PART 1:

SUBJECT: ACTIONS ON SAFETY/ CHEMICALS/ BRAND (EU) FOR GOODS

ML: - Group: 8
I. Requirements for goods in the EU market
1. EURO product standards
The European Commission works to ensure that Europe's good supply is the safest in the
world and that the same standards of food safety apply to all products regardless of
origin. As the world's biggest importer and exporter of foodstuffs, the European Union
works closely with international organizations and offers advice as well as assistance to
non-EU country trading partners.

2. Chemical safety
As a manufacturer or importer registering such substances, you must show the European
Chemicals Agency (ECHA) how they can be used safely and use a safety data sheet to
inform potential users in the supply chain of any risk management measures they may
need to take.
3. Classification, labelling and packaging of chemicals
If you supply any hazardous chemicals within the EEA, you must abide by the
Classification, Labelling and Packaging Regulation. It complements the REACH
Regulation and ensures that the hazards of chemicals are clearly communicated to
workers and consumers through pictograms and standard statements on labels and safety
data sheets.
II. Regulations on safety for specific goods:
1. Seafoods:
Because the EU is one of the most defending markets, the standards for exporting to EU
countries are very high.
Vietnam is one of the few countries that are allowed to export fishery products to the EU
and have the FFP agreement signed on May 15, 2019 and effective on May 28, 2019. The
proposal to export to the EU has actually been available since 2007.
Companies register their export right through a national authority and then send their
application to the EU for quality verification.
Fishery products must be fished by recognized fleets (natural catches) or must be
produced on registered farms (if farmed) to reduce fishing unlawful. The Food and
Agriculture Organization of the United Nations (FAO) is conducting the verification.

a. Rules:

 Sanitation: Sanitation relates to regulations on fish health standards, including

contaminants, microbiological contaminants and HACCP implementation. In
addition, they also include packaging and storage (for example, checking the
temperature and also during transport). (HACCP are the principles used in
establishing food safety management systems. HACCP is mandated by many
countries around the world to apply in the manufacturing process)
 Traceability and labeling: Stricter traceability regulations for fishery products
exported to the EU. Effective from December 2014 ((Directive No. 1379/2013).
According to this regulation, labels must provide accurate information on the
harvest and production of products. They apply to all seafood. Processing, as well
as some processed, does not mention whether it has been prepackaged or not.
The new labeling system provides consumers with the opportunity to select harvested
seafood in sustainable ways and from specific sources. One of the most significant
changes relates to the identification requirements for equipment used for fishing and
fishing grounds.
 Contaminants: Contaminants include heavy metals such as lead, cadmium,
mercury, dioxins and PCP as well as PAHs. Fish exported to the EU are usually
tested before shipping, sometimes in the buyer's lab, or in independent accredited
laboratories. Read more about contaminants in the contaminants in the EU Export
Helpdesk. Microbiological contaminants: are bacteria found in fish as stated in EU
regulation No. 2073/2005.
Microbiological contaminants: are bacteria found in fish and are part of the standard
content of fish as stated in EU regulation No. 2073/2005.
For example, high histamine levels due to poor temperature management can be found in
tuna and sardine. Microbiological contamination can be prevented by proper hygiene
measures, such as for histamine where immediate cooling of fish and good temperature
management are required at all stages.
b. Additional requirements of the buyer:

 Food safety certification is an additional guarantee: The seafood safety

certification program is usually required for IFS and / or BRC. You will know this
program is mainly in Northern and Western Europe. The standards initially
focused on food retail, but later they also became recognized programs in the food
service channel system (e.g., restaurants and food service providers). high quality).
Certification in accordance with one of these programs plays an important role
when entering the EU market. Both programs are based on HACCP and are
similar in several respects.
 Achieving BRC and / or IFC certification can enhance opportunities within the
EU. Therefore, you should know about these standards.
 If you plan to invest in processing equipment, you should consider the rules to
avoid having to rebuild expensive processing facilities when you want to get a
certificate later.
 Need to know the amount of time needed and costs related to the preparation
phase. The most difficult and expensive part of obtaining a certificate is
preparation to meet the standard. The actual cost of certification usually accounts
for only a fraction of the total cost associated with obtaining the certificate.
 You may also consider using a certification service provider. They often provide
both pre-certification and certification services.

