Traceability implementation in developing
countries, its possibilities and its constraints
Summary
“Traceability/ product tracing” is defined by the Codex Alimentarius Commission1 as “the ability to
follow the movement of a food through specified stage(s) of production, processing and distribution”. The International Standards Organization (ISO 84022) defines “Traceability” as the
“ability to trace the history, application or location of an entity by means of recorded identifications”. The EU General Food Law (Regulation [EC] No. 178/2002, Article 18 paragraph 1) offers a definition of traceability with particular regard to food and feed sectors: “’Traceability’ means the ability to trace and follow a food, feed, food-producing animals or substance intended to be, or expected to be, incorporated into a food or feed, through all stages of production, processing and distribution.”
In general, traceability measures can be used to:
• improve the management of risks related to food safety and animal health issues;
• guarantee products’ authenticity and to give reliable information to customers;
• improve products’ quality and processes.
With regard to international trade, new legal requirements in mainly developed countries relating to traceability have recently been implemented, and in various sectors, importing countries have placed increasing pressure on exporting countries to comply with traceability requirements. These measures, however, must comply with the World Trade Organization agreements; they must be justified as having a sanitary or phytosanitary (SPS) objective3 or as having a legitimate objective.4
When international debates are held, developing countries emphasize the significant constraints5
they face in implementing the required traceability systems; in addition, they have argued that establishing international standards on traceability would not favour them.
Traceability is not a purely Western initiative: many interesting developments are under way in developing countries. Harmonized standards for traceability, inspection and certification systems within the organic production sector, for instance, would facilitate organic export from developing countries to the premium markets of the Western world. However, as outlined below, these countries can face significant constraints. Developing exporting countries face different situations (for instance, sanitary, economic and structural) than countries in the EU.
This study then outlines the key issues involved in implementing traceability systems in developing countries, and sheds light on the particular constraints and problems they face. The aim is to provide an overview of the possibilities and constraints of traceability implementation in developing countries in several examples of products intended for export (to the developed world). Three case studies are examined in detail:
1 The production of bovine meat (with traceability used as a tool to control animal health and/or food safety hazards).
2 Pistachio production (with traceability used as a tool to control food safety hazards).
3 Organic agricultural products (with traceability used as a tool to guarantee products’ authenticity and to provide customers with reliable information).
4
1 Adopted at its 27th session (July 2004)
2 International Organization for Standardization : standard available at www.iso.org 3 According to Article 3 of the SPS agreement.
4
According to article 2, paragraph 6 of the TBT agreement. 5 And especially the costs.
P
RODUCTION OF BOVINE MEAT INTENDED FOR EXPORT
Because of their trading links with the European Union (EU), the four Mercosur countries – Argentina, Brazil, Uruguay, and Paraguay – and Botswana and Namibia are under increasing pressure to implement more comprehensive and more efficient animal identification and traceability systems. These systems would enable them to:
• improve the control of disease outbreaks;
• avoid consecutive huge trade losses;
• possibly gain access to premium markets;
• control lost and stolen cattle; and
• improve systems’ efficiency.
In most of the developing countries reviewed for this document, improved cattle-identification systems are currently under development. On the whole, they are designed to apply only to bovines intended for export (Argentina, Namibia, Uruguay, Brazil, Chile). However, developing countries still face significant constraints when attempting to implement traceability systems, including the following:
• high costs and lack of financial resources;
• for some of the countries, huge size and dispersion of the various stakeholders;
• lack of infrastructure and knowledge.
Most systems of animal identification are currently based on ear tags1. In order to fully implement
an animal traceability system, each animal must be identified individually. However, several issues related to the implementation of animal identification systems have to be addressed, and the answers may differ from one country to another:
• Is individual identification actually necessary?
• Does the traceability system have to be extended to the entire national cattle population?
• How should appropriate legislations be designed?
• Would traceability and certification allow bovine meat for export to be sold at higher prices?
• the identification of orchards at a high risk for aflatoxin contamination;
• an identity preservation programme;
• a quality-dependent payment system;
• a quality label.
O
RGANIC AGRICULTURAL PRODUCTS INTENDED FOR EXPORT
For organic growers and producers, the implementation of traceability systems is a key element in securing international organic certification and a basic requirement for gaining access to premium export markets, where products can be sold at the highest prices. More and more developing countries are becoming interested in organic agriculture. However, with regard to the traceability issue (and the certification procedure that is linked to it), they are penalized by:
• high costs of certification, especially when international certifying bodies are used;
• an absence of appropriate legislation in their own country;
• complexity of import and certification procedures;
• the proliferation of different standards and requirements, frequently resulting in multiple certifications;
• lack of knowledge about organic traceability systems;
• lack of governmental financial and technical support in developing countries;
• size of the country.
In order to implement traceability procedures, organic growers and producers could avail of:
• technical or financial assistance;
• the development of an international system for harmonization and equivalence;
• development of group certification and inspection;
• development of national infrastructure and legislation.
These case studies show that many interesting initiatives are being implemented in developing countries, either in the bovine meat sector, the pistachio sector, or in the organic sector. This underlines that traceability is not purely a western phenomenon. The case studies show that, to an extent, efforts can be made to overcome some of these constraints.
The constraints and costs of implementing traceability procedures depend mainly on the objectives and characteristics of the system being developed; in some sectors, procedures relying on paper documents and records could be enough to meet the desired objectives, while other sectors may require more advanced techniques.
