1. EU HYGIENIC REQUIREMENTS in BULGARIA and their IMPACT ON AGRICULTURAL PRACTICES in HIGH NATURE VALUE AREAS of HNV Seminar Village of Brashlyan, Strandzha Nature Park 26 – 27 June 2007 Stanimir Stoychev Independent Consultant STOYCHEV Consult ЕООD Emil Petrov Independent Consultant HACCP

2. STRUCTURE OF THE PRESENTATION  Overview of the Е U hygiene legislation  Overview of the harmonized BG hygiene legislation  Analysis (scenarios) of potential impact of hygiene legislation on SMALL and MEDIUM- SIZE agricultural producers and processors in High Nature Value (HNV) areas  Conclusions  Recommendations

3. THE QUESTION IS...  Can traditional practices of milk and meat production and processing in HNV areas be preserved observing existing increased hygienic requirements in accordance with the national legislation ?

4. Overview of the EU hygiene legislation  Regulation (EC) 852/2004 laying down common rules on food producing enterprises concerning foodstuffs hygiene  Regulation (EC) 853/2004 laying down specific hygiene rules on food of animal origin Concerning buildings and equipment Concerning indicators for TNM and TNSCs

5. Overview of EU hygiene legislation 3. This regulation 853/2004/ЕС shall not apply to: a) primary production intended for private home use; b) home preparation, handling or storage of food for private home consumption ; c) the direct supply, delivered by the producer, of small quantities of primary products to the end consumer or to local retail establishments directly supplying the end consumer ; d) the direct supply, delivered by the producer, of small quantities of meat from poultry and lagomorphs slaughtered on the farm to the enf consumer or to local retail establishments directly supplying such meat to the enf consumer as fresh meat; (e) hunters who supply small quantities of wild game or wild game meat directly to the end consumer or to local retail establishments directly supplying the end consumer. 4. Member States shall establish, according to national law, rules governing the activities and persons referred to in paragraph 3 (c), (d) and (e). Such national rules shall ensure the achievement of the objectives of this Regulation..

6. Overview of the harmonised BG hygiene legislation (1)  Strategy for the development of milk animal-breeding and improvement of the quality of raw cow’s milk for the period 2006- 2009  Law on the support of agricultural producers  Law on the veterinary activities  Law on foods  Law on fodder  Law on animal-breeding  Regulation No.44/20.04.2006 on the veterinary requirements concerning animal-breeding sites  Regulation No.51/20.04.2006 concerning the national reserve, individual milk quotas, approval of buyers and the buying up of cow’s milk  Regulation No.61/09.05.2006 concerning the conditions and order for identification of animals, registration of animal-breeding sites and access to the database of the identified animals  (draft) REGULATION CONCERNING THE SPECIFIC REQUIREMENTS of THE PRODUCTION, STORAGE AND TRANSPORTATION OF RAW COW’S MILK AND THE REQUIREMENTS FOR THE TRADE AND PLACEMENT ON THE MARKET OF DIARY PRODUCTS

7. Overview of the harmonised BG hygiene legislation (2)  Good Manufacturing Practices (GMP) for buying out and processing of raw cow’s milk  Conditions for maintaining the land in good agricultural and environmental condition (Good Agricultural and Environmental practices)

8. EXAMPLES of the REQUIREMENTS under Regulation 44  Up to 2009, a farm must meet the following requirements : To have separate premises for animals of different technological groups conforming to the requirements relating to the parameters of the living environment To have production equipment and premises for storage of milk until its delivery for processing which shall comply with the veterinary-sanitary and hygiene requirements relating to milk production To ensure adequate conditions for veterinary care and stationary treatment of the animals To have isolated maternity boxes or to create a delivery premise To ensure conditions for movements of the animals To possess premises and grounds for open-air breeding of calves complying with the regulations related to the protection and humane treatment during calf-breeding To keep and handle waste in a manner preventing environmental contamination.