2. Coffee
a. Achieving BRC and / or IFC certification can enhance opportunities within the
EU. Therefore, you should know about these standards.
b. If you plan to invest in processing equipment, you should consider the rules to
avoid having to rebuild expensive processing facilities when you want to get a
certificate later.
c. Need to know the amount of time needed and costs related to the preparation
phase. The most difficult and expensive part of obtaining a certificate is
preparation to meet the standard. The actual cost of certification usually accounts
for only a fraction of the total cost associated with obtaining the certificate.
 d. You may also consider using a certification service provider. They often provide
both pre-certification and certification services.
e. 2. Coffee
The most important market in the world for coffee is the European Union (EU) that has
standardized rules for importing this product (and once it enters it can circulate freely
among the different countries of the Union). In addition to Germany’s 10% accumulated
consumption, the other EU countries consume a fair amount of coffee: France and Italy,
for example, each account for 6% of the world market. In total, the sum consumed by all
EU countries accounts for 44% of the global coffee market.
a. Traceability
Foodstuffs must comply with the EU health and safety requirements before entering the
EU market. As a result, coffee can only be exported to the EU if it complies with EU
food law or equivalent conditions. For instance, food business operators – including the
final importer – should be able to trace and identify where their products came from, and
where they are going as well, to rapidly provide this information to the competent
authorities if required. This is called 'traceability'
As a food business operator – including final importer – you must be able to trace and
identify where your products came from and where they are going, to rapidly provide this
information to health and safety authorities if required.
b. Pesticide residue
To ensure that food placed on the market is safe and does not contain contaminants that
could pose a danger to human health, food imports into the EU should comply with EU
food safety standards and respect the maximum level of contaminant per product. For
instance, specific limits of Ochratoxin A are set for coffee and the limits vary depending
on whether the coffee is roasted or soluble.
Besides, coffee cannot be exported to the EU if it presents residues of pesticides
exceeding the maximum levels permitted, thereby posing an unacceptable risk to humans.
Maximum pesticide residue limits have been established for coffee and you can find the
exact amount for each pesticide at the EU pesticide database available at the Export
Helpdesk. For instance, 1 kg of coffee beans may not contain more than 1 mg of
Carbofuran in order to enter the EU.
c. Labelling/Brand
Labels must be, visible, legible, indelible, and clearly worded in a language easily
understood by consumers. Usually this means in the official language(s) of the European
country where the product is marketed. You may use foreign terms or expressions if they
will be easily understood by consumers. Packages (or labels attached to pre-packaged
coffee) must display:

 NAME UNDER WHICH THE PRODUCT IS SOLD. Unless specific EU or

national provisions apply, the name should be a customary name or a description.
A trademark, brand name or fancy name may be used in addition to the generic
name. You must also include the coffee's physical condition or specific treatment
undergone (roasted, soluble, etc), if its omission could be misleading for
consumers.
 LIST OF INGREDIENTS, INCLUDING ADDITIVES. Exception: foods
consisting of a single ingredient, where the name of the food is identical to the
name of the ingredient or enables the nature of the ingredient to be clearly
identified. You must always indicate any substances that might cause allergic
reactions.
 NET QUANTITY MINIMUM DURABILITY DATE. Format: "best before
DD/MM/YYYY"
 SPECIAL CONDITIONS FOR STORAGE OR USE NAME OR BUSINESS
NAME AND ADDRESS of the manufacturer, packager, or seller established in
the EU.
 PLACE OF ORIGIN OR PROVENANCE, where its omission could be
misleading for consumers.
 LOT MARKING on pre-packaged foodstuffs. Format: "L..."

These indications must appear on the package or on a label attached to pre-packaged

coffee

b. Coffee extract, soluble or instant coffee – specific labelling requirements

Markings such as `Coffee extract©, `soluble coffee extract©, `soluble coffee© or `instant
coffee© mean that the package contains concentrated product obtained by extraction
from roasted coffee beans using only water as the medium of extraction and excluding
any process of hydrolysis involving the addition of an acid or a base.
Coffee extract must contain only the soluble and romatic constituents of coffee – apart
from insoluble substances technically impossible to remove, and insoluble oils derived
from coffee.
The term "concentrated" may only appear on the label if the coffee-based dry matter
content is more than 25% by weight.
The term "decaffeinated" must appear if the anhydrous caffeine content does not exceed
0.3% by weight of the coffee-based dry matter.
This information must be within the same field of vision as the sales description.
The above requirements do not apply to café torrefacto soluble.
Coffee extract in solid or paste Liquid coffee extract
to be considered "coffee", dry Dry matter content must be between 15% and 55 %
matter content must not be less by weight. If containing sugars (roasted or not), the
than 95% by weight (dried coffee proportion must not exceed 12% by weight. Label
extract) or 70% to 85% by must include the terms `with', `preserved with',
weight (coffee extract paste). `with added' or `roasted with' followed by the
Must not contain substances name(s) of the types of sugar(s) used.
other than those derived from the
extraction of coffee.
Label must indicate minimum
coffeebased, drymatter content
(% by weight of the finished
product)