Moreover, developing countries might actually benefit from international standards. For instance, harmonized standards for traceability, inspection and certification systems within the organic production sector would facilitate organic export from developing countries to the premium markets of the western world. It is also worth examining the possibility of harmonizing and standardizing aspects relating to individual livestock identification and traceability systems, as well as in sectors such as pistachio production.
However, as noted above, setting up traceability systems may be much more difficult for developing countries than for countries in the EU, the United States of America or Japan. This is because developing exporting countries can face very different sanitary, economic and structural circumstances than more developed countries. Even within the developing world, some countries
have far more advanced infrastructures than others and benefit from better political, economical or sanitary conditions. This document addresses most of these challenges and makes recommendations of ways to overcome them.
Table of contents
Summary... 2
Table of contents... 5
Introduction ... 11
Chapter 1 Prerequisites on traceability ... 13
1.1. Definition... 14
1.2. Main objectives... 15
1.2.1. A tool to manage risks related to food safety and animal health issues... 15
1.2.2. A tool to guarantee product authenticity and to give reliable information to customers . 15 1.2.3. A tool to improve product quality and processes... 16
1.3. New legal requirements in developed countries... 16
1.3.1. European Union... 16
1.3.2. United States of America... 16
1.3.3. Canada... 18
1.3.4. Japan... 18
1.4. Brief overview of international issues and debates... 18
1.4.1. WTO agreements ... 18
1.4.1.1. SPS agreement: its main provisions and principles... 18
1.4.1.2. TBT agreement and its main provisions... 19
1.4.1.3. Traceability compliance with WTO agreements... 19
Equivalence ... 20
Regionalization... 20
1.4.2. Codex Alimentarius negotiations ... 20
Debate of the costs and benefits of traceability... 21
1.5. Bibliography ... 22
Chapter 2 Traceability implementation in developing countries: Production of bovine meat intended for export... 24
2.1. Economic BACKGROUND: data on world trade and bovine meat production in developing countries... 24
2.2. Sanitary and regulatory background... 27
2.2.1. Brief overview of the animal health situation in the developing countries considered ... 27
2.2.1.1. FMD and FMD status... 27
2.2.1.2. BSE ... 29
2.2.1.3. FVO inspections... 29
2.2.2. Implementation of new traceability standards in developed countries: a brief overview. 29 2.2.2.1. Implementation of new EU standards ... 29
Japan... 30
Australia ... 30
The United States of America ... 31
Canada... 31
2.2.3. Requests for export to the EU countries... 31
2.2.3.1. Establishment of lists of authorized countries... 31
2.2.3.2. Freedom from diseases (such as FMD)... 32
2.2.3.3. Freedom from specific residues (antibiotics, contaminants, hormones) ... 32
2.2.3.4. Exports from EU-agreed slaughterhouses, veterinary checks and certificates... 33
2.2.3.5. Specific requirements concerning BSE... 33
2.2.3.6. New EU requirements on beef and veal labelling... 35
2.2.4. Import bans for disease outbreaks and when requested conditions are not satisfied ... 37
2.3. A presentation of the technical devices for bovine identification... 37
2.3.1. The different devices available ... 37
2.3.1.1. Non-electronic devices... 37
2.3.1.2. Electronic devices ... 38
Tags with chips and transponders... 38
Boluses ... 38
Microchip implants... 38
DNA fingerprinting ... 39
Other identification tools... 39
2.3.2. A comparison of identification devices ... 40
2.3.3. The IDEA project ... 42
2.4. Incentives for traceability implementation ... 44
2.4.1. General incentives for improved animal identification systems and livestock traceability 44 2.4.1.1. With regard to food-safety issues... 44
2.4.1.2. With regard to the animal health status of the country/region and to international trade... 45
2.4.1.3. With regard to consumers’ demand and confidence in bovine meat production... 46
2.4.2. Specific incentives for developing countries... 47
2.4.2.1. A direct response to the identified shortcomings of the former/current systems ... 48
2.4.2.2. A response to the EU pressure ... 49
2.4.2.3. A more efficient and less expensive control of diseases outbreaks and tracing of relevant animals.... 49
Argentina... 50
Uruguay... 50
Brazil ... 50
2.4.2.4. A way to avoid trade losses and to gain premium markets ... 50
2.4.2.5. A way to lower costs and to improve efficiency in the system ... 52
2.4.2.6. A way to control stock theft and lost cattle ... 52
2.5. Overview of current livestock traceability systems and ongoing projects in several developing countries... 53
Uruguay ... 56
Brazil ... 57
Chile ... 57
Systems applying to the entire national cattle ... 57
Botswana ... 57
Malawi... 58
Countries for which no improved identification system is being implemented... 58
Paraguay ... 58
2.5.4.2. The technological devices used... 58
Argentina ... 58
Namibia ... 59
Uruguay ... 59
Brazil ... 59
Botswana ... 59
2.5.4.3. Individual identification or group identification?... 60
Namibia ... 60
Uruguay... 60
2.5.5. Registration and databases ... 61
2.5.5.1. Holdings’ identification and registration... 61
Argentina... 61 Uruguay... 61 Brazil ... 62 Paraguay... 62 Namibia ... 62 Botswana ... 62
2.5.5.2. Animal movement control and registration... 62
Argentina... 63 Brazil ... 63 Uruguay... 63 Paraguay... 63 Namibia ... 63 Botswana ... 64
2.5.6. Tracing of imported animals (particularly from BSE indigenous countries) ... 64
Argentina... 65
Brazil ... 65
Namibia ... 65
2.5.7. Export certification and traceability in slaughterhouses and cutting plants ... 65
Argentina... 66
Paraguay... 66
Uruguay... 67
Namibia ... 67
2.6. Constraints and weaknesses ... 67
2.6.1. Costs and lack of financial resources ... 67
2.6.1.1. Data on the costs of traceability measures in developing countries ... 67
Brazil ... 68 Uruguay... 68 Botswana ... 69 Argentina... 69 Paraguay... 69 Namibia ... 69
Before ear-tag system implementation ... 69
