Laying down the general principles and requirements of food law, regulation (EC) 178/2002 established a raft of procedures in matters of food safety, including the establishment of Europe's first food safety agency.
Enforced in January, general food law requirements are traceability of food and feed products, responsibility of operators, withdrawal of unsafe food or feed from the market and notification to competent authorities.
"Their implementation has given rise to numerous questions in particular from EU food chain operators and third country trading partners," says the Commission this week.
In a bid to guide the food industry through the labyrinth of rules, a group of scientists under the aegis of the Commission have created a document to communicate how the new traceability rules should be implemented.
Key areas addressed in the document are: responsibilities (Article 17); traceability (Article 18); withdrawal, recall and notification for food and feed (Articles 19 and 20) in relation to food and feed safety requirements (Articles 14 and 15); imports and exports.
Testing the traceability efficacy of food firms operating in the UK, the discovery of the potential carcinogen sudan 1 in hundreds of processed foods on the shelves triggered a massive recall.
Sudan 1 to IV are classified as carcinogens by the International Agency for Research on Cancer and are banned under European Union rules imposed in July 2003.
The red dye had been detected in chilli powder used to make Worcester sauce. The sauce, made by UK firm Premier Foods, is used as both an ingredient in processed products, as well as a tabletop product.
Rattling through the UK chain, the discovery prompted the UK's Food Standards Agency to pull all related products, such as Sainsburys pork sausages and Tesco's chicken and vegetable casserole, out of consumer reach. Costing millions of euros, the total number of affected products is now about 580, and still rising.
A UK delegate told the Commission last week that the contaminated chilli had been imported in 2002 from India.
Highlighting the role of traceability, the UK delegate said he believed the entire imported batch had been used. Unconfirmed reports in various press suggest that five tons of the imported consignment were eventually sold in September 2002 to the flavourings firm Unbar Rothon in Billericay, Essex: Premier Foods is believed to have bought the Unbar Rothon batch. The rest appears to have been sold to other food companies.
"Lessons for the industry will have to be drawn with respect to the implementation of the fundamental principles of the food law - primary responsibility of food business operators, application of HACCP" the EU working group on contaminants concluded after a meeting last week.
But recently speaking with FoodNavigator.com, the UK's food industry body, the Food and Drink Federation, said: "The speed at which this ingredient has been traced shows the efficiency of the system."
Looking into how the contamination leaked into the food chain, Premier Foods said that it had certificates from its suppliers that guaranteed the chilli used was free of sudan 1.
If this is the case, contamination occurred because the processors used old stocks that pre-date the EU emergency measures.
Premier Foods confirmed to FoodNavigator.com that the stocks were brought in before July 2003.