3. Tea
a. Food safety: Traceability, hygiene and control
 Food safety and food control are key issues in European food legislation.
 The General Food Law is the legislative framework regulation for food safety in
the European Union.
 To guarantee food safety, it must be traceable throughout the supply chain, and
risks of contamination must be limited. Implementing a quality management
system can be an important tool in controlling food safety hazards.
 The European Union exercises official checks on tea to guarantee compliance with
the European food safety standards.
 The Regulation requires that food business operators put in place, implement and
maintain a permanent procedure or procedures based on Hazard Analysis and
Critical Control Point (HACCP) principles. This requirement will apply to tea
processors carrying out any stage of production, processing and distribution of
food after primary production and associated operations. Tea imported into the EU
is subject to the requirements laid down in this Regulation.

b. Contaminants in food (TEA)

The European Union has set maximum levels for certain contaminants (Regulation (EC)
No 396/2005 in its current version*)
Besides pesticide residues, monitoring may take place for:
  Foreign matter: contamination by foreign matter such as plastic and insects is a
threat when food safety procedures are not carefully followed.
 Mycotoxin contamination: Although mycotoxins are generally not a major
problem in tea production, the situation may be different for some herbal teas.
 Microbiological: although tea is a low-risk commodity, contamination with
salmonella can be a serious threat. The current European legislation has no
microbiological criteria for tea. Food safety authorities can, however, withdraw
imported food products from the market or prevent them from entering the
European Union when salmonella is found to be present.

c. Extraction solvents
These can be used for decaffeination of tea. There are maximum residue limits
restrictions for the extraction solvents such as methyl acetate (20 mg/kg) and
dichloromethane (5 mg/kg).
Maximum Residue Levels (MRLs) of pesticides in food

Pesticide residues are an important issue in the tea trade. The European Union sets
maximum levels on the amount of pesticides allowed on imported foods including tea.
However, individual buyers in Germany for example, may have stricter requirements on
MRLs than the official limits as part of their private standard (such as 30% of the level of
the European Union). In addition, thresholds have become more rigorous as accredited
laboratories are increasingly able to detect lower residue levels on dried tea leaves.
The use of pesticides is permitted in tea cultivation, but it should be strictly controlled,
particularly for tea from Asian countries (e.g. China, Vietnam, India, Indonesia, Sri
Lanka)
The residues that are most commonly found in tea are dicofol, ethion, quinalphos,
hexaconazole, fenpropathrin, fenvalerate and propargite. Residues vary by country of
origin, however, and are constantly changing.

Food safety Management for tea

Due to the growing attention for food safety, large retailers and other buyers, such as
importers and processors in Europe, more often request food safety management systems
(FSMS). The most important food safety management systems in the European Union
are BRC, IFS, ISO22000 (FSSC22000) and SQF, which are mainly relevant for packers
of consumer teas (not so much for farmers or traders).
REGULATION ON CONSUMER LABELLING FOR TEA
Pre-packed tea sold to consumers must adhere to strict requirements from the European
Union concerning labelling, presentation and advertising of foodstuffs. It prescribes all of
the information that must be mentioned on consumer packaging, including the list of
ingredients, net quantity and the possible presence of allergens.
Although tea itself normally does not contain allergens, this may change if you sell mixes
of (for example) herbal tea.…
Regulation (EU) No 1169/2011 in its current version.

