1. Honey and Traceability P-142/2005/Traceability©QSI 2005 1 Honey and Traceability

2. P-142/2005/Traceability©QSI 2005 2 Content Background Legal Requirements –EC-Regulation No. 178/2002 –Reasons for Traceability –Scope of Traceability –Covered Products –Covered Operators –Applicability to Third Countries –Implementation of Traceability Limits of Traceability Systems and Procedures of Traceability Traceability in Honey Trade, Labelling and Documentation at –Beekeeper level –Co-operation level –Exporter/importer companies –Packing/bottling companies –Food industry –Trade, supermarket level Measures of Traceability in Honey Control Traceability in Organic Honey Production Traceability of Measurements Traceability in QM-Documentation

3. Honey and Traceability P-142/2005/Traceability©QSI 2005 3 Background Recent food scares (BSE and dioxin crisis) have demonstrated that the identification of the origin of food and feed is of prime importance for the protection of consumers. The functioning of the international market in food or feed can be at risk where it is impossible to trace food and feed. Motivation for the implementation of traceability procedures therefore are mainly based on economic and corporate policy necessities as well as on the creation of reliance.

4. Honey and Traceability P-142/2005/Traceability©QSI 2005 4 Traceability Traceability means the ability to trace and follow a food, feed, food- producing animal or substance intended to be, or expected to be incorporated into a food or feed, through all stage of production, processing and distribution.

5. Honey and Traceability P-142/2005/Traceability©QSI 2005 5 Legal Requirements

6. Honey and Traceability P-142/2005/Traceability©QSI 2005 6 Regulation (EC) No 178/2002 of 28. January 2002 laying down the general principles and requirements of food law, establishing the European Food safety Authority and laying down procedures in matters of food safety - “ from farm to folk” - Its objective is to establish common definitions and to lay down overarching guiding principles and legitimative objectives for food law in order to ensure a high level of health protection and the effective functioning of the internal market.

7. Honey and Traceability P-142/2005/Traceability©QSI 2005 7 Article 18 Traceability 1. The traceability of food, feed, food-producing animals, and other substances intended to be, or expected to be, incorporated into a food or feed shall be established at all stages of production, processing and distribution. 2. Food and feed business operators shall be able to identify any person from whom they have been supplied with a food, a feed, a food-producing animal, or any substance intended to be, or expected to be, incorporated into a food or feed. To this end such operators shall have in place systems and procedures which allow for this information to be made available to the competent authorities on demand...

8. Honey and Traceability P-142/2005/Traceability©QSI 2005 8 Article 18 Traceability, cont. 3. Food and feed business operators shall have in place systems and procedures to identify the other business to which their products have been supplied. This information shall be made available to the competent authorities on demand. 4. Food or feed which is placed on the market or is likely to be placed on the market in the Community shall be adequately labelled or identified to facilitate its traceability, through relevant documentation or information in accordance with the relevant requirements of more specific provisions. 5. Provisions for the purpose of applying the requirements of this Article in respect of specific sectors may be adopted in accordance with the procedures laid down in Article 58(2).

9. Honey and Traceability P-142/2005/Traceability©QSI 2005 9 Article 18 Traceability Is legal duty since 01.01.2005 Implies that business operators are legally obligated to assure traceability. By this Regulation, general traceabilty has been fixed for the first time as obligating requirement in the food law. The Regulation introduces the traceability requirement with in particular the objective to ensure food safety and to assist in enabling unsafe food/feed to be removed from the market

10. Honey and Traceability P-142/2005/Traceability©QSI 2005 10 Reasons for Traceability Objectives of traceability food safety fair trading between operators reliability of the information provided to consumers.

11. Honey and Traceability P-142/2005/Traceability©QSI 2005 11 Reasons for Traceability Traceability is meant to ensure that a food or feed business including an importer can identify at least the business from which the food.....has been supplied targeted and accurate withdrawals or recalls can be undertaken appropriate information can be given to consumers and food business operators concerning implicated products risk assessment can be performed by control authorities unnecessary wider disruption of trade can be avoided.

12. Honey and Traceability P-142/2005/Traceability©QSI 2005 12 Reasons for Traceability Traceability does not itself make food sure, but establishes the transparency needed for efficient control measures. is a risk management tool to be used in order to assist in containing a food safety problem.

13. Honey and Traceability P-142/2005/Traceability©QSI 2005 13 Scope of Traceability Article 18 creates a new general obligation for food business operators Article 18 is worded in terms of its goal and intended results, rather than in terms of describing how that result is to be achieved

14. Honey and Traceability P-142/2005/Traceability©QSI 2005 14 Scope of Traceability Food business operators has to be able to identify the immediate supplier(s) of their products - „one step up“ to be able to identify the immediate customer(s) of their products - „one step down“ to have systems and procedures in place that allow for this information to be made available to the competent Authorities upon their request „Supplier - product“ and „customer - product“ links shall be established Exception: The final customer has not to be identified.

