CFG
15/07 final
Letter dated 20 May 2007
from Foodaware to Rufina Acheampong, Official Control Regulation Implementation
Team, Food Standards Agency:
Dear Ms Acheampong
Import controls for high-risk feed and food of non-animal
origin
Members have not been able to consider this consultation in detail
but here are our preliminary thoughts in relation to the discussions
on the Working Document. Members want to ensure that there are high,
and equivalent, standards of enforcement throughout the European Community
and that these should apply both to imports and internal trade. We
support a risk based approach to enforcement and so establishing a
list of high risk non-animal products would seem appropriate. There
have been a number of scares and successful interventions by Port
Health Authorities in recent years in relation to produce such as
nuts and figs contaminated with fungal toxins, and risks also arise
from bacterial or viral contamination in plants, fruit and vegetables.
An increasing potential risk will come from genetically modified crops
which are not authorised for sale in the EU.
However, it is important that the list should be a means of identifying
those products which pose the greatest risk and not become a bureaucratic
constraint against action in relation to other products or risks to
health and safety where the need arises. We would encourage you to
ensure that there is some flexibility built in to the system to allow
prompt action where there are particular concerns, or evidence of
potential harm to human health or the integrity of the market.
Equally, such measures must not be used to erect inappropriate barriers
to trade with third countries where it is not warranted by the risk
assessment and a clear need to protect consumer health and safety.
Yours sincerely
Susan Knox
Chairman
|
