Report on the Implementation of the derogation to ... - Trade Websites

Final <strong>Report</strong>
RoO Derogation under the PACP-IEPA
In the case of processing plants, Regulations (EC) 853/2004 and 854/2004 need to be followed with
respect to microbial criteria, temperature control, cold chain compliance, sampling and analysis, and
hygiene controls, in addition to the application of HACCP measures.
A traceability system from capture to packing, in accordance with Regulation (EC) 178/2002 also
needs to be in place. In PNG, this is provided for in the PNG SFFP 2009. SPS traceability looks at the
hygiene and temperature controls from vessels to plant, and includes special product coding of fish
from landing to final destination. This allows tracing to product origin if there is a complaint (e.g. DG
SANCO Rapid Alert System for Food and Feed (RASFF) notifications). Traceability along the chain of
custody can be evaluated by logbooks, the Freezer Vessel Fish Origin Declaration Form (FVFODF),
transhipment forms, observer data, port sampling forms, export documentation and VMS reports.
Validated catch certificates (CCs) and Processed Statements (Annex 4) for year 2010 are filed
electronically in NFA headquarters in Port Moresby, but from 2011 are filed in respective port
offices.
Landing sites and cold storage are also subject to EU SPS regulations.
In March 2007, the EU Food and Veterinary Office (FVO) carried out an inspection/audit of the PNG
CA (i.e. NFA) system. 224 At that time, 6 plants and 41 freezer vessels (including some Vanuatu flag
vessels) were on the list of establishments authorized to export to the EU. The FVO reported
numerous deficiencies in CA activities and authorized establishments. A follow-up FVO mission in
February 2008 assessed what corrective action had been taken by the CA, according to PNG’s
remedial action plan lodged following the 2007 FVO inspection and audit. 225 With some problems
persisting, the CA was then required to de-list two of the three tuna processors (RD Tuna Canners
and SSTC). Some fishing vessels were also removed from the list, as EU indicated Vanuatu vessels do
not meet the EU rules because of the flagging arrangements and should not be DG SANCO listed by
PNG, but rather the flag state, which in this case does not have CA status.
Following the de-listing of RD Tuna Canners, exports of canned tuna to the EU almost halved during
2008, and had not fully recovered by the end of 2009. After adequately addressing various SPS
compliance issues, RD Tuna Canners was re-listed in mid-2009, and SSTC in April 2010. By 2010,
export volumes to the EU returned to levels prior to the de-listing of the plant.
Assistance was provided to the CA in January-February 2009 under the FFA Export, Inspection and
226
Certification Project. The consultant reported that, with implementation of a new regulatory
verification system, the ACU was well placed to strengthen official controls over the industry and to
comply with EU export requirements, but there was a need to strengthen HACCP application and
verification, and to improve the current MoU with the Philippines CA.
There is no FVO inspection for PNG scheduled for 2011, nor is one confirmed for 2012 at this
point.
227 There appear to have been no potential triggers for scheduling an FVO inspection, such as a
marked increase in the number of rapid alerts but this is worth closer examination. Table 5.6 lists,
for the period 2006 to 30/9/2011, the number of fish and fish product (FP) rapid alerts listed DG
SANCO’s Rapid Alert System for Food and Feed (RASSF) portal for a range of countries with tuna
processing plants, focusing on canned and frozen cooked loins (HS 1604 products). 228 Several
countries have had no alerts posted during this time, despite considerable quantities of canned tuna
224 DG SANCO 2007.
225 DG SANCO 2008.
226 da Silva 2009.
227 Interview, DG SANCO representative, Brussels, July 2011.
228 RASSF 2011; https://webgate.ec.europa.eu/rasff-window/portal
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