoid a build up of harmful vapours. No N/A.

Minor Bij betreedbare kast ventilatiespleten, -roosters of ventilator aanwezig.

3a,5b,5f 2.6.8.7 Are crop protection products stored in a location that is well lit?

The crop protection product storage facilities have or are located in areas with sufficient illumination both by natural and by artificial lighting, to ensure that all product labels can be read easily on the shelves. No N/A.

Minor Bij betreedbare kast ingebouwde verlichting of looplamp. Bij losse kast voldoende (kunst)licht in nabijheid om etiketten te kunnen lezen.

3a,5b,5f 2.6.8.8 Are crop protection products stored in a location that is located away from other materials?

The crop protection product storage facilities are located in a separate air space independent from any other materials. No N/A.

Minor Opslag bladmeststoffen, middelen voor privegebruik en hulpmiddelen (bv rugspuit, onkruidstrijkers) toegestaan mits duidelijk apart geplaatst. Verf en dergelijke zijn niet toegestaan.

3a,5b,5f 2.6.8.9 The crop protection product storage facilities are located in a separate air space independent from any other materials. No N/A.

The crop protection product storage facilities are equipped with shelving which is not absorbent in case of spillage, e.g. metal, rigid plastic.

Recommendation

Houten planken mits geverfd of geplastificeerd.

3a,5b,5f 2.6.8.10 Is the crop protection product store able to retain spillage?

The crop protection product storage facilities have retaining tanks or are bunded according to the volume of stored liquid, to ensure that there cannot be any leakage, seepage or contamination to the exterior of the store. No N/A.

Minor De lekbak/opvang moet minimaal 110% van het volume van de grootste container zijn.

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3a,5b,5f 2.6.8.11 Are there facilities for measuring crop protection products?

The crop protection product storage facilities or the crop protection product filling/mixing area if this is different, have measuring equipment whose graduation for containers and calibration verification for scales has been verified annually by the farm.

Minor Goed werkende weegschaal bij poeders of granulaten en maatbeker met duidelijke maatverdeling bij vloeibare middelen. De jaarlijkse controle door de teler hoeft niet vastgelegd te zijn.

3a,5b,5f 2.6.8.12 Are there facilities for mixing crop protection products?

The crop protection product storage facilities or the crop protection product filling/mixing area if this is different, are equipped with utensils, e.g. buckets, water source etc. for the safe and efficient handling of all crop protection products which can be applied. No N/A.

Minor Een menginrichting op de spuit is voldoende.

3a,5b,5f 2.6.8.13 Are there facilities to deal with spillage? The crop protection product storage facilities and all fixed filling/mixing areas are equipped with a container of absorbent inert material such as sand, floor brush and dustpan and plastic bags, that must be signposted and in a fixed location, to be used

Minor Voorzieningen mogen in de kast worden opgeslagen (apart). Buiten de kast (wel in de nabijheid) met aanduidingsteken.

3a,5b,5f 2.6.8.14 Are keys and access to the crop protection product store limited to workers with formal training in the handling of crop protection products?

The crop protection product storage facilities are kept locked and physical access is only granted in the presence of persons who can demonstrate formal training in the safe handling and use of crop protection products. No N/A.

Minor Sleutel moet uit zicht zijn op kindveilige plaats. Alleen bij gebruik of bij aanvoer van middelen mag kast geopend worden door bevoegde met spuitlicentie.

BW *5h,7 2.6.8.15 Is the product inventory documented and readily available?

A stock inventory which indicates the contents of the store is available and it is updated at least every 3 months.

Minor Lijst met namen van middelen of jaarlijkse inventarislijst en ordelijke verzameling van alle afleverbonnen.

BW *3a,5b,5f 2.6.8.16 Are all crop protection products stored in their original package?

All the crop protection products that are currently in the store are kept in the original containers and packs, in the case of breakage only, the new package must contain all the information of the

Minor

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original label. No N/A.

BW *3a,5b,5f, 5h

2.6.8.17 Are only those crop protection products that are approved for use on the crops grown in the crop rotation stored separated within the crop protection product store?

All the crop protection products currently kept in the crop protection product store or which are indicated on the stock rotation records are officially approved and registered (point 8.2.3) for application on the crops within the crop rotation program. Crop protection products used for purposes other than application on crops within the rotation are clearly identified and stored separated from the EUREPGAP crop protection products store.

Minor Zowel gewasbeschermingsmiddelen gebruikt voor EurepGap producten als middelen gebruikt voor andere producten mogen in dezelfde ruimte worden opgeslagen mits duidelijk herkenbaar.

BW 3a,5a,5b, 5f

2.6.8.18 Are liquids not stored on shelves above powders?

All the crop protection products that are liquid formulations are stored on shelving which is never above those products that are powder or granular formulations. No N/A.

Minor Poeders onder vloeistoffen is toegestaan als de vloeistoffen direct in of boven lekbakken staan.

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2.6.9 Empty Crop Protection Product Containers 3a,5a,5b,

5f 2.6.9.1 Are empty crop protection product containers not

re-used? There is no evidence that empty crop protection product containers have been or currently are being re-used in any form or manner. No N/A.

Minor In bedrijf mogen geen herkenbare verpakkingen (met etiketten) worden hergebruikt.

3a,5b,5f 2.6.9.2 Does disposal of empty crop protection product containers occur in a manner that avoids exposure to humans?

The system used to dispose of empty crop protection product containers ensures that persons cannot come into physical contact with the empty containers by having a secure storage point, safe handling system prior to the disposal and a disposal method that avoids exposure to persons. No N/A.

Minor Afvoer moet in overeenstemming met de STORL-aanduidingen zijn (bedrijfsafval of klein chemisch afval). Verpakkingen moeten verplicht gespoeld worden direct na het leegmaken; het is niet toegestaan om niet-gespoelde lege verpakkingen te bewaren.

3a,5b,5f 2.6.9.3 Does disposal of empty crop protection product containers occur in a manner that avoids contamination of the environment?

The system of disposal of empty crop protection product containers minimises the risk of contamination of the environment, watercourses and flora and fauna, by having a safe storage point and a handling system prior to disposal by an environmentally responsible method. No N/A.

Minor Afvoer in overeenstemming met de STORL-aanduiding voldoet. STORL (=Stichting Opruiming restanten Landbouwbestrijdingsmiddelen)

BW *5f 2.6.9.4 Are official collection and disposal systems used?

Where official collection and disposal systems exist, there are documented records of participation by the farmer.

Minor Afvoer moet in overeenstemming met de STORL-aanduidingen zijn (bedrijfsafval of klein chemisch afval).

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3a,5b,5f 2.6.9.5 Are containers not re-used, and where a collection system exists are they adequately stored, labelled and handled according to the rules of a collection system?

