Fruits, vegetables and other perishable products make up a significant proportion of the imported food supply. Import controls need to be able to cope with the demand while maintaining a high level of food safety.
The European Commission has identified a list of ‘high risk’ products and/or countries as a known or emerging risk to public health. These products are subject to increased controls at the EU border including documentary, identity and physical checks. During the initial implementation of Commission Regulation 669/2009 (the legislation governing the ‘high risk list’), concerns were raised about the potential for delays whilst perishable consignments were detained at UK ports pending the results of sampling and analysis.
Some of these ‘high risk’ consignments were sourced from assured traders. An Agency pilot scheme was devised to assess whether the level of compliance with permitted levels of pesticide residues on products subject to increased import checks, was improved if farmers/suppliers were part of independent assurance schemes. The outcome of this voluntary monitoring exercise will be assessed as part of this project.
The role of independently accredited certification schemes operating in the global supply chain were also assessed as was the potential role they could play in the better targeting of risk based inspection activity with particular focus on the deployment of imported food checks at UK points of entry.
Some evaluation of previous literature in this field were required to:
- Establish how independently accredited certification schemes operate in the global supply chain and
- Assess the role they may play in the better targeting of future inspection activity at UK points of entry
An Agency-commissioned pilot scheme which explored the performance of certified and non-certified consignments, and the role that third party assurance schemes could play in the food sector, was also considered. The results of the scheme will be particularly pertinent to this study.
EU or third country research and/or trials which have reviewed the suitability of accreditation schemes, in particular from an enforcement perspective, were of interest.
There was some liaison with UK and EU accreditation bodies such as United Kingdom Accreditation service, British Retail Consortium, Global Standard, Global Good Agricultural Practice (Global GAP) and the Soil Association, in relation to organic produce. This involved obtaining a greater understanding about how such schemes work and an evaluation of the types of assurance schemes that are currently available to, and used by UK Importers.
Liaison with Public Health Authorities and Local Authorities was necessary in order to best assess what and how information relating to assurance schemes could be presented.
There was poor participation in the FSA’s pilot scheme. The research needed to establish the reasons and identify how a future pilot scheme might be introduced in the UK.
The research involved contacting a representative number of businesses, ranging from multi-national supermarkets to small and medium-sized cash and carry/wholesale traders, which import fresh fruits and vegetables, using UK designated points of entry.
- Assurance schemes are a common feature of FNAO supply chains. The most common schemes in the FNAO supply chain can be defined as ‘process-based’: their standards focus on the production process, and consist mainly in ensuring that producers have put in place an agreed set of quality assurance measures. This contrasts with official controls for imported FNAO which emphasise compliance controls on the final product – so called ‘product based’ standards. This means that assurance schemes alone are unlikely to be suitable for the prioritisation of FNAO control
- Assurance schemes generally overlap with food safety legislation and, in some cases, go beyond legislative requirements. However, there is little evidence to support the proposition that products produced in accordance with assurance scheme standards are more likely to meet EU import requirements
- In theory, prioritising FNAO controls could involve selecting consignments on the basis of whether or not products were sourced from producers certified to assurance scheme standards. In practice, relying on assurance scheme certification is likely to be problematic as assurance scheme certification alone is unlikely to be a reliable indicator of whether a product is more or less likely to comply with EU import requirements
- The report proposed two policy options with respect to prioritising FNAO import controls. There are advantages and disadvantages with both options
- Implementing either option will require the FSA, DPEs and importers to undertake additional work to determine how the options would function in practice, and perhaps more importantly, establish the demand for the options
- The majority of importers and DPEs interviewed by the study team were unaware of the 2011 pilot and those who were aware of the pilot were uncertain about its objectives and requirements. A future pilot scheme would be more successful if communication about its objectives and requirements were improved and scope limited