European Working Community for Food Inspection and Consumer Protection
EWFC
La communauté de travail européenne pour le contrôle alimentaire et la protection des consommateurs est un regroupement des unions professionnelles des contrôleurs des états membres de l'Union Européenne.
ID: 52069834210-92
Lobbying Activity
Response to Sustainable food system – setting up an EU framework
24 Oct 2021
Membership of the European Working-Community for Food-Inspection and Consumer Protection (EWFC) membership is split between food inspectors and meat inspectors, we therefore have quite a deep appreciation of the EU food system.
We have studied both this latest document, named above, and the European Green Deal with great interest and admiration.
We support the Commission’s initiative in this area. We also believe there will be very difficult choices to be made.
We understand that this initial assessment is not meant to go into detail but we also know that for the planet to change to a sustainable pattern of consumption sacrifices must be made by some agricultural sectors.
We feel your laudable aim from page one of changing to a sustainable system and, “improving the incomes of primary producers and reinforcing the EU’s competitiveness”, will be very difficult to achieve. We believe that the expertise and professionalism of our members could play an important role in this process.
Most experts in sustainability and climate change control state that the world needs to drastically reduce consumption of red meat and poultry. This as you will understand is not without important consequences for our members but we are sure we are ready for that challenge.
We are sure you know, therefore, to succeed in your stated aims you may have to face the difficult task of reducing meat production and consumption in the Union. You may also have to deal with the problem of preventing the agreed import of meat from third countries as mentioned on your pages 5 and 6.
Page 4 of this document states, “in Article 39 of TFEU, are to increase agricultural productivity, to ensure a fair standard of living for the agricultural community, stabilisation of markets and availability of supplies, while ensuring that supplies reach consumers at reasonable prices;”
We support you in the above aim but believe there may be many producers and processors in the animal sector who will be disadvantaged if you reach your target.
If a reduction in the consumption of animal protein is necessary, we feel this will also present an opportunity to improve the already good standard of food, of both animal and plant origin, safety in the Union. Meat production lines already run too fast and this speed causes contamination, which in turn causes human illness. For example, if we are reducing meat and poultry consumption production lines can run slower and food processors can take more care over the safety of products they produce.
Our members should have more time to carry out official controls and ensure the products are wholesome and safe. This is a positive in what we believe will be quite a difficult time for the animal protein sector as the volume may get smaller and the price probably increase.
Read full responseResponse to Practical arrangements for official controls of food of animal origin
17 Oct 2018
EWFC’s comments on the Commission draft proposal:
Article 7, 3. (b)” states, “does not bear faecal or other contamination considered to pose an unacceptable human health risk;”
We believe any visible faecal contamination always poses an unacceptable health risk, it should read, “does not bear visible faecal contamination”.
Article 11 Ante Mortem can be limited to a representative sample of each poultry flock of poultry
We are surprised the Commission suggest reducing ante mortem inspection to a batch of poultry. EFSA recommended it should continue.
Article 25 poses the most serious risk to consumer health.
The study carried out by Ewa Pacholewewicz of Utrecht university, shows:
“the visibly contaminated carcasses after evisceration have higher E. coli concentrations than visibly clean carcasses”
“carcasses with even small spots of faecal and caecal content after evisceration carried on average a significantly higher load of E. coli (p ¼ 0.001).”
“removing carcasses or their parts with visible faecal contamination in Slaughterhouse A was hardly ever carried out, whereas in Slaughterhouse B it was frequently carried out (Fig. 2).”
“Abattoir B had much better post mortem inspectors the removal of carcases or their parts with visible faeces led to a much lower level of bacterial contamination.
We ask that this dangerous proposal is withdrawn.
Visually inspecting or microbiologically testing a sample will not detect random carcases with heavy contamination. The Cibin study shows a great variation in microbiological load of carcases.
We also consider the use of an Implementing act to be an abuse of process.
Read full response