FSA Consultation Letter, 2 November 2006
The Agency is seeking views and comments on new draft FSA Guidance Notes on Article 14-16 and 18-20 of the General Food Law Regulation (EC) 178/2002 Responses are requested by: 26 January 2007
New draft Food Standards Agency (FSA) Guidance Notes on Articles 14-16 and 18-20 of the General Food Law Regulation (EC) 178/2002 have been developed.
The notes provide advice on compliance with legal requirements covering food and feed safety, traceability provisions and the need to notify, withdraw and/or recall products not conforming with the food and feed safety requirements applying under the Regulation.
These new Guidance Notes have been written to address responses to the public consultation exercise on the EC Guidance for the Regulation, held between July and October 2005.
The purpose of this consultation is to obtain views on:
Articles 14-16 and 18-20 of the General Food Regulation (EC) 178/2002 cover food and feed safety, traceability and the need to notify, withdraw and/or recall products not conforming with the food and feed safety requirements applying under the Regulation.
Agency Guidance Notes on the legislative requirements were issued on 31 December 2004. The EC Guidance was issued on 20 January 2005. The Agency Guidance was subsequently revised to take account of the EC Guidance and reissued on 10 March.
The Agency consulted in July 2005 on how well the EC Guidance had been working to inform a review of the Guidance by the European Commission. The reaction from business was that the EC Guidance was resulting in disproportionate costs to the food industry. The EC Guidance classifies traceability information in two categories, the first to meet the legal requirements and the second to be followed as best practice. Responses from food businesses to the consultation exercise indicated that following such best practice guidance could result in additional costs.
The Agency has reviewed the results of this consultation and has redrafted the FSA Guidance Notes, which now focus primarily on the legal requirements.
The principal changes in the new FSA Guidance Notes compared with the EC Guidance are:
The Agency view is that these new FSA Guidance Notes are more appropriate for food businesses in the UK. This approach has been discussed with the European Commission.
Comments on any aspect of the FSA Guidance Notes are welcome. We would particularly welcome comments on the partial Regulatory Impact Assessment, which seeks to identify key issues and potential costs. In particular we would welcome your views on whether the focus on the requirements of legislation rather than best practice is more helpful to businesses and if this will remove the additional administrative costs businesses thought were contained in the EC Guidance. We would also welcome views on whether there is a need for any additional guidance.
Links to documents on this site: