Fresh Produce Consortium
FPC
The Fresh Produce Consortium is the UK trade association for the UK fresh produce and cut flower industry.
ID: 197992215493-62
Lobbying Activity
Response to Rules on plant passports
10 Jan 2020
The Fresh Produce Consortium is the UK’s trade association for the UK fresh produce, cut flower and plants industry.
We welcome the opportunity to comment on the proposal for types and species of plants for planting not exempted from the traceability code requirement for plant passports. We do not support this proposal which we believe is disproportionate and which does not add any value to maintaining the European Union’s biosecurity.
We believe that the list of plants not exempted must be more specific to have any value in the framework of a risk based approach to plant health and biosecurity, using assessments and expertise available to the Commission and EU Member States in consultation with industry. The list should focus on those specific plant species which are identified as carrying a risk rather than having such a broad generic basis.
The industry is engaged in meeting new requirements for plant passporting which is causing significant additional costs and resources, including labelling. Traceability of products is already in place across the UK supply chain and any additional requirements for plants to carry specific codes is an unnecessary step and will pose an immense burden in terms of resource and cost on the industry.
Read full responseResponse to Commission Regulation setting maximum residue levels for chlorate in or on certain products
8 Feb 2019
The Fresh Produce Consortium is the trade association for the UK fresh fruit, vegetable and cut flower industry.
We have shared data with Freshfel, our European trade association, as we did for the earlier consultation in 2015. Compliance with the new proposed MRLs will not be possible to achieve across a range of fresh fruit and vegetable products for the reason that produce comes into contact with chlorinated drinking water and also the use of biocides containing chlorine, essential for maintaining good hygiene in production and throughout the supply chain. There needs to be an assessment of the potential low risk from residues of chlorate to human health with the potential risk of increased levels of microbiological contamination.
We question the scientific basis and rationale for the proposed MRLs given that chlorate is no longer used as a pesticide yet still comes under the framework of pesticide regulation, EU Regulation 396/2005, rather than being considered as a contaminant.
Cleaning agents are used throughout the supply chain, from hand washes in the field, cleaning lines in the packhouse and on retail shelves to prevent microbiological contamination. Chlorine based disinfectants have a proven track record over many years and the UK fresh produce industry has an excellent public health record with current practices which will be at risk if these proposed MRLs are approved.
The fresh produce industry uses chlorinated drinking water supplied by individual water companies across the UK for irrigation, washing and transportation, as advocated as good hygiene practice by the European Commission. The fresh produce industry has no control over the levels of chlorine used to protect UK consumers in drinking water. The potential entry points for chlorates are therefore widespread in the supply chain for fresh fruit and vegetables, even before products reach the final stage of preparation by the customer in a food outlet or in the home.
Any EU MRL for fresh produce commodities must take into account the use of drinking water in food production and preparation and what are already deemed to be acceptable guidance levels by the World Health Organisation.
There few reliable alternatives to chlorine based disinfectants and the industry would need sufficient lead in time for any revalidation of disinfection processes to avoid a future food safety issue. We are concerned, should this draft regulation go forward, that it only indicates a 20-day period of implementation from the date of publication of the regulation in the Official Journal.
Read full response10 Aug 2018
The Fresh Produce Consortium is the UK’s trade association for the fresh fruit, vegetable and cut flower industry. Our membership includes UK retailers, importers, wholesalers, food service companies, distributors, processors and growers as well as a number of allied organisations, including embassies.
FPC believes that the EU and UK plant health strategy should be managed by a risk-based approach to prevention and intervention, reflecting current and emerging threats to biosecurity. Plant health controls need to be risk based, proportionate and to recognise the need for continued international trade.
The fresh produce industry recognises its shared responsibility to manage plant health controls through an integrated approach throughout the supply chain. There are occasions where effective awareness raising and reliance on industry control measures can prove highly effective against the potential threat of new and emerging pests and diseases.
The draft Implementing Regulation uses a very broad definition of plants and we would request that the Commission looks in the first instance to use CN commodity codes, and secondly develops a further solution, to help identify those specific products and varieties/species which are to be included as ‘high risk’. In addition, there is a need to clarify which parts of a plant are included within the definition: the fruit, leaves, seeds, roots or pollen.
We would request more transparency regarding the criteria used to assess whether a product is deemed to be ‘high risk’, and the technical evidence to support this. It is not apparent how a product may in the future be removed from the listing, and how the trade can assist this process.
We believe that the list of high risk products should be a combination of the specific product, identified by its CN code together with a specific country/countries of origin, to mitigate the impact on other exporting countries which do not have the same plant health issues.
The European Commission should be using the intelligence gathered through EUROPHYT and audits to target those countries which are the originators of plant health issues and engage in an effective dialogue with national plant health authorities, trade bodies and exporters to help them eliminate problems at source.
Fresh fruit and vegetables offer a low risk compared to plants or seeds and there is far greater scope in some cases to have further reduced inspection levels where products already require a phytosanitary certificate from the exporting country, and there is evidence of effective control measures in place which have reduced the number of interceptions.
We would request that the Commission provides more information on the preliminary risk assessment and how it will operate, the processes for submission of supporting dossier, the methodology for the pest risk analysis and its evaluation. Third countries and importers will need to have more information on the timing for carrying out a pest risk analysis.
We would be interested in seeing the Commission’s assessment for the economic impacts of the implementation of the new regulation. We are concerned whether there will be sufficient official resources in place for carrying out the significant increase in documentary checks and physical inspections at points of entry. There will be considerable potential delays in clearing consignments as a consequence, as well as the increased charges for official controls which will impact on the UK fresh produce industry and our trading partners in third countries. This could lead to increasing the price of goods for EU consumers. One consideration might be to look at phasing in the introduction of the requirements for phytosanitary certification based on more detailed prioritisation of the highest threats.
For our full response, please see our attachment.
Read full responseResponse to Revision of the Drinking Water Directive (RECAST 2017)
27 Mar 2018
It is vital that there is coordination within the Commission regarding values set for drinking water and the current review of MRLs for chlorate in foodstuffs. Any Maximum Residue Level for chlorate in foodstuffs must consider water treatment and biocidal uses through the food supply chain.
The UK fresh produce industry believes that a proportionate, risk-based approach to setting Maximum Residue Levels should be taken which takes into account the absolute need to protect consumer safety whilst allowing industry to retain the use of chlorine to reduce microbiological contamination.
Read full response