15. Honey and Traceability P-142/2005/Traceability©QSI 2005 15 Covered Products All products of the food chain! Covered substances are those intended or expected to be incorporated, as a part of a food/feed during its manufacture, preparation or treatment. That means for honey: from the bee to bottle, also: pollen, gelee royal, propolis, comb honey…. For example: food producing animals (bees), raw material (e.g. raw honey, cereals, fruits, vegetable), additives, semi-products (e.g. peeled potatoes), all types of food/feed ingredients, additives irrespectively of the amount used

16. Honey and Traceability P-142/2005/Traceability©QSI 2005 16 Covered Products Not covered are: e.g. grain when used as seed for cultivation packaging material traceability of food packaging material is covered by regulation EC/1935/2004 of 27. October 2004 veterinary medicinal products, plant protection products, fertilisers from 1 st of January 2006 covered by the new food hygiene Regulation EC/852/2004 and the forthcoming feed hygiene Regulation forming a link between food/feed and veterinary medicinal and plant protection products, since farmers will have to keep and retain records on these products

17. Honey and Traceability P-142/2005/Traceability©QSI 2005 17 Covered Operators The Regulation applies to food business operators at all stages of the food chain, from primary production (food producing animal, harvests), food/feed processing to distribution. Food business operators are: „any business/company/...,carrying out any of the activities related to any stage of production, processing and distribution of food/feed“ That means for honey: beekeepers,…, any honey processing enterprise/organisation, ex-, importers, packers, traders Transporters and storage operators, involved in the distribution of food/feed, are covered as well

18. Honey and Traceability P-142/2005/Traceability©QSI 2005 18 Applicability to Third Countries The traceability provisions do not have an extra-territorial effect outside the EU. However all stage of production, processing and distribution in the EU - from the importer up to the retail level. Food/feed imported into the EU only has to comply with the relevant requirements of EU food law, e.g. Directive 2001/110/EC relating to honey. But, it is common practice among some EU food business operators to request trading partners by contractual arrangements to meet the traceability requirements.

19. Honey and Traceability P-142/2005/Traceability©QSI 2005 19 Implemetation of Traceability A. Identification of suppliers and customers by food business operators –A food business operator should be able to identify any person from whom it received its food/raw material. This could be an individual (hunter, beekeeper, mushroom collector..) or a legal person (e.g.honey co-operation). –Supplier does not mean the name of the person who physical delivered (e.g. truck driver ) but the company/operator –A food business operator must identify only the other business (legal entity). This also includes e.g. a distributor or restaurant.

20. Honey and Traceability P-142/2005/Traceability©QSI 2005 20 Implemetation of Traceability B.Internal traceability The Regulation does not contain a regulatory requirement for process (internal) traceability, but a certain level of internal tracebaility should be put in place by food operators due to Recital 28: „ It is necessary to establish a comprehensive system of tracebaility within food and feed business is put in place so that targeted and accurate withdrawals can be under taken...avoiding the potential for unnecessary disruption in the event of food safety problems“ An internal tracebility system will benefit the operator by contributing to more targeted and accurate withdrawals

21. Honey and Traceability P-142/2005/Traceability©QSI 2005 21 Implemetation of Traceability C. Types of information to be kept According to the level of priority the information is classified in 2 categories: 1. Category- any information which shall be made available to the competent Authorities –Name, address of supplier, nature of products supplied from him –Name, address of customer, nature of products delivered to that customer –Date of transaction/delivery

22. Honey and Traceability P-142/2005/Traceability©QSI 2005 22 Implemetation of Traceability 2. Category - additional information highly recommended to be kept: –Volume or quantity –Batch number, if any –More detailed description of the product (pre-packed of bulk product, variety of fruit/vegetable/honey..., raw or processed product It is essential that the traceability system is designed to follow the physical flow of the products  the use of delivery notes (or registration of address of producing units) ensures more efficient traceability

23. Honey and Traceability P-142/2005/Traceability©QSI 2005 23 Implemetation of Traceability D. Time of reaction for traceability data available The most crucial point is the time needed to deliver fast and accurate information.The faster the data are available the faster a prompt reaction in case of crisis is possible. Information of the 1. Category shall be immediately available to the competent Authorities Information of the 2. Category shall be available as soon as practicable - within deadline appropriate to circumstances Pre-setting of time limits is not possible since each situation is different with respect to processes, products and persons involved.