REGULATIONS ON GENERAL CHARACTERISTICS OF TEA according to

Compendium of Guidelines for Tea (former ETC document)
Tea is a low moisture ambient-stable foodstuff, therefore microbiologically stable under
normal storage conditions. These may be defined as max. 25° C, max. 65% RH and light
protected.
 Tea is virtually free from any vegetative forms of moulds and should be free from
any foreign material so far as is reasonably practicable.
 The content of acid-insoluble ash in the dry matter of tea provides information as
to whether or not it may be contaminated or adulterated with mineral components
such as soil or sand. According to ISO Standard 3720 the acid insoluble ash
should not exceed 1%.
 As per ISO 3720 no moisture (loss in mass) limit is specified for tea as received
from the country of origin. However, as a general rule a moisture level of 8 %
should not be exceeded. Where moisture levels are determined they should be
based on ISO 1573.
 Caffeine is naturally present in tea. Tea contains no less than 1.5% in the dry
matter.
 Water-soluble tea matter is typically no lower than 32%. Notable exceptions to
this are Turkish and Russian teas which contain at least 26% in the dry matter.
4. Fruits and vegetables:
a. Content:

When exporting fresh fruit and vegetables to Europe, you have to comply with the
requirements below. These requirements can be categorised as:
 food safety;
 product quality;
  social, environmental and business compliance.
b. Labelling and packaging
Food placed on the EU market must meet the legislation on food labelling.
Cartons of fresh fruit or vegetables must mention the following particulars:
 name and the address of the packer or the dispatcher;
 name and variety of the produce (if the produce is not visible from the outside of
the packaging);
 country of origin;
 class and size (referring to the marketing standards);
 lot number for traceability or GGN if certified GlobalG.A.P. (recommended);
 official control mark to replace name and address of the packer (optional).
For consumer and pre-packed fresh products, you must add the name and the address of a
seller established within the European Union with the words “Packed for:” or an
equivalent phrase.
Packaging marketed within Europe must comply with the general requirements, which
aim at protecting the environment, as well as with the specific provisions designed to
prevent any risk to the health of consumers. The packaging must protect the product
against contamination, leakage and dehydration. Also pay attention to your buyer’s
preference for presentation, such as individual wrapping or sortation (for example, one
side up). Products and packaging should be uniform.
c. Control of food imported to the EU (Food Safety)
To ensure food safety and avoid environmental damage, your products will be subjected
to official controls. These controls are carried out to ensure that all foods marketed on the
European market are safe and in compliance with all applicable regulatory requirements.
There are three types of checks:
 documentary checks;
 identity checks;
 conformity checks to marketing standards.
In case of repeated non-compliance of specific products originating from particular
countries, the European Union can decide to carry out controls at an increased level or lay
down emergency measures. Controls can be carried out at all stages of import and
marketing in Europe. However, most checks are done at the points of entry.
For importers of fresh fruit and vegetables, the traceability of products is
compulsory. To fulfil this obligation, European importers will require you to provide
proof of origin for all fruits and vegetables. In addition to a Bill of Lading, phytosanitary
certificate, packing list and custom documentation, you must also use a unique
traceability code such as a lot number or GLOBALG.A.P. Number (GGN).
d. Marketing standards
European legislation sets general and specific marketing standards for the minimum
quality and the minimum maturity of all fresh fruit and vegetables. A marketing standard
determines the characteristics of “Extra Class”, Class I and Class II products, the
different size codes, and the allowed tolerances in quality and size.
The preferred sizes vary between the different European markets, but the quality is
generally “Extra Class” or Class I. You might find a market for Class II products in some
eastern European countries, the processing industry or less formal segments.
There are specific marketing standards (MS) for the fresh fruit and vegetables listed
below. These products must be accompanied with a certificate of conformity for each
consignment. These certificates can be issued by the European control bodies and in
some cases by the country of origin. A sample certificate of conformity can be found on
p. 115 in Annex III to EU Regulation No 543/2011:
 apples;
 citrus fruit;
 kiwi fruit;
 lettuce, curly and broad-leaved endives;
 peaches and nectarines;
 pears;
 strawberries;
 sweet peppers;
 table grapes;
 tomatoes.
Fresh products that are not covered by a specific marketing standard have to comply
with:
 the general marketing standards (GMS) in Annex I, Part A of EU Regulation No
543/2011; or
 the applicable UNECE standard (sometimes less strict than the EU standard).
Operators are free to choose whether to work with the EU or UNECE standard. If your
product is not covered by any specific European standard, you can also check for similar
standards in the Codex Alimentarius.
Imports of products intended for processing are not subject to compliance with the EU
marketing standards. However, they must be clearly marked on the packaging with the
words "intended for processing" or other equivalent wording.
Part II: