The overall risk to food safety has not increased as a result of the United Kingdom leaving the European Union, according to the Food Standards Agency (FSA).

The authority officials also said the agency has not seen any evidence to suggest there is more of a risk from food crime or food fraud.

However, the revised timetable for introducing import controls could reduce the FSA’s ability to trace such consignments and control problem products at the border. Currently, the EU is doing checks on UK meat and fish exports but the UK is not looking at these EU imports.

Issues with delay
A six month delay to pre-notification for high-risk food and feed from EU countries means issues may not be picked up at the border and will have to be addressed further along the food chain, said FSA.

While the agency believes any further delays will present “challenges”, the regulator added it allows more time to support trader readiness and compliance with new import requirements.

Beginning in October 2021 pre-notification requirements will be needed for products of animal origin such as honey, meat and milk products, high risk food not of animal origin (HRFNAO) and certain animal by-products entering the UK from the EU. Health certificates will also be required for items of animal origin and certain animal by-products.

Beginning in January 2022, physical checks for products of animal origin, certain animal by-products, HRFNAO and high risk plants will take place at border control posts. Pre-notification requirements and documentary checks, including phytosanitary certificates, will be introduced for low risk plants and plant products. Beginning in March, checks at border control posts will occur on live animals, low risk plants and plant products.

Now the FSA has lost full access to the Rapid Alert System for Food and Feed (RASFF), it wants to introduce pre-notification for all imported high-risk food and feed, not just that from non-EU countries. This allows identification of what commodities are entering Great Britain and their destination in the UK as well as helping with tracing the product back to its source.

Trichinella, ink and shellfish
Comments were made in written evidence submitted to the Committee on Environment Food and Rural Affairs as part of an inquiry into seafood and meat exports to the EU.

There was a positive vote on the UK’s application to the European Commission in February to remove the requirement for Trichinella testing on all non-frozen pork products certified as coming from controlled housing conditions. This regulation will be implemented on April 21, according to the Department for Environment, Food and Rural Affairs (Defra).

The EU is also not allowing import of live bivalve mollusks from class B waters for purification. Production areas are classified as A, B or C, with A as the least and C as the most contaminated.

One issue was certain border control posts requesting export health certificates (EHCs) were signed and stamped in a particular color of ink. There is no requirement for a certain color to be used but it has to differ from that on the printed certificate.

The Chartered Institute of Environmental Health, Association of Independent Meat Suppliers, National Farmers Union, British Poultry Council and British Meat Processors Association are among more than 30 groups to have submitted written evidence to the inquiry.

Food crime and a risk-based approach
The committee also held three oral evidence sessions. Speaking at one of these meetings in mid-March, Gary McFarlane, CIEH director in Northern Ireland, said that food crime is still a risk.

“Not all those risks necessarily pose public health risks, but many of them potentially could, particularly when we get into areas such as allergic reactions and mislabeling of products. The short answer, in my professional view, is that, yes, there are risks to public health from delaying the introduction of checks,” he said.

“It is not the vast majority of diligent operators and legitimate food businesses that we need to be concerned about here. It is those who will set out to thwart the controls and the checks that the system puts in place.”

Speaking at another session later in March, environment secretary George Eustice said the European Union is not looking at risk and only at its rulebook.

“Put bluntly, the checks the EU is carrying out on British exports are entirely futile. The products we have now are as safe as they were three months ago, when they were able to travel without any paperwork. We have chosen to recognize that and be pragmatic in the way we have phased in checks. The EU has not really approached this on a risk-based approach. Goods coming from the EU fundamentally do not pose any more threat today than they did three months ago. For that reason, we do not think there is a risk to public health.”

Eustice said the UK can have a more-risk based approach to border checks now it is out of the EU.

“Rather than just having percentages of checks that are prescribed in law, which is what the EU system is, we can have a much more dynamic approach where you identify emerging risks in real time and focus your energies to try to intercept particular problems from wherever they might come in the world,” he said.

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