24. Honey and Traceability P-142/2005/Traceability©QSI 2005 24 Implemetation of Traceability E: Time of records keeping Fixed time frame is not set in Art. 18, but the following recommendation is given: Generally for all products - 5 years from date of manufacturing or delivery For products without a specified shelf life - 5 years For products with a shelf life above 5 years - the period of the shelf life + 6 month For highly perishable products with a „use by“ date less than 3 month or without a specified date - 6 month after the date of manufacturing or delivery

25. Honey and Traceability P-142/2005/Traceability©QSI 2005 25 Additional Policy and Procedures E.g. for Organic products (EC/2092/91) Lot identification (Directive 89/396) Specific traceability requirements for GM Food and Feed and products produced from GMO (gen-modified organism) (Regulation No. 1830/2003) Beef labelling (EC/1760/2000) partly the procedures are exactly described, partly only general advises are given

26. Honey and Traceability P-142/2005/Traceability©QSI 2005 26 Limits of Traceability Technology and procedures in continuous procedures an exact differentiation of delivers may not be possible Raw material and status of processing the higher the rate of processing or distribution the more complicate is the traceability back to the raw material sources Infrastructure the kind of trading - regional, national or world-wide, in collecting points, intermediate storage etc. can constrain the possibilities of traceability (step up)

27. Honey and Traceability P-142/2005/Traceability©QSI 2005 27 Systems and Procedures of Traceabilty Creation of organisational requirements to connect information relevant to the product with defined product units: –Determination of a reference unit - e.g. a delivery, daily production, production amount –Determination of relevant data - supplier, delivery date, delivery amount, customer... –Determination of labelling (Code) - lot, production date, barcode...

28. Honey and Traceability P-142/2005/Traceability©QSI 2005 28 Systems and Procedures of Traceability But operators are not required by law to invest in sophisticated IT systems. A paper-based system for managing delivery/procurement documents and customers invoices may be adequate However, where large amounts of data are involved, relevant IT systems will be indispensable.

29. Honey and Traceability P-142/2005/Traceability©QSI 2005 29 Charge Coding Systems A „charge“ means a production unit A“lot“ means a batch of sales units of a foodstuff produced, manufactured or packaged under practically the same conditions Mostly, both terms are used synonymous

30. Honey and Traceability P-142/2005/Traceability©QSI 2005 30 Charge Coding Systems Clearness coding has to be short and incisive (has to be noted several times within the process) Understandable and readable the use should readily recognise which data are coded Explanatory power recommended is a max. amount of a daily production Possibilities of mistakes it has to be assured that a mixing-up with other data/numbers is excluded Secrecy it should be avoided that from a lot number conclusion to suppliers is possible to outstanding persons

31. Honey and Traceability P-142/2005/Traceability©QSI 2005 31 Charge Coding Systems Coding of date (e.g. production date) example: C241-03 means: the charge was produced the 241. day in 2003 A-0B-C means: 02. (0B) January (A) 2003 (C) Continuous numbers Individual systems e.g. country codes, recipe codes

32. Honey and Traceability P-142/2005/Traceability©QSI 2005 32 Charge Coding Systems, cont. Bar codes (e.g. EAN- Codes - European Article Number) EAN 128-code: international standard, available are 128 digits to code charge numbers, type and amount of the product, best before date and the international harmonized trade number EAN 13-code: mainly used code in food trade Bar code are the basis for the application of scanners UPC (Universal Product Code) US-norm code comparable to the EAN code Chemical marks e.g. ISO-ID, developed by ‘agroisolab GmbH, Germany’ used to verify origin data

33. Honey and Traceability P-142/2005/Traceability©QSI 2005 33 ISO-ID Principle ISO-ID is based on the fact that all biomass posses a natural, isotopic fingerprint which can not be changed by chemical methods. The ISO-ID system uses water as marker substance. By isotope analysis this water together with the natural isotopes is analysed. Features Marking of semi-products for recovering in the final product Marking of final products to prevent unwarranted origin reclamation's Marking of final products to identify plagiaries Marking of raw material for recovering in the final product (e.g. additives in foodstuff)

34. Honey and Traceability P-142/2005/Traceability©QSI 2005 34 Example: Possible Structure of Lot-Numbers Honey Lot 10 03 04 0 008 ID-Number year 2000 Sub group Kind of good Raw material group

35. Honey and Traceability P-142/2005/Traceability©QSI 2005 35 Example: EAN 13 code Country codeProducer/ Manufacturer Article Number Check digit The first 7 digits build the ‚basis-number‘ which is centrally assigned.

36. Honey and Traceability P-142/2005/Traceability©QSI 2005 36 Techniques of Coding Manually easy, but time-consuming and only limited flexible Ink-Jet Systems Standard in industrial food production applicable to all font types and EAN-Codes Thermotransfer printer high resolution, expensive