Implementation of the ear-tag system... 69
Colombia ... 70
2.6.1.2. How to finance the traceability measures?... 70
Argentina... 71 Uruguay... 71 Namibia ... 71 Botswana ... 71 Chile ... 71 Malawi... 72
2.6.2. Constraints related to the national geography and organization of beef cattle production 72
2.6.3. Lack of infrastructure and knowledge... 73
2.7. A final discussion on long-term objectives and opportunities... 73
2.7.1. Is individual identification necessary?... 74
2.7.2. A traceability system extended to the nation’s entire cattle?... 75
2.7.3. The importance of an efficient system of registration and control... 75
2.7.4. A voluntary system or a compulsory system, mandated by a specific legislation?... 76
2.7.5. Higher prices for traceable and certified products?... 77
2.8. Conclusion... 77
2.9. Bibliography ... 79
Chapter 3Traceability implementation in developing countries:
pistachio production for export... 82
3.1. Economic background of pistachio production ... 83
3.1.1. Some data on the most important pistachio-producing countries... 83
3.1.2. Some data on international market of pistachio... 84
3.1.3. The situation of the main producers in the developing world ... 85
3.1.3.1. Iran ... 85
3.1.3.2. Turkey... 85
3.2. The sanitary background... 87
3.2. The sanitary background... 88
3.2.1. Aflatoxin contamination... 88
3.2.2. Toxicological evaluation of aflatoxin... 88
3.2.3. Occurrence of aflatoxins in tree nuts ... 89
3.2.4. Dietary intake of aflatoxin ... 90
3.2.5. Prevention of contamination... 90
3.2.5.1 Methods 3.2.5.2 Code of practice 3.3. The regulatory background ... 91
3.3.1. European legislation ... 91
3.3.1.1. Maximum levels set by the EU ... 91
3.3.1.2. EU sampling methods ... 92
3.5.3. A few recommendations and opportunities for traceability implementation within the
production channel for export ... 97
3.5.3.1. Identification of orchards and pistachio consignments that are at a higher risk of contamination... 98
3.5.3.2. Implementation of a system of quality- dependent payment... 98
3.5.3.3. Development of an identity-preservation programme (IP)... 98
3.5.3.4. Development of a quality label ... 99
3.6. Bibliography ... 100
Chapter 4...Traceability implementation in developing countries: organic products intended for export ... 100
4.1. Overview on principles and standards applying to the organic sector ... 102
4.1.1. Definition of organic farming ... 102
4.1.2. Development of international standards and national regulations ... 103
4.1.2.1. Codex Guidelines... 103
4.1.2.2. IFOAM Basic Standards ... 104
4.1.2.3. National regulations ... 104
EU regulations... 105
United States organic regulations ... 105
Japanese Agricultural Standard ... 105
4.1.3. Certification and accreditation procedures... 106
4.1.3.1. Certification ... 106
4.1.3.2. Accreditation... 106
4.1.4. Examples of provisions related to traceability... 107
4.1.4.1. In EU Regulation 2092/91 (its modifications being taken into account) ... 107
Labelling... 107
Certification for imports... 107
Record-keeping for inspection and certification purposes ... 107
Specific provisions with regard to livestock and livestock products ... 108
4.1.4.2. In Codex Guidelines (GL 32 – 1999, Rev. 1 – 2001)... 109
Labels/claims... 109
Inspection and certification ... 109
Export certificate ... 109
Product identification and record-keeping... 110
4.1.5. Overview of different import systems and procedures ... 110
4.1.5.1. The EU import system ... 111
Amendment ... 112
4.1.5.2. The United States iport system... 112
4.1.5.3. Japanese import system... 113
4.2. Opportunities and incentives for organic production in developing countries and for the necessary traceability implementation... 115
4.2.1. Global growing demand: an opportunity for developing countries... 115
4.2.2. General benefits attributed to organic production in developing countries: the incentives for traceability implementation ... 115
4.2.3. Data on organic production, projects and opportunities: the example of several developing countries... 116 4.2.3.1. Latin America ... 116 Argentina... 116 Uruguay... 117 Chile ... 118 Peru ... 118 Dominican Republic... 118 Honduras ... 119 El Salvador ... 119 Costa Rica ... 120 Colombia ... 120
4.2.3.2. Africa ... 120
The EPOPA programme... 120
Tunisia... 121
4.2.3.3. Asia ... 121
Turkey ... 121
India... 122
The Philippines... 122
4.3. Constraints and weaknesses ... 122
4.3.1. Absence of appropriate legislation in developing countries... 122
4.3.2. A proliferation of different standards and requirements, leading to necessary multiple certifications... 123
4.3.3. Complexity of import and certification procedures ... 124
4.3.4. High costs of certification... 125
4.3.5. Lack of knowledge about organic management and traceability systems... 126
4.3.6. Lack of governmental financial and technical support in developing countries... 127
4.3.7. Size of the country ... 127
4.4. How to improve the system? A few suggested solutions... 128
4.4.1. Governmental support ... 128
4.4.2. Technical and financial assistance from developed countries ... 128
4.4.3. Development of an international system for harmonization and equivalence ... 129
4.4.4. Development of national infrastructure and regulation... 129
4.4.5. Development of group certification and inspection ... 130
4.4.6. Contract farming and out-growing... 130
4.4.7. Access to modern technology... 131
4.5. Bibliography ... 134
Conclusion ... 136
List of abbreviations (Annex 1) ... 138
Introduction
The term “traceability” is not new: it first originated in various issues related to health, aeronautics, space and arming activities. It then spread to industrial sectors, including the food industry sector. Since the 1980s, as result of several crises,1 the desire for information about animal health and
food safety, as well as concerns about food quality, has increased at both governmental and consumer levels within developed countries. This has underlined the need to implement or improve traceability systems – with a strong demand in particular from the retailing sector. Traceability is considered by consumers as a guarantee of safe and high-quality products and as a guarantee of reliable information on the origin and production conditions.