All the empty crop protection product containers, once emptied, are not reused, and have been adequately stored, labelled and handled, according to the requirements of official collection and disposal schemes where applicable. No N/A.

Minor Afvoer moet in overeenstemming met de STORL-aanduidingen zijn (bedrijfsafval of klein chemisch afval). Geen hergebruik.

5f 2.6.9.6 Are empty containers rinsed either via the use of an integrated pressurerinsing device on the application equipment, or at least three times with water?

Installed on the crop protection product application machinery there is pressure-rinsing equipment for crop protection product containers or there are clear written instructions to rinse each container 3 times prior to its disposal. No N/A.

Minor Reinigen of spoelen volgens etikettekst. Controle spoelinstallatie valt onder SKL-keuring.

3a,5b,5f 2.6.9.7 Is the rinsate from empty containers returned to the application equipment tank?

Either via the use of a container-handling device or via written procedure for the application equipment operators, the rinsate from the empty crop protection product containers is always put back into the application equipment tank when mixing. No N/A.

Minor Spoelinstallatie wordt beoordeeld bij SKL-keuring. Gekeurde spuit voldoet.

3a,5b,5f 2.6.9.8 Are empty containers kept secure until disposal is possible?

There is a designated secure store point for all empty crop protection product containers prior to disposal that is isolated from the crop and packaging materials i.e. permanently signed and with physically restricted access for persons and fauna.

Minor Afvoer moet in overeenstemming met de STORL-aanduidingen als bedrijfsafval of klein chemisch afval worden opgeslagen en afgevoerd.

3a,5b,5f 2.6.9.9 Are all local regulations regarding disposal or destruction of containers observed?

All the relevant national, regional and local regulations and legislation if it exists, has been complied with regarding the disposal of empty crop protection product containers.

Major Afvoer moet in overeenstemming met de STORL-aanduidingen als bedrijfsafval of klein chemisch afval worden opgeslagen en afgevoerd.

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2.6.10 Obsolete Crop Protection Products 3a,5b,5f,

5h 2.6.10.1 Are obsolete crop protection products securely

maintained and identified and disposed of by authorised or approved channels?

There are documented records that indicate that obsolete crop protection products have been disposed of by officially authorised channels. When this is not possible, obsolete crop protection products are securely maintained and identifiable.

Minor Oude middelen moeten duidelijk apart staan en jaarlijks worden opgehaald of ingeleverd.

2.7 HARVESTED CROP/PRODUCE HANDLING 2.7.1 Hygiene 2,5b 2.7.1.1 Has a hygiene risk analysis been performed for

the harvested crop handling process? There is a documented and up to date (reviewed annually) risk assessment (national, industry-wide, or individual) that covers that hygiene aspect of the harvested crops handling operation.

Minor Een relevante risicoanalyse, bv checklist met risicopunten moet aanwezig zijn. Bijv. risicoanalyse voor akkerbouwmatige teelten, of hygiënecode voor teeltbedrijven van groente en fruit.

2,5b 2.7.1.2 Has a hygiene procedure been implemented for the process of harvested crop handling?

As a direct result of the harvested crop handling hygiene risk analysis, a hygiene (physical, chemical and microbiological contaminants) procedure has been implemented.

Minor Hygiënevoorschriften moeten aanwezig zijn en opgevolgd worden.

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2.7.2 Post-Harvest Treatments 10.3 geldt ook voor opslag bij derden onder verantwoording van teler.

5h,9a 2.7.2.1 Are all label instructions observed? There are clear procedures and documentation available, i.e. post-harvest biocides, waxes and crop protection products application records and packaging/delivery dates of treated products, which demonstrate that the label instructions for chemicals applied to the harvested crop have been observed.

Major Registratie moet aanwezig zijn met uitsluitend toegelaten middelen in toegelaten doseringen. Etiketvoorschriften moeten opgevolgd worden.

5h,9a 2.7.2.2 Are only biocides, waxes and crop protection products used that are officially registered in the country of use, and for use post-harvest on the harvested crop being protected?

All the post harvest biocides, waxes and crop protection products used on harvested crop are officially registered or permitted by the appropriate governmental organisation in the country of application and are approved for use in the country of application and are approved for use on the harvested crop to which it is applied as indicated on the biocides, waxes and crop protection products� labels. Where no official registration scheme exists, refer to the EUREPGAP guideline on this subject and FAO International Code of Conduct on the Distribution and Use of Pesticides.

Major Registratie moet aanwezig zijn met uitsluitend toegelaten middelen.

BW *5h,9a 2.7.2.3 Are any biocides, waxes and crop protection products that are banned in the European Union and used on harvested crop destined for sale in the European Union?

The documented post harvest biocide, wax and crop protection product application records confirm that no biocides, waxes and crop protection products have been used within the last 12 months on the harvested crop grown under EUREPGAP destined for sale within the E.U., having been prohibited by the E.U.

Major Registratie moet aanwezig zijn met uitsluitend toegelaten middelen. (In Nederland zijn geen na-oogstmiddelen toegelaten die niet toegelaten zijn in EU)

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BW *5h 2.7.2.4 Is there a current list of approved post harvest biocides, waxes and crop protection products that have been or will be considered for use on the produce?

There is a documented record available of all the current registered biocides, waxes and crop protection products for post harvest usage on the harvested crop to be treated, and which have been or will be considered for use.

Major Er moet een lijst aanwezig zijn met alle toegelaten naoogst-middelen of deze gegevens moet aantoonbaar geraadpleegd kunnen worden met een bedrijfsmanagementprogramma of op internet.

BW *5h 2.7.2.5 Does this list take into account any changes in biocides, waxes and crop protection products legislation?

The list takes into account the changes of registration status of the post harvest biocides, waxes and crop protection products when they occur (i.e. versions with revision dates).

Major Op de lijst moeten recente toelatingswijzigingen aangegeven zijn. Managementprogramma's of websites moeten aantoonbaar regelmatig ge-update zijn.

BW *5h, 10 2.7.2.6 Is the technically responsible person for the harvested crop handling process able to demonstrate competence and knowledge with regard to the application of biocides, waxes and crop protection products?

The technically responsible person for the post harvest biocides, waxes and crop protection products applications can demonstrate sufficient level of technical competence via nationally recognised certificates or formal training.

Major Toepasser moet in bezit zijn van spuitlicentie.

9a 2.7.2.7 Have the post-harvest biocides, waxes and crop protection products applications been recorded including the harvested crops' identity (i.e. lot or batch of produce)?

The lot or batch of harvested crop treated is documented in all post-harvest biocide, wax and crop protection product application records.

Major In de registratie moet behandelde partij zijn aangegeven.

9a 2.7.2.8 Has the location of application of the post-harvest biocides, waxes and crop protection products applications been recorded?

