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International Nut and Dried Fruit Council Foundation

INC

The International Nut and Dried Fruit Council (INC) is a not-for-profit foundation established in 1983, whose mission is to facilitate sustainable growth in supply and consumption through sharing the goodness and health benefits of nuts and dried fruit globally.

Lobbying Activity

Response to Food and Feed Safety Simplification Omnibus

14 Oct 2025

The International Nut and Dried Fruit Council (INC) welcomes the launch of the call for evidence on the Food and Feed Safety Simplification Omnibus. We broadly support the overarching objectives to streamline the regulatory framework and reduce bureaucratic burdens on business operators. We trust that this will also be an opportunity to provide clarification on certain aspects of official controls with a view towards greater regulatory harmonization across Member States. Nut and dried fruit imports from various countries contribute significantly to the processing and manufacturing sectors, supporting SMEs across the European Union. We would like to highlight the current challenges faced by exporters and local processors, where there is a lack of consistency across border control posts and decision-making processes. In particular, there are inconsistencies in the interpretation of Articles 66 and 67 of Regulation (EU) 2017/625 by competent authorities. This leads to operational challenges, financial impacts on SMEs, and concerns about food loss and food waste. With the 2019 update to the Official Controls Regulation (OCR), two articles were introduced that address non-conforming consignments. Article 67 specifically addresses the "risk" posed by detained consignments, but there is a lack of clarity on how this "risk" is defined. As a result, European importers and suppliers have experienced inconsistent interpretations across Member States concerning the fate of consignments rejected for exceeding aflatoxin limits. In some instances, Member States have considered reprocessing or destruction as the only options (as per Article 67), while others have interpreted that shipments could be returned to the origin under Article 66. Providing clear guidance on this would benefit both importers and shippers. Article 66 of Regulation (EU) 2017/625 does not prohibit re-dispatch of consignments detained for failing to comply with rules referred to in Article 1(2) the various EU regulations in the areas of food safety, plant health, GMOs, etc. Article 66(3) allows for measures such as destruction, re-dispatch outside the Union, or special treatment to ensure compliance. Article 67, however, interprets risks differently, with no option provided for re-dispatch. Unfortunately, the interpretation in Article 67 does not distinguish between serious or immediate human, animal and plant health risks and lesser risks that can be corrected with special treatments and/or reconditioning. As an example, a consignment with higher than permitted aflatoxin levels may still meet other countrys limits and do not pose an immediate human health risk since it could be reconditioned to comply with health regulations. Not allowing re-dispatch outside the EU for consignments deemed "low-risk" prevents corrective actions that could mitigate the potential risks without destroying the goods. Beyond economic losses, such decisions also lead to preventable food loss, which runs counter to EUs sustainability goals. Please proceed to read the attached PDF to read the rest of the comment.
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Meeting with Maciej Golubiewski (Cabinet of Commissioner Janusz Wojciechowski)

18 Nov 2020 ยท Key speaker in the First INC Online conference (International Nut and Dried Fruit Council)