As a result, importing countries are placing higher requirements and pressure on exporting countries regarding traceability and new legal requirements have been developed with regard to international trade in meat or in other products. Not surprisingly, the EU leads most other countries in the development of mandatory traceability protocols. International discussions and negotiations are currently being held on traceability issues2. During these debates, developing countries (as
well as some developed countries) are highlighting the significant constraints they face in implementing traceability systems. In particular, the costs of traceability measures are cited as prohibitive. In fact, some countries frequently refuse to go further in discussions aimed at drafting international standards about traceability.
This document then examines how developing countries that are also main exporters respond to this pressure: it gives an overview of the possibilities and constraints of traceability implementation. Three examples of agricultural products intended for export have been chosen and will be examined in detail:
• production of bovine meat intended for export;
• pistachio production intended for export;
• organic products intended for export.
For these three case studies, we will try to answer the following questions:
• What are the exact benefits for developing countries in implementing improved traceability systems?
• How is this implementation progressing: what are the main programmes being held, the infrastructures needed, the technological devices needed, and so on?
• What are the main constraints faced?
1
Such as Foot-and-Mouth Disease outbreaks or the Bovine Spongiform Encephalopathy Crisis
Chapter 1 provides a few prerequisites on the general concept of traceability:
• a definition;
• general objectives;
• main new general legal requirements;
• current international discussions on traceability issues.
The information and results collected for the first case study (production of bovine meat intended for export) are given in Chapter 2. Chapter 3 is related to the second case study (pistachio production intended for export), and Chapter 4 to the third (organic products intended for export). The data used was collected from several sources:
• literature: referenced books and articles (including FAO, OIE1, IFOAM2 and World Bank official
publications), mostly found by using the search engine of the FAO library, which is connected to many important international catalogues and databases, or by using the internet;
• information found on websites, including official websites of some developing countries’ competent authorities;
• reports from the EU, especially reports from the Food and Veterinary Office (FVO) of the European Commission;
• internet databases, such as FAOLEX and EUR-Lex for legislation; FAOSTAT and Eurostat for statistical data; Codex Alimentarius website;
• FAO intranet databases, such as Field Programme Management Information System (FMPIS), providing access to country data and to FAO Technical Cooperation Project (TCP);
1. Chapter
Prerequisites for traceability
1.1.
D
EFINITION
The term “traceability” is often used hand in hand with the concept of “product tracing”: while “traceability” is considered as a passive process, “product tracing” is considered as an active process. There is more of a terminological difference between the terms than any real opposition in meanings; therefore, throughout this document, we refer to “traceability”.
In its 27th session (July 2004), the Codex Alimentarius Commission agreed on the following
definition for traceability/ product tracing: “the ability to follow the movement of a food through specified stage(s) of production, processing and distribution”. Several other definitions for traceability are also in use:
• theInternational Organization for Standardization (ISO) defines traceability as the “ability to trace the history, application or location of an entity by means of recorded identifications” (ISO 8402);
• the US Food and Drug Administration (FDA) proposes the following definition: “the ability to identify by means of paper or electronic records a food product and its producer, from where and when it came, and to where and when it was sent” (OECD, 2003);
• according to EU General Food Law (Regulation [EC] No. 178/2002, Article 3), “ ‘traceability’ means the ability to trace and follow a food, feed, food-producing animal or substance intended to be, or expected to be, incorporated into a food or feed, through all stages of production, processing and distribution.”
Two elements are implicit in these definitions. Traceability implies:
• the identification of a product;
• the ability to trace through the records to know more about the product.
In addition to an identification and record system, a system of communication between operators needs to be developed to utilize the benefits of traceability systems.