The geographical area, the name or reference of the farm or harvested crop handling site where the treatment was undertaken is documented in all postharvest biocide, wax and crop protection product application records.

Major Alleen van toepassing bij productbehandeling op andere locatie dan eigen bedrijf.

9a 2.7.2.9 Have the application dates of the post-harvest biocide, wax and crop protection product been recorded?

The exact dates (day/month/year) of the applications are documented in all post-harvest biocide, wax and crop protection product application records.

Major

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9a 2.7.2.10 Has the type of treatment been recorded for the post-harvest biocide, wax and crop protection product applications?

The type of treatment used for product application (i.e. spraying, drenching, gassing etc.) is documented in all post-harvest biocide, wax and crop protection product application records.

Major Registratie moet type behandeling bevatten. Eenmalige vastlegging is voldoende.

9a 2.7.2.11 Has the product trade name of the post-harvest biocide, wax and crop protection product applications been recorded?

The trade name and active ingredient of the products applied are documented in all post-harvest biocide, wax and crop protection productapplication records.

Major Handelsnaam moet in de registratie opgenomen zijn. De actieve stof moet aantoonbaar herleidbaar zijn.

9a 2.7.2.12 Has the product quantity applied of the post-harvest biocide, waxes and crop protection product applications been recorded?

The amount of product applied in weight or volume per litre of water or other carrier medium is recorded in all post-harvest biocide, wax and crop protection product applications records.

Major De totale hoeveelheid middel moet zijn vastgelegd óf de dosering wanneer de totale hoeveelheid opgeslagen product is vastgelegd, zodat de totale hoeveelheid herleidbaar is.

BW *9a 2.7.2.13 Has the operator�s name for post-harvest biocide, wax and crop protection product applications been recorded?

The name of the operator who has applied the crop protection product to the harvested crop is documented in all post-harvest biocide, wax and crop protection product application records.

Minor Naam van toepasser mag éénmalig worden vastgelegd + alle uitzondering hierop.

BW *9a 2.7.2.14 Has the justification for application for the post-harvest biocide, wax and crop protection product applications been recorded?

The common name of the pest, disease to be treated is documented in all post-harvest biocide, wax and crop protection product application records.

Minor Dit voldoet wanneer het aantoonbaar herleidbaar is.

85

5g,9c 2.7.2.15 Are all of the post-harvest crop protection product applications also considered under points 2.6.7.1, 2, 3 and 4 of this document?

There is documentary evidence to demonstrate that the farmer considers all post-harvest fungicide or insecticide applications under Control Points2.6.7.1, 2, 3 and 4 of this document, and acts accordingly.

Major Residuanalyseresultaten van bemonstering tijdens of na productopslag moeten aanwezig zijn. Of deelname aan residumonitoringsprogramma, wat erkend is door CI.

2.7.3 Storage of Harvested Crop

5b 2.7.3.1 Is the risk of contamination by glass or other physical contaminants prevented?

Light bulbs and fixtures suspended above harvested crop or material used for harvested crophandling are of a safety type or are protected/shielded so as to prevent contamination of food in case of breakage. This applies to temporary holdings, long-term stores and all product movement areas.

Major

5e 2.7.3.2 Is access of domestic animals and birds to the facilities restricted?

Domestic animal and bird access to facilities is managed, to prevent harvested cropcontamination.

Major

5b,5e 2.7.3.3 Is a specific storage strategy required for longer term product storage?

Where longer term storage takes place, farmer to demonstrate compliance by means of records detailing the regular checking and follow up actions, such as: regular monitoring of temperature and condition of product, including investigation of any changes. Bird and rodent activity, Water ingress, and hot spots within the heap must have been acted upon and remedied . The frequency of inspection may be reduced once the condition of the crop has stabilised. No N/A unless no longer term storage.

Major

5b 2.7.3.4 Is storage adapted to type of product and conditions, is implementation of best practice encouraged minimising risk of contamination? Storage may be inside or outside.

The storage conditions are adapted to the type of product and conditions (weatherproof, solid floors, suitable walls and doors, etc.).

Major

86

5b 2.7.3.5 Do harvested crops, susceptible to deterioration and, which are stored for more than a few days in conditions that may lead to their deterioration, have conditioning? Does long term stored product have a moisture content and temperature suitable for storage? Damage caused by heating must be avoided.

Product conditioning equipment must be available where applicable and farmer to demonstrate compliance at interview. No N/A unless no storage for more than a few days.

Minor

5b 2.7.3.6 Does the resonsible person have easy access to product storage monitoring devices if they store harvested crops?

The responsible person must demonstrate compliance by showing evidence of the monitoring devices or policy.

Major

5a 2.7.3.7 Is product drying equipment regularly maintained in line with manufacturers' instructions and are the dates recorded?

Maintenance records and manufacturer's instructions should be available.

Recommendation

5a,5b 2.7.3.8 In the case of flat product stores, are hard outside loading areas maintained in a clean and well drained condition?

Loading areas should be clean with no dips and areas where standing water can gather.

Recommendation

5b 2.7.3.9 Is no daylight ingress allowed into longer term storage facilities for products sensitive to light (i.e. potatoes)?

Check for no daylight ingress. Major

87

2.8 WORKER HEALTH, SAFETY AND WELFARE

2.8.1 Protective Clothing/Equipment

5a 2.8.1.1 Is protective clothing cleaned after use? There are procedures in place to clean the protective clothing after use.

Minor

5d,5h 2.8.1.2 Are farmers able to demonstrate that they follow label instructions with regard to use of protective clothing and equipment?

There are appropriate recommendations or procedures for the use of protective clothing and equipment, and are available and used by all workers handling or applying crop protection products, according to the label recommendations. No N/A.

Major

5d,5h 2.8.1.3 Is protective clothing and equipment stored separately from crop protection products?

All the protective clothing and equipment including replacements filters etc., are stored apart and physically separate from the crop protection products in a well-ventilated area. No N/A.

Major

88

5d,5h 2.8.1.4 Are there facilities to deal with operator contamination?

All crop protection product storage facilities and all filling/mixing areas present on the farm have eye wash capability, a source of clean water no more than 10 meters distant, a complete first aid kit and a clear accident procedure with emergency contact telephone numbers or basic steps of primary accident care, all permanently and clearly signed. No N/A.

Minor Of een oogdouche of stromend water (kan vanuit schoonwatertank op spuit) moet aanwezig zijn; én EHBO-koffer moet aanwezig zijn (zie 12.3.1); én ongevallenprocedure aanwezig (zie 12.3.4)

3. COMBINABLE CROPS MODULE

3.1 VARIETIES, SEEDS AND ROOTSTOCKS

3.1.1 Choice of Variety 3b 3.1.1.1 Is the choice of variety based on acceptable

agronomic performance in the local conditions? The farmer must be able to demonstrate the varieties grown meet these requirements either through official trials (variety lists), seed supplier information or customer requirements.