9. OBJECTIONS to Regulation 44  This regulation should only apply to large animal-breeding complexes  This regulation provides no requirements related to the pastures and meadows needed for ruminant animals (cattle and sheep)  This regulation does not apply to traditional animal-breeding practices, e.g. breeding sheep herds in movable pens (sheepfolds) on harvested fields  The requirements related to summer mountain animal camps are not addressed  Mountainous breeding of calves and weaned lambs are not addressed  This regulation describes “bookish” norms for animal- breeding but it has been forgotten that norms depend on the applied breeding technology  This regulation should provide conditions for the development of not only “large” but “small” farms, as well

10. EU Legislation  Presents complicated requirements within large limits  Makes possible interpretations  Implementation of these large requirements into practice is not accompanied by concrete requirements and model implementation scenarios  No clear relation of EU hygienic requirements with the EU policy relating to rural development exists  Presents very well translated hygiene requirements contained in EU regulations with increased and ambitious objectives  Limited transitional period for implementations  Poorly presented to farmers and limited transparency relating to specific requirements  Diverse interpretation on local level  Improperly trained officials for the control of hygienic requirements  Lack of clarity with respect to direct sale practices BG Legislation

11. SITUATION OF ANIMAL-BREEDING IN THE DAIRY SECTOR (intensive regions)  Plovdiv Region: 30 registered milk buyers  Farms of group 1 129 farms with 7,696 dairy cows Average herd size: 60 cows Varying from 11 to 792 cows  Farms of group 2 112 farms with 2,707 dairy cows Average herd size: 24 cows Varying from 5 to 78 cows  Sliven Region: 18 registered milk buyers  Farms of group 1 72 farms with 4,180 dairy cows Average herd size: 58 cows Varying from 11 to 550 cows  Farms of group 2 59 farms с 1,115 dairy cows Average herd size: 19 cows Varying from 6 to 70 cows

12. SITUATION OF ANIMAL-BREEDING IN THE DAIRY SECTOR (areas of HNV)  Bourgas Region: 7 registered milk buyers  Farms of group 1 38 farms with 2,131 dairy cows Average herd size: 56 cows Varying from 11 to 296 cows  Farms of group 2 35 farms with 640 dairy cows Average herd size: 18 cows Varying from 4 to 146 cows  Smolyan Region: 12 registered milk buyers  Farms of group 1 59 farms with 667 dairy cows Average herd size:– 11 cows Varying from 5 to 79 cows  Farms of group 2 25 farms with 303 dairy cows Average herd size:– 12 cows Varying from 5 to 75 cows

13. EXAMPLES of the REQUIREMENTS of REGULATION 853/2004 CATEGORY Milk farm Transition al period TNMTNSCBUILDINGS Group I up to 100,000/ml up to 400,000/ml Requirements met Group II Start 2008 End 2009 from 300,000/ml up to 100,000/ml up to 400,000/ml Requirements met Up to end 2007 from 500,000/ml up to 300,000/ml от 500,000/ml Up to 400,000/ml Group III Up to end 2007 up to 500,000/ml Requirements not met

14. SITUATION OF ANIMAL-BREEDING IN THE DAIRY SECTOR– as of 1 June 2007 INDICES CATEGORY Group 1Group 2Group 3 Number of farms1,1451,353 ? Number of diary cows47,97028,779 Average number per farm4221 Total number of dairy cows as of 2005: 350,000 Total number of milk producers with quotas for shipment and direct sale: 96,572

15. CONCLUSIONS  Greatest impact have the requirements concerning milk hygiene and the requirements concerning buildings  Lack of clarity on how direct sales have to be carried out  Lack of clarity with respect to milk processing at farm level  Lack of nationally represented organisation for protection of small and medium-size milk processors  Existing conflict of the legislation regulating cow’s milk producers organisations

16. RECOMMENDATIONS  Introducing amendments in BG legislation correcting 2 things: Milk processing on “farm” level practicing “direct sales”  Establishing a national organisation of “small” milk processors processing on “farm” level and applying direct sales  Establishment of milk producers groups on regional principle practicing traditional methods of agriculture who will be able to apply for support of up to EUR 3,000 for the production of traditional products under the RDP (2007–2013)