The definitions of some other concepts related to traceability, although not extensively discussed in this document, are as follows:
• trace-back: the ability to identify and trace the origin of problems when they occur;
• trace-forward: the ability to provide information at retail;
• identity preservation: a particular batch of products is kept separate, and not mixed with other products that may have different origins or characteristics; therefore, its identity is maintained through the marketing channel;
• market segregation: refers to the separation of products with different safety or quality characteristics in the marketing chain. It is less strict than an identity preservation system.
1.2.
M
AIN OBJECTIVES
Traceability provides a tool to achieve the three following key objectives:
• managing risks related to food safety and animal health issues;
• guarantee products’ authenticity and to give reliable information to customers; and
• improve product quality and processes.
1.
2
.1. A tool to manage risks related to food safety and
animal health issues
First, traceability can be used as a tool to manage risks related to food safety and animal health issues. It can be used to:
• identify outbreak or hazard sources;
• manage safety alerts;
• withdraw contaminated or dangerous products.
Traceability is part of a reactive control system for risk management. This is because it allows regulators to trace contamination to its source, to eliminate contaminated products from the market, and then to contain the problem. Recent crises, such as the crisis of dioxin in animal feed in Belgium in the late 1990s or the Bovine Spongiform Encephalopathy (BSE) crisis, have emphasized its importance.
Traceability can also be used to support post-market monitoring – such as monitoring the occurrence of potential long-term human health effects. (Its possible use with regard to GMOs’ potential and uncertain long-term effects is worth noting here.)
1.
2
.2. A tool to guarantee product authenticity and to give
reliable information to customers
There are many traceability systems that are used to support specific brand labels, claims or certifications in order to meet the desires of a certain type of consumer – one instance is organic food production.
1.
2
.3. A tool to improve product quality and processes
Lastly, traceability can be used as a tool for improving products’ quality and processes. In this way, it can assist in enhancing supply-side management, and contribute to optimizing yields. It can be used to
• identify sources of non-compliance;
• product fluxes; and
• stock management.
1.3.
N
EW LEGAL REQUIREMENTS IN DEVELOPED COUNTRIES
1.
3
.
1
. European Union
Several new regulations regarding traceability have recently been adopted in the European Union (EU). Some of these are specific to one or several particular sectors, such as the bovine meat sector (see Chapter 2). However, others have more general coverage. For instance, in 2002, Article 18 of the General Food Law (Regulation [EC] No. 178/2002 provided for the extension of traceability to all food, feed, food-producing animals, and to all food and feed-business operators. It stipulated that:
2 Traceability shall be established at all stages of production, processing and distribution.
3 Food and feed business operators shall be able to identify any person from whom they have been supplied with a food, a feed, a food-producing animal, or any substance intended to be, or expected to be, incorporated into a food or feed. To this end such operators shall have in place systems and procedures which allow for this information to be made available to the competent authorities on demand
4 Food and feed business operators shall have in place systems and procedures to identify the other businesses to which their products have been supplied. This information shall be made available to the competent authorities on demand.
5 Food or feed placed on the market or likely to be placed on the market in the Community shall be adequately labelled or identified to facilitate its traceability, through relevant documentation or information in accordance with the relevant requirements of more specific provisions..
1.3.2. United States of America
In the United States of America, following the publication of the Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (Bioterrorism Act) and pursuant to its title III, subtitle A sec.301, steps were taken to protect the public from a threatened or actual terrorist attack on the US food supply. In the event of a potential or actual bioterrorism incident or an outbreak of food-borne illness, the aim is to help the FDA to determine the location and source of the incident and to enable the agency to quickly notify facilities that may be affected.
• This Act1 gave the FDA additional authority in the following areas: requiring administrative
detention of foods that may pose a risk to public health (final regulation adopted in 2004);
• registering foreign and domestic food production facilities (interim final regulation published in 2004);
• requiring prior notice of imported foods (interim final regulation published in 2004);
• establishing and maintaining records among food firms (proposed regulation published in 2004).
Under the proposed rule related to record keeping (which follows the “one step back, one step forward” principle), manufacturers, processors, packers, distributors, receivers, holders and importers of food will be required to keep (paper or electronic) records:
• identifying the immediate source from which they have received the food;
• identifying the immediate subsequent recipient of the food.
This requirement will apply to almost all foreign and domestic food sources and almost all recipients of food destined for consumption in the United States of America. It will assist the FDA in addressing credible threats of serious adverse health consequences or death to humans or animals.
For all operators, other than transporters, records will be required to contain the following information for each article of food:
• firm's name;
• responsible individual representative of the firm that was the immediate previous source or the immediate subsequent recipient of the food;
• the firm’s address, telephone and fax numbers, and e-mail address;
• type of food (including brand name and specific variety);
1.3.3. Canada
In June 2001, federal, provincial, territorial Agriculture Ministers in Canada signed or initialled the Agricultural Policy Framework Agreement (“Federal-Provincial-Territorial Framework Agreement on Agricultural and Agri-food Policy for the Twenty-first Century”). Food safety and quality are key elements of this agreement. One of its goals (Para. 22.1.7) is “to facilitate the development and implementation of traceability1 systems by industry throughout the agri-food continuum by, inter
alia,”:
• assisting the agriculture and agri-food sector in the development of data management standards for traceability systems;
• continuing to support the development of traceability systems at the retail level; and
• providing funding and technical support for development of traceability and identity preservation (IP) systems, along the agri-food continuum to the retail level.