Minor

3.1.2 Seed/Rootstock Quality and Origin 3b 3.1.2.1 Are purchased seeds accompanied by records of

variety name, batch number, supplier, seed certification details and are seed treatment records retained?

Farmer must provide records of variety name, batch number, supplier, seed certification details and seed treatments applied.

Minor

3b 3.1.2.2 Do home-saved seed have available records of the identity, source, treatments applied (e.g. cleaning and seed treatments)?

Farmer must keep records and have them available on the farm.

Minor

3.1.3 Genetically Modified Organisms (GMO) BW 3.1.3.1 Did the farmer inform their direct clients of the

GMO status of the product? Documented evidence of communication must be provided. No N/A if GMO used.

Major

BW 3.1.3.2 Has a risk assessment for handling GM material (crops and trials) been undertaken and a management plan developed setting out strategies to minimise risks, such as adventitious mixing of adjacent non GM crops and maintaining product integrity?

Completion of a basic risk assessment (or demonstrate the application of national risk assessment), demonstrating strategies used to avoid mixing. No N/A if GMO used.

Minor

89

BW 3.1.3.3 Are GMO crops handled and stored separately from other crops to avoid adventitious mixing?

Visual assessment must be made of genetically modified (GMO) crops storage for integrity and identification. No N/A if GMO used.

Major

3.2 FERTILISER USE 3.2.1 Choice of Fertilisers BW *3a 3.2.1.1 Are any application of fertilisers in excess of

national limits avoided? Do fertiliser applications protect surface- and ground-waters from excessive nitrate and phosphate contamination?

Farmer to produce records of application and demonstrate on interview.

Minor

BW *3a 3.2.1.2 Are the application of all fertilisers and manure timed to maximise the efficacy and/or uptake by target crops consistent with minimising any adverse impacts on non-target species or crops; the environment and surface- and ground-waters?

Farmer must demonstrate that consideration has been given to nutritional needs of the crop, soil fertility and residual nutrients on the farm and records must be available as evidence. No N/A

Minor

BW *3a 3.2.1.3 Is an analysis of the levels of nutrients, heavy metals and other potential pollutants in the manure completed according to risk assessment of the nitrate levels, heavy metals and other pollutants before application?

A risk assessment should be made of pollution caused by heavy metals and where these identify a risk, analysis should be made by recognised laboratories, results should be recorded and available.

Recommendation

3.3 CROP PROTECTION 3.3.1 Basic

Elements of Crop Protection

5h, 9a 3.3.1.1 Are the applications of all Crop Protection Products timed to maximise the efficacy and/or uptake by target crops, consistent with minimising any adverse impacts on non-target species or crops, the environment and surface- and ground-waters?

Records should be available which show that the requirements have been met, including written justifications and target intervention thresholds.

Recommendation

3.3.2 Choice of Chemicals 5h 3.3.2.1 Are restrictions imposed by national or local

legislation on crop protection product application methodology complied with?

Where national or local legislation imposes restrictions on methods of crop protection product application (for example: distance to water ways while spraying etc.) farmer must show knowledge at interview and demonstrate compliance.

Major

90

3.3.3 Protective Clothing/Equipment BW *5b,5d 3.3.3.1 Do farmers ensure that Crop Protection Product

handlers and workers have access to washing facilities in the vicinity of their work?

Inspectors to verify by visual inspection. Minor

3.4 HARVESTING 3.4.1 Hygiene 5d 3.4.1.1 Do workers receive basic instructions in hygiene

before handling crops destined for food or feed? Compliance to be demonstrated by workers at interview or records of hygiene basic instructions (i.e. use of jewellery, contamination with foreign bodies, etc.). Applicable to all farms that harvest, cross check with requirement for Hygiene standard, point 1.4.2.3.

Minor

5b,5d 3.4.1.2 Do harvest workers have access to clean toilets and hand washing facilities in the vicinity of their work?

Fixed or mobile toilet and hand washing facilities are accessible to harvest workers who have direct contact with the crop within at least 500 meters and they are in a good state of hygiene.

Minor

3.5 HARVESTED CROP HANDLING 3.5.1 Hygiene 5a,5b 3.5.1.1 Are all product store walls, floors and

horizontal surfaces of any storage, holding or reception facilities cleaned and where appropriate, washed and insecticide treated prior to use? Are residues of previous crops cleaned from all areas including ventilated floors and beneath conveyors?

Farmer to demonstrate compliance at interview and through visual inspection. Applicable to all farms that store harvested crop; cross check requirement for inspection, cleaning and chemical treatment records with Hygiene standard, point 1.4.2.3.

Major

5a,5b 3.5.1.2 Where livestock buildings are intended for use as product storage or temporary holding facilities, are they thoroughly cleaned and power washed at least 5 weeks prior to storage?

Farmer to demonstrate compliance at interview and through visual inspection. Applicable to all farms that store harvested crop; cross check requirement for inspection, cleaning and chemical treatment records with Hygiene standard, point 1.4.2.3.

Major

5a,5b,5e 3.5.1.3 Are pre-harvest insect trapping in product storage areas carried out to demonstrate that cleaning operations have been successful?

Compliance to be demonstrated by the production of receipts for traps and records detailing monitoring. Baits containing nuts should not be used.

Recommendation

91

9a 3.5.1.4 If any pre-harvest product store crop protection products are used, are the product use, dose rate, date of application, reason for application and operator recorded?

Records must be available where applicable. Major

5a,5d 3.5.1.5 Are all equipment used for the harvesting transportation handling, conveying and loading operations of product thoroughly cleaned, visual evidence presented and awareness demonstrated by the responsible workers?

Visual evidence and awareness can be demonstrated by the responsible workers where applicable. Type of cleaning must be appropriate to what was being previously transported.

Major

3.5.2 Haulage 5b 3.5.2.1 Is ex-farm transport carried out by the farmer

covered according to weather conditions, once loaded and during transit?

Farmer/operatives must demonstrate compliance on interview.

Minor

4 FRUIT AND VEGETABLE MODULE

4.1 VARIETIES, SEEDS AND ROOTSTOCKS

4.1.1 Choice of variety or Rootstock

BW 4.1.1.1 Is the farmer aware of the importance of effective crop husbandry in relation to the "mother crops" (i.e. the seed producing crop) of the registered product crop?

Cropping techniques and measures are adopted in the "mother crops" which can minimise inputs such as crop protection products and fertilizers in the registered product crops.

