How to navigate new EU food regulations
firms in the UK meet new legislative requirements.
The lobby group says that changes to the law, which came into effect this month, will affect every business involved with food.
As of 1 January 2006, 17 old regulations have been replaced by five new, far-reaching pieces of legislation and failure to comply could lead to the closure of businesses.
"As with all food regulation, it is critical businesses are fully up to speed with it," said FPB's food adviser Bob Salmon.
"These changes are significant and require business owners to fully prepare 'belt and braces' style for them."
Register with the competent authority
This, says the FPB, usually means the local council and almost all existing businesses will be registered. Companies must also tell authorities of any significant changes in activities.
In addition, firms dealing with produce of animal origin must be approved before they can start trading. Although regulation 853/2004, says that firms are not permitted to trade after 1 January 2006 without official approval, the transitional arrangements indicate that either conditional or full approval will be granted at the next scheduled visit from the Environmental Health Officer (EHO).
Composite products - combinations of vegetable and animal products such as pizzas and mayonnaise - are exempt.
Be safe
Food firms cannot use ingredients that are illegal. For example, the Sudan dyes that caused such a furore in 2005 were not necessarily dangerous, but were illegal nevertheless.
Ingredient traceability
Traceability: businesses must know where their ingredients come from, and be able to trace unsafe food to the source.
There is no obligation to have internal traceability, although the FPB points out this may be economically beneficial where stock control is critical.
Risk assessment
Businesses are required to undertake a risk assessment to ensure they are complying with microbiological criteria, temperature requirements and general hygiene good practice. Some allowances for small businesses are being proposed by the European Commission (EC).
Principles of HACCP
Food companies must have a food safety management system based on the HACCP (Hazard Analysis and Critical Control Point) principles. The EC says that traditional methods should be allowed to continue, provided they do not pose any risk to consumers.
Food makers who use a traditional method, should register this with their EHO. The rules say that a detailed hazard analysis should be carried out to ensure that the objectives of the regulation are not compromised.
This flexibility is designed to enable the continued use of such methods and to accommodate the needs of food businesses situated in regions that are subject to special geographical constraints.
Finally, all labels must be accurate, informative and free of any text that could mislead by word or implication. The FPB says that it is worth getting any labelling checked by a local trading standards officer, which, under the home authority principle, will ensure that the labelling is approved across the country.
The five new regulations in question
EC 178/2002: general principles and requirements of food law. This demands traceability.
EC 852/2004: hygiene of foodstuffs. This demands HACCP and registration.
EC 853/2004: specific rules for foods of animal origin.
EC 854/2004: official controls of foods of animal origin.
EC 882/2004: official controls to ensure verification of compliance with feed and food law.