It is envisaged that the authorities will work with industry towards the development by industry of traceability systems that would:
• enable 80 percent of domestic products available at the retail level to be traceable through the agri-food continuum (Para. 21.1.4);
• allow the development by industry of traceability components for all products/commodities within the food quality and food-safety control systems (Para. 21.2.5).
1.3.4. Japan
Following the detection of BSE in Japanese domestic beef in 2001, new legislation mandated the implementation of a traceability system for domestic beef. The law established a farm-to-table traceability system based on a ten-digit cattle identification number assigned to each animal at birth (see Chapter 2 for more details).
1.4.
B
RIEF OVERVIEW OF INTERNATIONAL ISSUES AND DEBATES
1.
4
.
1
. WTO agreements
1.
4
.
1
.1. SPS agreement: its main provisions and principles
The Sanitary and Phytosanitary (SPS) agreement was signed in 1994, following the GATT Uruguay Round Negotiations (which also established the World Trade Organization [WTO]). The SPS agreement concerns food safety, animal health, and plant health regulations, which may affect – directly or indirectly – international trade of animals, plants and their products. Its objective is to ensure that governments do not use food safety and quarantine requirements as unjustified trade barriers to protect domestic agricultural industries from import competition.
To comply with the SPS agreement, the relevant measure must meet the following principles:
• principle of scientific objectivity: it must be based on scientific principles and must not be maintained without sufficient evidence (see Article 2.2 of SPS agreement in Annex 2);
1 In this agreement, "traceability" or "traceability system" are defined as “the ability to trace the history, application or location of an entity by means of recorded identifications”
• principle of non-discrimination between WTO members: it may not be applied in a way which arbitrarily or unjustifiably discriminates between countries where identical or similar conditions exist (see Article 2.3 of SPS agreement in Annex 2).
• principle of proportionality: it must be the least restrictive to trade as possible (see Article 5.6 of SPS agreement in Annex 2);
An importing country can choose the appropriate level of protection (ALOP) it considers necessary to protect human, animal, or plant health, but it must be consistently applied in various situations, such as for imported or domestically- produced products.
Where an international standard, guideline or recommendation is already in place, an SPS measure should be based on it, and it would then be presumed to be consistent with the SPS agreement. The Codex Alimentarius Commission, the International Plant Protection Convention (IPPC) and OIE have been recognized in article 3 paragraph 4 of the SPS Agreement as responsible for establishing such international standards, guidelines and recommendations. Otherwise, if an international standard does not exist or if a country uses a more stringent measure, the measure must be scientifically justified and based on a risk assessment (see Article 3 of SPS agreement in Annex 2).
1.
4
.
1
.2. TBT agreement and its main provisions
The Technical Barriers to Trade (TBT) agreement was first signed in 1979, and reviewed in 1994. This covers technical regulations and voluntary standards and addresses all aspects of food standards not related to SPS measures, including measures intended to protect the consumer against deception and economic fraud. For instance, with regard to food products, it applies to standards related to food composition, nutritional characteristics, food quality, food labelling, and so on.
• In order to be considered as acceptable and non-abusively discriminative, technical regulations must be the least trade restrictive possible, pursuant to article 2 paragraph 3, and they must fulfil a legitimate objective1 (see Annex 3).
The TBT agreement emphasizes the validity of international standards. Its Article 2.5 states that “whenever a technical regulation is prepared, adopted or applied for one of the legitimate objectives explicitly mentioned in paragraph 2, and is in accordance with relevant international standards, it shall be refutably presumed not to create an unnecessary obstacle to international trade.” Codex Alimentarius standards constitute such relevant international standards.
Equivalence
According to the equivalence principle (see Article 4 of the SPS agreement in Annex 2 and article 2 paragraph 7 of the TBT agreement), the exporting country can suggest using traceability as a tool for an “equivalent measure”, enabling it to meet the importing country’s requirements.
Regionalization
According to Article 6 of the SPS agreement (see Annex 2), importing countries can adapt their requirements depending on the pest or disease status of the region from which the imported product originates. They must recognize the concepts of pest- or disease-free areas and areas of low pest or disease prevalence. It is the responsibility of the exporting country to prove the disease or pest status of a specific area, and the importing country then evaluates the claim. The ability to trace animals or animal products using traceability systems would provide greater confidence in such claims.
Within the framework of the TBT agreement, traceability is not a legitimate objective in itself. Nevertheless, it could be used as a tool helping to fulfil such a legitimate objective. For instance, by guaranteeing the reliability of the labelling information, it could contribute to the prevention of deceptive practices, and could help to ensure fair practices in trade.
1.
4
.
2
. Codex Alimentarius negotiations
Traceability/product tracing issues are currently being discussed within the framework of Codex Alimentarius.
Following lengthy discussions in the Codex Executive Committee, Codex Alimentarius Commission (CAC), the Codex Committee on General Principles (CCGP) and the Codex Committee on Food Import and Export Inspection and Certification Systems (CCFICS), the 27th Session of CAC (July, 2004) adopted a definition for traceability/ product tracing, as follows: “the ability to follow the movement of a food through specified stage(s) of production, processing and distribution” (Codex Alimentarius, ALINORM 04/27/41).
However, some countries questioned the definition as it did not specify how the stages of production, processing and distribution would be specified and the current text might result in potential barriers to trade, and therefore proposed to add, at the end of the definition, the phrase “as far as possible”.