Recommendation

92

4.1.2 Seed/Rootstock Quality

3b 4.1.2.1 Is there a document that guarantees seed quality (e.g.: free from injurious pests, diseases, virus, etc.�) and that states variety purity, variety name, batch number and seed vendor?

A seed record/certificate of the seed quality, variety purity, variety name, batch number and seed vendor is kept and available.

Recommendation

Certificaat of keuringsrapport moet aanwezig zijn of een aankoopbon/leveringsverklaring met minimaal: NAW-teler, soort-/rasnaam, partijnummer, klasse/generatie, hoeveelheid.

4.1.3 Propagation Material

3b 4.1.3.1 Is purchased propagation material accompanied by officially recognised plant health certification?

A plant health certificate is available complying with national legislation or sector organisation guidelines.

Minor Certificaat of keuringsrapport moet aanwezig zijn of een aankoopbon/leveringsverklaring met minimaal: NAW-teler, soort-/rasnaam, partijnummer, klasse/generatie, hoeveelheid.

3b 4.1.3.2 Is purchased propagation material free of visible signs of pest and disease?

When plants have visible signs of pest and disease damage, a justification should be available (e.g. threshold for treatment).

Recommendation

Beoordelen op basis van mondelinge informatie teler.

93

3b 4.1.3.3 Are quality guarantees or certified production guarantees documented for purchased propagation material?

There are records to show propagation material is fit for the purpose i.e. quality certificate, terms of deliverance or signed letters.

Minor Certificaat of keuringsrapport moet aanwezig zijn of een aankoopbon/leveringsverklaring met minimaal: NAW-teler, soort-/rasnaam, partijnummer, klasse/generatie, hoeveelheid.

3b 4.1.3.4 Are plant health quality control systems operational for in-house nursery propagation?

A quality control system that contains a monitoring system on visible signs of pest and diseases is in place and current records of the monitoring system must be available.

Minor Veldkeuringsrapporten of eigen vastleggingen bv spuitboekje of teeltregistratie.

9a 4.1.3.5 Are crop protection product treatments on in-house nursery propagation applied during the plant propagation period recorded?

Records of crop protection product treatments applied during the plant propagation period for in-house plant nursery propagation are available and include product name, application date and doses.

Minor

94

4.2 SITE HISTORY AND SITE MANAGEMENT

4.2.1 Site History

3a 4.2.1.1 Is there a risk assessment for new agricultural sites, which shows the site in question to be suitable for food production, with regards to food safety, operator health and the environment?

There is a documented food safety, operator health and environment risk assessment that takes into account prior use of land, type of soil, erosion, quality and level of groundwater, availability of sustainable water sources, and impact on and of the adjacent area. (See EUREPGAP guidelines for risk assessment for new plantings). When the assessment identifies a noncontrollable risk that is critical to health and/or the environment, the site must not be used for agricultural activities.

Major De risico-inventarisatie hoeft alleen uitgevoerd te worden voor die percelen die voor het eerst in gebruik worden genomen voor agrarische doeleinden.(5 jaar terugkijken), anders NVT. Agrarische bestemming is ook fruitteelt, maar geen veehouderij of andere

3a 4.2.1.2 Is there corrective action plan, setting out strategies to minimise all identified risks in new agricultural sites?

Each identified risk indicates the severity and probability as well the measures taken to prevent or to control the risk.

Minor

4.2.2 Site Management

7 4.2.2.1 Has recording system been established for each field, orchard, or greenhouse?

There are documented records that reference each area covered by a crop with all the agronomic activities related to EUREPGAP documentation requirements of this area. No N/A.

Major Er moet een beschrijving of plattegrond zijn met alle percelen (incl. huurpercelen). Alle teeltactiviteiten (zaaien/planten, bemesten, gewasbescherming, oogsten, afleveren) moeten per perceel worden geregistreerd.

95

4.3 SOIL AND SUBSTRATE MANAGEMENT

4.3.1 Soil Fumigation

3a 4.3.1.1 Is there a written justification for the use of soil fumigants?

There is written evidence and justification for the use of soil fumigants including location, date, active ingredient, doses, method of application and operator.

Minor Een verklaring van de Plantenziektekundige Dienst moet kunnen worden overlegd.

3a 4.3.1.2 Are alternatives to chemical fumigation explored before resorting to the use of chemical fumigants?

The farmer is able to demonstrate assessment of alternatives to chemical soil fumigation through technical knowledge, written evidence or accepted local practice.

Recommendation

4.3.2 Substrates

BW *5f 4.3.2.1 Does the farmer participate in substrate recycling programmes for substrates where available?

The farmer keeps records with quantities recycled and dates. Invoices/loading dockets are acceptable. If there is no participation in a recycling program available, it should be justified.

Recommendation

3b,5b,9a 4.3.2.2 If chemicals are used to sterilise substrates for reuse, has the location of sterilisation been recorded?

When the substrates are sterilised on the farm, the name or reference of the field, orchard or greenhouse are recorded, if sterilised off farm then the name and location of the company which sterilises the substrate

Major Indien ontsmetting elders plaatsvindt moeten naam en adres van het bedrijf dat het substraat ontsmet geregistreerd worden

3b,5b,9a 4.3.2.3 If chemicals are used to sterilise substrates for reuse, has the date of sterilisation, type of chemical, method of sterilisation and name of the operator been recorded?

The following are all correctly recorded: the dates of sterilisation (day/month/year); the name and active ingredient; the machinery (e.g. 1000 l-tank etc); the method (e.g. drenching, fogging); and the operator�s name (the person who actually applied the chemicals and did the sterilisation).

Minor

3b,5b 4.3.2.4 When substrates are reused, has steaming been used for sterilisation?

When substrates are reused, documentary evidence shows that steaming is the option used.

Recommendation

96

BW 4.3.2.5 Are substrates traceable to the source and do not come from designated conservation areas?

There are records that prove the origin of the substrates being used. These records demonstrate that the substrates do not come from designated conservation areas.

Recommendation

4.4 FERTILISER USE

4.4.1 Application Machinery

3a,5a 4.4.1.1 Is fertiliser application machinery kept in good condition?

There are maintenance records (date and type of maintenance) or invoices of spare parts of both the organic and inorganic fertilizer application machinery available on request.

Minor Keuringsbewijs of facturen van onderdelen of onderhoud aanwezig of onderhoudsregistratie (bv. in agenda, logboek, onderhoudslijst). Visuele inspectie op onderhoud, o.a. loszittende of verbogen onderdelen.

3a,5a 4.4.1.2 Is inorganic fertilizer application machinery verified annually to ensure accurate fertilizer delivery?

There are documented records stating that the verification of calibration has been carried out by a specialised company, supplier of fertilization equipment or by the technically responsible person within the last 12 months. Verification of calibration covers the quantity per time and per area.

