The Committee has long been concerned about possible inconsistencies between the standards under which food is produced in the UK compared to other countries from which food is imported. In particular, ACAF has expressed concern about the implications of imports of meat and other animal products not having been produced under comparable feed regimes to those in the UK. The Committee wrote to the Chairman of the Food Standards Agency and organisations representing, or with an interest in, imports of meat and other animal products, earlier this year voicing its concerns.
The Committee contends that the control of animal feed is important in the UK and elsewhere in the European Union (EU), but it is equally important in feeding systems used third countries exporting animal products to the UK and Europe. ACAF supports the statement in the Report of the Food Standards Agency's review of BSE Controls (Review of BSE Controls (December 2000) published by Food Standards Agency - available from www.bsereview.org.uk), that imports should not carry a significantly greater risk than domestic produce.
Bearing in mind that two of the three largest food scares in the European Union (EU) during recent years have been feed-related (i.e. BSE and dioxins), the Committee is of the strong view that there is a clear obligation on all concerned to minimize any potential future risks to the public.
The Committee considers that EU animal feedingstuffs legislation forms a useful basis on which those feeding livestock in third countries, for eventual export to the UK, should proceed. ACAF therefore believes the wider application of these EU standards in countries supplying meat and other animal products to the EU should be sought. This could be by broadening EU rules to such countries and through international fora. These include the Codex Alimentarius Commission and the OIE (the World Organisation for Animal Health). However, we note that negotiations on a proposal for a Council and European Parliament Regulation laying down specific hygiene rules for food of animal origin, containing specific provisions for drawing up lists of third countries from which imports of products of animal origin are permitted, are at an early stage in Brussels.
Examples of anomalies between European controls on feed standards and those in non-EU countries to be addressed are:
ii) An EU ban on the use of processed animal protein in animal feed has been introduced largely to control risks from BSE and other transmissible spongiform excephalopathies. Even if these risks are less in other countries, it is desirable to prohibit the feeding of mammalian material to ruminant animals (e.g. cattle, sheep, goats) throughout the world;
iii) Besides the UK Feed Assurance Scheme, establishments that produce animal feed are required to be approved or registered. To achieve this the staff, premises, equipment, procedures, etc. must meet certain legislative requirements and be monitored with respect to writtten quality assurance criteria. The core of this EU derived legislation is based on Hazard Analysis and Critical Control Point (HACCP) principles. EC law requires these arrangements to apply in countries supplying additives, premixtures and feeds to the EU. This must be pursued more forcibly.
iv) The EC proposal to ban the blending down of materials containing elevated levels of undesirable substances. The Committee has noted the risk of such materials being fed in third countries (without any controls on final feed levels of undesirable substances) and the resultant animal products being imported to the EU.
v) The EC proposal that all feed for sale within the EU be labelled with the full percentage formulation. It would be inconsistent for the EU to allow the import of animal products from animals fed on purchased feed not similarly labelled.
The Committee accepts that controls applying to imported food and feed have to be justified under World Trade Organisation rules. It also welcomes steps being taken by the Food Standards Agency to tighten inspection and other control procedures on the imports of meat and meat products and other foods. However, food analysis alone may not ensure safety. ACAF therefore believes that the application of HACCP principles to control risk in the animal feed supply chain is equally important within third countries wishing to export to the UK, as it is within the UK and EU.
The Committee has asked to be kept informed, at least at each alternative meeting, of steps being taken to minimize the aforementioned anomalies.
The Committee believes that in the interim, companies that are involved in the merchandising of imported food should show due diligence in ensuring that the animal produce they import is subject to satisfactory, and ideally UK equivalent, standards where animal feed manufacturing and feeding regimes are concerned.