However, the definition was adopted as originally proposed, as delegations felt it reflected substantial discussion in CCGP and was necessary to further work on traceability/product tracing in Codex.
The Commission requested the CCFICS to present a proposal for new work on principles for the application of traceability/product tracing as a matter of priority, as certain countries maintained the view that the application of the definition should be deferred until the principles under development had been finalized.
The 13th session of CCFICS (Melbourne, Australia, December 2004) “agreed on the need to
develop principles for the application of traceability/product tracing in the context of food import and export inspection and certification systems, and to forward a project document for new work on the development of these principles, through the Executive Committee, to the 28th Session of the
Group would prepare proposed draft principles for circulation for comments at Step 3 and consideration at its 14th Session” (Codex Alimentarius, ALINORM, 05/28/30)
As evidenced above, Codex Alimentarius members have different (and sometimes opposite) opinions concerning traceability issues. This has led to interesting debates within the framework of Codex negotiations. It is worth highlighting a few issues and differences between member states. Concerning the coverage of possible Codex standards/guidelines on traceability, most Codex members seem to agree that traceability could be used as a tool for risk management with regard to food safety issues. Some members, however, are also concerned with the possibility of also using traceability as a tool to guarantee products’ labelling and authenticity (North America and South-West Pacific). Some developing countries fear that such traceability measures would actually disguise a technical barrier to trade. The United States of America and Canada have also raised concerns about traceability as applied to methods of production (such as the use of modern technology), as this kind of requirement raises technical barriers to trade. Other delegations (Europe, Near-East) suggested that both food safety and other matters necessary for ensuring fair practices in food trade (guarantee of the product authenticity and of the labelling) should be examined at the same time (Codex Alimentarius, ALINORM 03/33/A).
Because of the cost and complexity of traceability measures, many developing countries emphasize that they face significant difficulties in implementing traceability. They frequently underline that case studies should be done before implementing traceability in specific sectors (Codex Alimentarius, ALINORM 03/33/A; Codex Alimentarius, CX/GP 03/7).
Debates on the traceability issue within Codex may be just beginning, and are a good example of the various difficulties that need to be faced if final consensus and harmonization are desired. Debate of the costs and benefits of traceability
The following items have been cited as important considerations related to the design of a traceability / product tracing system to determine traceability costs and benefits:
• extent of the system (how far along the food production chain will traceability extend?);
• whether traceability regulations will apply to both domestic and imported products;
• complexity of the product and number of ingredients and sources of ingredients. It determines the size of product batches for which traceability would be economically feasible and desirable. If the sources are homogenous, traceability is less valuable than if they are not;
1.5.
B
IBLIOGRAPHY
Codex Alimentarius Commission, ALINORM 05/28/30. 2004. Report of the 13th session of the
Codex Committee on Food Import and Export Inspection and Certification Systems. Melbourne,
Codex Alimentarius Commission, 6-10 December.
Codex Alimentarius Commission, ALINORM 03/33/A. 2003. Report of the 18th session of
Codex Committee on General Principles. Paris, Codex Alimentarius Commission, 7–11 April.
Codex Alimentarius Commission, ALINORM 04/27/41. 2004. Report of the 27th session. Geneva, Codex Alimentarius Commission, 28 June–3 July.
CX/GP 03/7. 2003. Consideration of traceability/product tracing, Codex Committee on General
Principles, 18th Session. Paris, Codex Alimentarius Commission, 7–11 April.
CX/FICS 02/11/7. 2002. Discussion paper on traceability/product tracing in the context of food
import and export inspection and certification systems – Codex Committee on Food Import and Export Inspection and Certification Systems. Adelaide, Codex Alimentarius Commission, 2–6
December.
OECD. 2003. Costs and benefits of food regulations – working party on agricultural policies and
markets. AGR/CA/APM(2002)18/REV1, 17 February.
Wilson, D.W. & Beers, P.T. 2001. Global trade requirements and compliance with World Trade Organization agreements: the role of tracing animals and animal products. Revue scientifique et
Case studies
When international discussions and negotiations are held on traceability issues, many developing countries emphasize that they have to face important barriers – such as high costs – in order to implement traceability schemes. As a result, they frequently do not wish to go further in discussions aimed at drafting international standards about traceability.
The three following case studies will provide information on the possibilities and constraints of traceability implementation in developing countries in some specific sectors. Two case studies (production of bovine meat intended for export and pistachio production intended for export) are related to the use of traceability as a tool to control animal health and/or food safety hazards (see Paragraph 1.2.1). The results are given in Chapter 2 and Chapter 3. The final case study example (organic products intended for export) is related to the use of traceability as a tool to guarantee products’ authenticity and to provide customers with reliable information (see Paragraph 1.2.2): the results are given in Chapter 4.
Note: These case studies were conducted in October 2003, so as such, reflect conditions at that time.
2. Chapter
Traceability implementation in developing countries:
production of bovine meat intended for export
During the past several years, a series of food safety and animal disease crises have occurred throughout the world, and especially in the European Union (EU). These have included the announcement of the possible link between Bovine Spongiform Encephalopathy (BSE) and the new-variant Creutzfeldt–Jakob disease, as well as outbreaks of foot-and-mouth disease (FMD) and classical swine fever. Many consumers from developed countries have lost confidence in the safety of meat products (especially beef) and in the ability of regulatory agencies to protect the food supply. These crises have given rise to greater worldwide consumer concern over meat safety and have increased the desire for information on meat products.