Recommendation

Kalibratie mag plaatsvinden door middel van een afdraaitest en/of computergestuurde toediening

4.4.2 Inorganic Fertiliser

3a 4.4.2.1 Are purchased inorganic fertilizers accompanied by documentary evidence of chemical content?

Documentary evidence detailing chemical content is available for all inorganic fertilizers used on crops grown under EUREPGAP within the last 12-month period.

Recommendation

Bewijs van chemische samenstelling moet aanwezig zijn, of aantoonbaar te herleiden zijn.

97

4.5 IRRIGATION/FERTIGATION

4.5.1 Predicting Irrigation Requirements

BW 4.5.1.1 Have systematic methods of prediction been used to calculate the water requirement of the crop?

Calculations are available and are supported by data records e.g. rain gauges, drainage trays for substrate, evaporation meters, water tension meters (% of moisture in the soil) and soil maps.

Recommendation

Alleen van toepassing bij Eurepgap-gewassen. In Nederland voor beregening van vollegrondsteelten NVT

BW 4.5.1.2 Is predicted rainfall taken into account when calculating irrigation application?

Documented records are available of predicted and actual rainfall (rain gauges).

Recommendation

In Nederland voor beregening van vollegrondsteelten NVT

BW 4.5.1.3 Is evaporation taken into account when calculating irrigation application?

The farmer is able to demonstrate via documentation which data is used to calculate the evaporation rate and how.

Recommendation

In Nederland voor beregening van vollegrondsteelten NVT

4.5.2 Irrigation/Fertigation Method

BW 4.5.2.1 Has the most efficient and commercially practical water delivery system been used to ensure the best utilization of water resources?

The irrigation system used is the most efficient available for the crop and accepted as such within good agricultural practice.

Recommendation

Voor vollegrondsteelten zijn haspel, sproeiboom, druppelbevloeing geschikt.

BW 4.5.2.2 Is there a water management plan to optimise water usage and reduce waste?

A documented plan is available which outlines the steps and actions to be taken to implement the management plan.

Recommendation

In Nederland voor beregening van vollegrondsteelten NVT

98

4.5.3 Quality of Irrigation Water

3a 4.5.3.1 Is irrigation water analysed at least once a year?

The risk analysis should justify the frequency necessary to analyse the irrigation water if done more frequently than annual.

Recommendation

Bij eigen watervoorziening moet analyse aanwezig zijn.

3a 4.5.3.2 Is the analysis carried out by a suitable laboratory?

The laboratory is able to analyse: N, P, K, Ec and pH.

Recommendation

Moet vermeld zijn op analyse (alleen ijzer en chloor is niet voldoende).

3a 4.5.3.3 Does the analysis consider the microbial contaminants?

According to the risk analysis, there is a documented record of the relevant microbial contaminants.

Recommendation

Moet vermeld zijn op analyse. Als uit risicoanalyse blijkt dat analyse niet noodzakelijk is dan NVT

3a 4.5.3.4 Does the analysis consider the chemical pollutants?

According to the risk analysis, there is a documented record of any chemical residues.

Recommendation

Moet vermeld zijn op analyse. Als uit risicoanalyse blijkt dat analyse niet noodzakelijk is dan NVT

3a 4.5.3.5 Does the analysis consider the heavy metal pollutants?

According to the risk analysis, there is a documented record of any heavy metals contaminants

Recommendation

Moet vermeld zijn op analyse. Als uit risicoanalyse blijkt dat analyse niet noodzakelijk is dan NVT

3a 4.5.3.6 Have any adverse results been acted upon?

Records are available of what actions have been taken and what the results are so far.

Recommendation

99

4.6 CROP PROTECTION

4.6.1 Basic Elements of Crop Protection

BW *5h 4.6.1.1 Has assistance with implementation of IPM systems been obtained through training or advice?

The technically responsible person on the farm has received formal documented training and / or the external technical IPM consultant can demonstrate their technical qualifications.

Minor De technisch verantwoordelijke persoon op het bedrijf heeft een geldige spuitlicentie en/of de externe technische adviseurs op gebied van geïntegreerde bestrijding kunnen hun geldende spuitlicentie overleggen. IPM is onderdeel van de spuitlicentie.

4.6.2 Application Equipment

BW 4.6.2.1 Is the farmer involved in an independent calibration-certification scheme?

The farmer's involvement in an independent calibration certification scheme is documented.

Recommendation

Voldoet met SKL-keuring

100

4.6.3 Crop Protection Product Residue Analysis

BW *5h 4.6.3.1 Is the farmer (or his customer) able to demonstrate that he has information regarding the market in which he is intending to trade his produce, and the MRL restrictions of that market?

The farmer or his customer must have available a list of current applicable MRLs for the market(s) where produce is intending to be traded in (whether domestic or international). The MRLs will be identified by either demonstrating communication with clients confirming the intended market(s), or by selecting the specific country(ies) (or group of countries) where produce is intending to be traded in, and presenting evidence of compliance with a residue screening system that meets the current applicable country(ies�) MRLs. Where a group of countries is targeted together for trading in, the residue screening system must meet the strictest current applicable MRLs in the group.

Major Lijst met Nederlandse MRL's moet aanwezig zijn of aantoonbaar te raadplegen zijn op internet. Wanneer land van afzet onbekend is moet afnemer over de MRL-eisen van de mogelijke afzetlanden beschikken. Bij directe verkoop naar buitenlandse handelaar moet

BW *5h 4.6.3.2 Has action been taken to meet those MRL restrictions of the market the farmer is intending to trade his produce in?

Where the MRLs of the market the farmer is intending to trade his produce in are stricter than those of the country of production, the farmer or hiscustomer can demonstrate that during the production cycle these MRLs have been taken into account (i.e. modification where necessary of crop protection product application regime and/or use of produce residue testing results).

Major Bij binnenlandse afzet is dit NVT.Bij afzet naar buitenland via handelaar moeten aanvullende eisen zijn opgenomen in teeltcontract.Bij directe verkoop naar buitenlandse handelaar moet teler afwijkende MRL-waarden kunnen aantonen.

101

4.7 HARVESTING

4.7.1 Hygiene 5b 4.7.1.1 Has a hygiene risk analysis been performed

for the harvest and pre-farm gate transport process?

There is a documented and up to date (reviewed annually) risk assessment (national, industry-wide, or individual) that covers the hygiene aspects of the harvesting operation as detailed in the following control point 4.7.1.2. No N/A.

Major Een relevante risicoanalyse, bv checklist met risicopunten moet aanwezig zijn. Bijv. risicoanalyse voor akkerbouwmatige teelten, of hygiënecode voor teeltbedrijven van groente en fruit.

5b 4.7.1.2 Has a hygiene procedure been implemented for the harvesting process?

