European Salmon Smokers Association
ESSA
ESSA is the European Salmon Smokers Association with member companies based in several European countries.
ID: 874084216961-91
Lobbying Activity
Response to Update of the food safety criterion regarding Listeria monocytogenes in ready-to-eat foods
7 May 2024
The European Salmon Smokers Association would like to offer comments on the draft Commission regulation amending Regulation (EC) No 2073/2005 as regards Listeria monocytogenes, with further details provided in the attached document. While we acknowledge the goal of this amendment to reduce Listeriosis prevalence in the EU, ESSA finds the proposed changes lacking in detail for effective implementation. Key remarks from our side include the need for more comprehensive monitoring throughout the entire supply chain and harmonised and concrete protocols and methods at European level for the justification of pathogen growth control, in order to address Listeria monocytogenes prevalence. Such protocols must indeed be coordinated at EU level to ensure uniform expectations and criteria for acceptability of the products. The development of official guidance on further procedures such as sampling plans, historical analyses, shelf life monitoring are necessary to guarantee food safety standards. ESSA also believes that an efficient communication system among CAs across the EU is essential to ensure the consistency of decision-making and actions taken to minimise unjustified recalls and economic damages to FBOs. If the draft regulation does not address all the points put forward here, substantial modifications of the current market situation will happen, likely provoke: a) An increase in alert notifications. b) An increase in product recalls. c) A probable loss in consumer confidence. d) A distortion in the treatment of Listeria monocytogenes alerts in different countries in the EU These concerns and alarms raised would be likely to happen even if the hygienic situation in salmon sector is maintained at current level.
Read full responseResponse to Updating the legislation related to the hygiene rules for products of animal origin
22 May 2023
The European Salmon Smokers Association (ESSA) fully supports the wording introduced in Section VIII, in Chapter VII as follows: 4. In the case that the temperature of fresh or processed fishery products needs to be temporarily decreased, or in the case that the temperature of frozen fishery products needs to be temporarily increased, to a temperature higher than -18°C to permit the use of machines that slice or cut fishery products, the change of temperature to reach that required for the cutting or slicing of fishery products, and the subsequent return to the storage temperature of the fishery products, shall be as short as possible. The total time of the operation of cutting or slicing at the technologically-required temperature shall not exceed 96 hours. Storage or transportation of fishery products at that temperature shall not be allowed.. In addition, attached, we would like to provide a series of information that we consider to be relevant to the stiffening technological step to apply for processed fish slicing and, in our specific case, for smoked salmon slicing. We consider this information crucial for the upcoming discussions.
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