Beruflich Dokumente
Kultur Dokumente
in the region
Big
Picture
• The
requirement
has
been
going
for
over
3
years
• It
has
been
demonised
and
sanc9fied
with
not
much
background
research
so
far.
• Last
week
the
EU
parliament
released
officially
an
independent
study
(250
pages)
they
have
commissioned,
on
the
effec9veness
of
compliance
of
fishery
imports
to
EU
legisla9on
(both
Health
and
IUU
CCS)
Big
Picture
• The
parliament
has
much
more
“teeth”
since
the
Lisbon
Treaty
• The
report
has
provided:
• 11
recommenda1on
to
DG
SANCO
in
regards
the
Health
Cer1fica1on
side
• 23
to
DG
MARE
in
regard
the
EU
CCS
side
• It
is
brutally
cri9cal
of
DG
MARE’s
lack
of
transparency
and
collabora9on
(with
everyone!)
• Not
only
in
regards
the
decisions
afflic9ng
3rd
countries,
but
in
regards
their
handling
of
EU
Member
Countries
non
compliances
Big
Picture
• The
study
is
very
well
researched
and
documented.
• The
situa9on
in
the
Pacific
are
men9on
in
various
points
stages
(in
a
very
unbiased
manner)
• ...The
decisions
of
the
European
Commission
to
prohibit
imports
from
a
third
country
based
on
ar<cle
53
of
Regula<on
No
178/2002
some<mes
seems
arbitrary,
the
case
of
Fiji
delis/ng
in
2008
being
an
example.
• ...
On
April
2013
several
no<fica<ons
were
s<ll
pending,
par/cularly
for
Pacific
Island
States.
According
to
the
wording
of
the
EU
IUU
Regula<on
it
would
seem
that
the
acceptance
of
the
no<fica<on
is
automa<c
and
cannot
be
refused
if
the
informa<on
requested
in
Ar<cle
20
is
provided.
It
is
not
very
clear
on
which
grounds
the
EC
is
currently
basing
the
acceptance
or
not
of
the
no<fica<on.
This
whole
procedure
lacks
transparency....
• ...In
the
Pacific
overall,
the
situa/on
has
greatly
improved
thanks
to
regional
coopera/on
through
the
Fisheries
Forum
Agency,
the
Nauru
Agreement
for
purse
seine
fisheries,
the
Niue
Treaty
on
coopera<on
in
MCS
and
others,
and
observer
programmes
under
the
auspices
of
the
WCPFC...
Where
we
are
at?
• The
report
explain
quite
well
how
“tuna
laundering”
works
120
t
40
t
40
t 40
t
Here
IUU
fish
could
be
introduced
into
the
system
as
the
full
weight
of
fish
could
be
sold
to
the
factory
by
the
broker
or
the
120
t 120
t 120
t
factory
could
introduce
uncer1fied
fish
and
process
it
under
the
excess
on
the
80
t 80
t
copy
cer1ficate
received.
80
t
Pacific
Island
Caught
Foreign
Caught
were not found. Name & Number of Vessel for the catch
consump<on.
Suggested
Procedures
Maximum
Levels
of
Contaminants
Parameter'! Product'! Chinese'legislation'! EU'legislation'!
0.5!mg/kg!! 0.3!mg/Kg!fish!
Lead!! Fish!! 1.0!mg/kg!Mollusks!&!! 1!mg/Kg!cephalopods!!
cephalopods! 1.5!mg/Kg!Mollusks!!
!0.050!mg/Kg!Most!fish!!
0.1!mg/Kg!Tunas,!mackerels,!
sardines!!
0.1!mg/Kg!! 0.2!mg/Kg!bullet!tuna!!
Cadmium!!! Fish!!
0.2!mg/Kg!!(canned!fish)! 0.30!mg/Kg!anchovy,!swordfish!!
0.50!mg/Kg!crustaceans!!
1.0!mg/Kg!mollusk!and!
cephalopods!!
1!mg/kg!(Predatory!fish)!!! 1!ppm!for!tuna!and!swordfish!!
Mercury! Fish!
0.5!mg/kg(!non!predatory)! 0.5!ppm!for!most!other!fish!
Iron!! Preserved!products!! 70!mg/Kg!! Not!regulated!
Copper!! Aquatic!products!! 50!mg/Kg!! 60!mg/kg!(oysters)!!
Zinc!! Fish!! 50!mg/Kg!! Not!regulated!
Tin!! Canned!foods! 50!mg/Kg!! 200!mg/Kg!!!
Chromium!! Fish!and!crustaceans! 2.0!mg/Kg!! Not!regulated!
Selenium!! Fish!! 1.0!mg/Kg!! Not!regulated!
0.5!mg/Kg!(live!weight)!!
Inorganic!Arsenic!! Fish!and!crustaceans! Not!regulated!!
1.0!mg/Kg!(dry!weight)!!
Fluor!! Fresh!water!fish!! 2.0!mg/Kg!! Not!regulated!
Suggested
Procedures
Exporter/Trader
RegistraGon
• While
in
force
since
the
1
October
2012,
this
requirement
has
been
slowly
enforced.
It
requires
all
exporters/traders
of
food
products,
including
seafood,
to
China
to
be
registered.
• This
registra1on
is
purely
administra1ve
and
does
not
require
the
exporter/trader
to
nominate
the
source
manufacturing
premises
or
vessels
• Exporter/trade
registra1on
is
conducted
through
an
on-‐line
system
which
is
available
at:
hSp://ire.eciq.cn
Recommenda1ons
For
CAs
• Given
there
does
not
appear
to
be
a
published
process
explaining
how
an
expor1ng
country
requests
authorised
status,
it
is
advisable
that
the
CA
follows
the
procedure
described
under
Registra<on
of
Country
and
Premises
of
the
FFA
brief,
and
by
default
register
themselves
as
a
“authorised”
country.
• CAs
should
follow
the
specific
health
requirements
as
presented
in
Maximum
Levels
of
Contaminants
in
Food
from
the
FFA
brief.
• It
is
up
to
individual
CAs
to
determine
how
they
intend
to
verify
seafood
exports
are
within
the
prescribed
limits.
The
simplest
path
is
to
asks
exporters
to
supply
proof.
• For
cer1fica1on,
use
the
official
model
provided
with
your
CA
details
on
it.
Recommenda1ons
For
CAs
• In
regards
the
emission
of
official
cer1ficates
for
products
landed
in
your
country
by
foreign
vessels
not
under
your
control:
• In
theory,
the
CA
of
the
flag
state
is
in
charge
of
its
vessels,
and
not
you
as
the
port
state
of
the
unloading
and/or
export.
• The
Chinese
legisla1on
appears
to
be
silent
in
this
regard,
so
officials
signing
cer1ficates
should
make
sure
the
best
possible
guarantees
are
obtained
from
the
Flag
State
CA
or
the
exporters,
in
regard
to
mee1ng
the
requirements
under
Maximum
Levels
of
Contaminants
in
Food
prior
to
signing.
• It
is
signing
officers
head
on
the
line
if
things
go
wrong...
Recommenda1ons