As a direct result of the harvest and pre-farm gate transport hygiene risk analysis, a documented hygiene procedure has been implemented.

Major Hygiënevoorschriften moeten aanwezig zijn en opgevolgd worden.

5a 4.7.1.3 Does the harvesting process hygiene procedure consider containers and tool handling?

Reusable harvesting containers, harvesting tools (i.e., scissors, knifes, pruning shears, etc) and harvesting equipment (machinery) are cleaned and maintained, and a cleaning and disinfection schedule is in place (at least once a year) to prevent produce contamination, in accordance with the harvest hygiene risk assessment results.

Major Reinigings- (en evt. desinfectie-) voorschriften voor oogstmachines, -apparatuur en -fust moeten aanwezig zijn.

5a,5b 4.7.1.4 Does the harvesting process hygiene procedure consider handling of harvested produce and produce packed and handled directly in the field, orchard or greenhouse?

All produce packed and handled directly in the field, orchard or greenhouse must be removed from field overnight, in accordance with the harvest hygiene risk assessment results. All field packed produce must be covered to prevent contamination once packed and during transport (from the fields or outlying farms to where it is stored), in accordance with the harvest hygiene risk assessment results. If harvested and on farm packed produce are stored on farm, storage areas must be cleaned, and if applicable, temperature and humidity control maintained and documented, in accordance with the harvest hygiene risk assessment results.

Major Als op het veld het product al verpakt of bewerkt wordt, moeten afdoende hygiënevoorschriften aanwezig zijn.Als niet bewerkt of verpakt wordt, dan NVT

102

5a,5b 4.7.1.5 Does the harvesting process hygiene procedure consider on farm produce transportation?

Farm vehicles used for transport of harvested produce that are also used for any purpose other than transport of harvested produce, are cleaned and maintained, and a cleaning schedule to prevent produce contamination is in place (i.e. soil, dirt, organic fertilizer, spills, etc.), in accordance with the harvest hygiene risk assessment results.

Major Reinigingsvoorschriften voor transportmiddelen moeten aanwezig zijn.

2,5b,5d 4.7.1.6 Do harvest workers have access to clean hand washing equipment in the vicinity of their work?

Fixed or mobile hand washing equipment is accessible to harvest workers within at least 500 meters and they are in a good state of hygiene. No N/A.

Major Minimaal jerrycan met schoon water. Oogstmedewerkers zijn personen met fysiek productcontact.

2,5b,5d 4.7.1.7 Do harvest workers have access to clean toilets in the vicinity of their work?

Fixed or mobile toilet facilities are accessible to harvest workers within at least 500 meters and they are in a good state of hygiene. No N/A.

Minor Toiletgelegenheden moeten binnen 500 meter of binnen 10 minuten van werkplek liggen, of beschikbaar tijdens vaste werkonderbrekingen

4.7.2 Packaging/Harvesting Containers on Farm

2,5a 4.7.2.1 Are produce containers used exclusively for produce?

Produce containers are only used to contain produce (i.e. no agricultural chemicals, lubricants, oil, cleaning chemicals, plant or other debris, lunch bags, tools, etc.).

Recommendation

Geen ander gebruik van oogstfust toegestaan.

4.7.3 Produce packed at point of harvest

5c 4.7.3.1 Is ice used in produce handling at point of harvest made with potable water and handled under sanitary conditions to prevent produce contamination?

Any ice used at point of harvest should be made with potable water and handled under sanitary conditions to prevent produce contamination.

Recommendation

103

4.8 PRODUCE HANDLING

Indien de productbehandeling onder verantwoording van de teler bij derden wordt verricht, moet inspectie productbehandlings-lokatie worden uitgevoerd of er moet een geldig geaccrediteerd certificaat worden overlegd (EG, BRC, HACCP-NL, IFS, BHC).

4.8.1 Hygiene 2,5b 4.8.1.1 Do workers have access to clean toilets and

hand washing facilities in the vicinity of their work?

Toilets in a good state of hygiene with hand washing facilities, containing non-perfumed soap and water must be accessible and close by, but must not open directly onto the produce handling area unless the door is selfclosing. Unless exclusion from Produce Handling declaration exists for each registered product, no N/A.

Minor

5d 4.8.1.2 Have workers received basic instructions in hygiene before handling produce?

There is evidence (i.e.: signed attendance registration, external certificates) that the workers have received verbal and documented understandable instructions in the relevant aspects of produce handling hygiene including: · personal cleanliness i.e. hand washing, wearing of jewellery and fingernail length and cleaning, etc; clothing cleanliness; personal behaviour, i.e. no smoking, spitting, eating, chewing, perfumes, etc.). Unless exclusion from Produce Handling declaration exists for each registered product, no N/A.

Major Instructies en handtekening voor gezien van medewerkers moeten aanwezig zijn.

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5d 4.8.1.3 Do the workers implement the hygiene instructions for handling produce?

There is evidence that the workers are complying with the hygiene instructions regarding personal cleanliness and clothing, i.e. hand washing, wearing of jewellery and fingernail length and cleaning, etc.; personal behaviour, i.e. no smoking, spitting, eating, chewing, perfumes, etc. Unless exclusion from Produce Handling declaration exists for each registered product, no N/A.

Minor Beoordelen tijdens visuele inspectie. De term medewerkers heeft betrekking op alle betrokken werkkrachten, inclusief bedrijfseigenaren en managers.

4.8.2 Post-Harvest Washing

5c 4.8.2.1 Is the source of water used for final product washing potable or declared suitable by the competent authorities?

Within the last 12 months a water analysis has been carried out at the point of entry into the washing machinery. The levels of the parameters analysed are within accepted WHO thresholds or are accepted as safe for the food industry by the competent authorities.

Major Naspoelen met leidingwater voldoet, tenzij aanvoer plaatsvindt met slangen en buizen van twijfelachtige (hygiënische) kwaliteit. Andere bronnen jaarlijks analyseren op minimaal microbiologische verontreinigingen.

5c 4.8.2.2 If water is re-circulated for final product washing, has this water been filtered and are pH, concentration and exposure levels to disinfectant routinely monitored?

Where water is re-circulated for final produce washing, it is filtered and disinfected, and pH, concentration and exposure levels to disinfectant are routinely monitored, with documented records maintained. Filtering must be done with an effective system for solids and suspensions that have a documented routine cleaning schedule according to the usage and water volume.

Major Als met leidingwater wordt nagespoeld is dit NVT.

5g,9c 4.8.2.3 Is the laboratory carrying out the water analysis a suitable one?

The water analysis for the product washing is undertaken by a laboratory currently accredited to ISO 17025 or its national equivalent or that can demonstrate via documentation that it is in the process of gaining accreditation.

Recommendation

Moet vermeld zijn op analyserapport.

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4.8.3 On farm Facility for Produce Handling and/or Storage

2,5a 4.8.3.1 Are floors designed to allow and ensure drainage?

Floors are designed with i.e. slopes, drainage channels and kept free and clear, to ensure drainage.

Recommendation

Alleen van toepassing bij bedrijven die wassen of spoelen.

5a,5b 4.8.3.2 Are produce handling facilities and equipment cleaned and maintained so as to prevent contamination?

Produce handling facilities and equipment (i.e. process lines and machinery, walls, floors, storage areas, pallets, etc.) must be cleaned and/or maintained according to a cleaning schedule, to prevent contamination, and documented records are kept. Unless exclusion from Produce Handling declaration exists for each registered product, no N/A.

Minor Schoonmaakplan voor gebouwen en apparatuur moet aanwezig zijn.

3a,5a,5f 4.8.3.3 Is rejected produce and waste material stored in designated areas, which are routinely cleaned and disinfected?

Rejected produce and waste material are stored in designated areas, which are routinely cleaned and disinfected, to prevent produce contamination, and documented cleaning records are kept.

Recommendation

Desinfectie alleen indien noodzakelijk.

5b,5f 4.8.3.4 Are Cleaning Agents, Lubricants, etc. kept in a designated area, separate from produce and materials used to handle produce?

Cleaning Agents, Lubricants etc. are kept in a designated area separate and apart from where produce is packed, to avoid chemical contamination of produce.

Recommendation

2 4.8.3.5 Are Cleaning Agents, Lubricants etc. that may come into contact with produce, approved for application in the food industry, and are dose rates followed correctly?

Documentary evidence exists authorising (i.e. specific label mention or technical data sheet) use for the food industry of Cleaning Agents, Lubricants etc. which may come into contact with produce.

Minor Niet van toepassing wanneer na gebruik van schoonmaakmiddelen nagespoeld wordt met leidingwater. Foodgrade smeermiddelen zijn bij kans op productcontact verplicht.

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2 4.8.3.6 Are there written glass and clear hard plastic handling procedures in place?

Written procedures exist for handling glass or clear hard plastic breakages in produce handling, preparation and storage areas.

Recommendation

Kan onderdeel zijn van hygiënevoorschriften

4.9 WORKER HEALTH, SAFETY AND WELFARE

4.9.1 Training BW 4.9.1.1 Is a record of training kept for each worker? A record is kept for each worker which contains the

required training programmes and a copy of the attendance certificates or their signature on a list of people who attended a training course.

Recommendation

Geldt ook voor teler zelf. Bewijs van gevolgde cursus in dossier is voldoende.

BW 4.9.1.2 Is there always at least one person trained in First Aid present on each farm at any one time whenever on-farm activities are being carried out?

At least one person who has had First Aid training within the last 5 years should be present on each farm at any one time whenever on-farm activities are being carried out. Applicable legislation on First Aid training should be followed where it exists. On-farm activities includes growing, transport, and produce handling if applicable.

Recommendation

Op het bedrijf moet een persoon aanwezig zijn die een EHBO en/of BHV diploma heeft.

BW 4.9.1.3 Are accident and emergency instructions clearly understood by all workers?

There are documented, understandable and verbally communicated instructions made to the workers enabling them to know how to act in accident and emergency situations. These instructions are available in the predominant languages of the workforce. Instructions are supported by symbols where possible. No N/A.

Minor

2 4.9.1.4 Are all subcontractors and visitors aware of the relevant demands on personal hygiene?

There is evidence that the company visitor personal hygiene procedures and requirements are officially communicated to visitors and subcontractors (i.e. the company visitor personal hygiene procedures are in a visible place where all visitors or subcontractors can read them).

Recommendation

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4.9.2 Facilities, equipment and accident procedures

BW 4.9.2.1 Do accident and emergency procedures exist? Written procedures must describe how to act in the event of an accident or emergency. The procedures must clearly identify the contact persons; indicate the location of the nearest means of communication (telephone, radio); display an up-to-date list of relevant phone numbers (police, ambulance, hospital, fire-brigade); and be available at all times. No N/A.

Minor

BW 4.9.2.2 Is the accident procedure evident within 10 meters of the crop protection product store?

An accident procedure containing all information detailed in 4.9.2.1 must visually display the basic steps of primary accident care and be accessible by all persons within 10 meters of the crop protection product storage facilities and all mixing areas. No N/A

Minor Uitgezonderd mengplaats op spuitmachine.

5f 4.9.2.3 Are signs warning of potential dangers placed on access doors?

There are permanent and clear hazard warning signs on or next to the access doors of the crop protection product and fertiliser storage facilities. No N/A.

Minor Bij meststoffenopslag alleen van toepassing wanneer de schadelijke meststoffen zijn opgeslagen (zie aanduiding op verpakking).

4.9.3 Crop Protection Product Handling

5h 4.9.3.1 Are the workers who handle and apply crop protection products trained?

All personnel who physically handle or apply crop protection products can demonstrate their competence and knowledge via official qualifications or specific training course attendance certificates. No N/A.

Minor Het tonen van een spuitlicentie wordt als voldoende geacht.

BW 4.9.3.2 Are all staff which has contact with crop protection products submitted voluntarily to annual health checks in line with guidelines laid down in local codes of practice?

If applicable, health checks to which all staff which has contact with crop protection products are voluntarily submitted comply with national, regional or local codes of practice.

Recommendation

Geldt ook voor teler zelf. Er zijn geen in Nederland hiervoor geen richtlijnen.

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4.9.4 Protective Clothing/Equipment

5h 4.9.4.1 Are workers (including subcontractors) equipped with suitable protective clothing in accordance with label instructions?

Complete sets of protective clothing, (e.g. rubber boots, waterproof clothing, protective overalls, rubber gloves, face masks, etc.) which enable crop protection product label instruction to be complied with are available and in a good state of repair. No N/A.

Major Alle beschermingsmiddelen die op de etiketten worden genoemd moeten aanwezig zijn. Bewijs bij loonwerkers kan aantoonbaar herleidbaar zijn via aparte inspecties.

4.9.5 Visitors Safety

BW 4.9.5.1 Are all subcontractors and visitors aware of the relevant demands on personal safety?

There is evidence that the company visitor personal safety procedures and requirements are officially communicated to visitors and subcontractors (i.e. the company visitor personal safety procedures are in a visible place where all visitors or subcontractors can read them).

Minor

4.10 ENVIRONMENT ISSUES

4.10.1 Wildlife and Conservation Policy

BW 4.10.1.1 Has a conservation management plan been established (either individually or on a regional basis)?

There is a documented wildlife and conservation statement.

Minor Een beleidsplan natuurbeheer (individueel of regionaal) moet aanwezig zijn.