The EU is leading most other regions in the development of mandatory traceability protocols for livestock and meat products. It is implementing stricter requirements and pressure on exporting countries. However, as noted in the examples below, the environment for the bovine meat production is actually very different between the EU countries and the developing countries, which causes the feasibility of the application of traceability to also differ greatly.
This chapter will address the production of bovine meat for export (not processed more than cutting), and especially for export to EU countries. It will focus particularly on issues related to animal identification. It will mainly look at six developing countries that are major bovine meat exporters: Brazil, Argentina, Uruguay, Paraguay, Botswana and Namibia.
The chapter begins by outlining the economic and sanitary backgrounds in these countries to provide an appreciation for the obstacles faced in implementing traceability schemes.
The table in Annex 5 provides a synthesis of this case study’s main findings on the possibilities and constraints of traceability implementation.
2.1.
E
CONOMIC
BACKGROUND:
DATA ON WORLD TRADE AND
BOVINE MEAT PRODUCTION IN DEVELOPING COUNTRIES
World trade of cattle meat has increased considerably since the 1960s: rising from 1.36 million tonnes in 1961 to 5.4–6.3 million tonnes in 1998 (Barcos, 2001). This increase underlines the necessity for implementing traceability systems in order to ascertain the origin and destination of products, for reasons related to safeguarding public and animal health, among others.
Chapter 2 will focus mainly on the primary fresh bovine meat exporters from developing countries: the four key exporters in South America (the Mercosur countries, Brazil, Argentina, Uruguay, and Paraguay) and the two principal exporters in Africa (Namibia and Botswana). Nevertheless, some
details about the situation in other countries can also shed light on the subject. As a result, we shall look in some instances at examples from Colombia, Chile and Malawi.
Tables 2.1 and 2.2 show data on cattle populations and bovine meat production and exports for these countries.
Table 2.1: Cattle population, beef and veal production in several developing countries
(Source: FAOSTAT Database)
Cattle population (head) Beef and veal production, 2001: quantity (tonnes) Argentina 48 850 000 2 452 000 Botswana 1 600 000 32 000 Brazil 176 400 000 6 671 000 Chile 3 876 000 217 640 Colombia 26 250 000 746 000 Paraguay 9 890 000 250 000 Namibia 2 500 000 57 788 Uruguay 10 600 000 317 000
Table 2.2: Data on bovine meat exports in several developing countries
(Source: FAOSTAT Database)
Meat bovine fresh exports, 2001
Quantity (tonnes) Value (US$1 000s)
Argentina 42 822 113 729 Botswana 20 516 90 828 Brazil 368 287 738 805 Chile 72 410 Colombia 6 124 16 438 Namibia 10 267 26 484 Paraguay 44 604 76 031 Uruguay 103 898 209 604
Bovine meat export trade with the European Union (EU) is a priority for the South American countries cited above: the most valuable meat cuts are sold to the EU countries at premium prices. In the Mercosur countries for instance, Argentina’s main export market is the EU, and Brazil (responsible for 13 percent of the world beef production) also focuses its exports on the EU. Uruguay’s and Paraguay’s most valuable beef cuts are also exported to the EU, so this market is, not surprisingly, considered crucial for all four countries. While livestock and meat used to constitute a by far smaller percentage of agricultural exports from Chile than from the four Mercosur countries, livestock production is expected to surpass national demand by 2008. As a result, the Chilean Agricultural Ministry and livestock industry leaders hope to develop exports via Chile’s multiple free trade agreements. For instance, free trade agreement with the EU went into effect in February 2003.
Botswana and Namibia are both Africa, Caribbean, Pacific (ACP) countries1 and the primary
bovine meat producers among African developing producers. As a consequence, they have favoured trade relationships with the EU. In Namibia, about 70 percent of people’s livelihoods depend on the export-oriented meat industry; Botswana is developing its beef production as an
1 African-Caribbean-Pacific (ACP) countries have specific aid, trade and political relations with the EU. The ACP-EU cooperation dates back to 1957 and the Rome Treaty; it was established in order promote economic and social development and to establish close economic relations. Being ACP countries, Namibia’s and Botswana main trading partner and export market is the EU.
alternative source of income to diamond production. As a signatory of the Lomé convention1, the
EU is Botswana’s biggest export market: Botswana has an export quota of 18 100 tonnes per
annum to the EU, and approximately 80–90 percent of Botswana’s export beef is indeed sent to
the EU.
As a result, exports to the EU are considered as a priority for all these countries. It is worth noting here, that, in the developing countries, cattle-breeding conditions are completely different and far more extensive than cattle breeding conditions in Europe, where small numbers of animals are raised in small, controlled conditions. Beef production takes place on extensive grass pastures in developing countries, which makes identification and maintenance of calving, health and other records more difficult.
2.2.
S
ANITARY AND REGULATORY BACKGROUND
2.
2
.1. Brief overview of the animal health situation in the
developing countries considered
The animal health situation of a country is determined by its status regarding various animal diseases, such as FMD, BSE, rinderpest, contagious bovine pleuropneumonia, brucellosis, swine fever, etc, and so on). FMD and BSE-related issues are particularly important within the framework of this study as these diseases are of great concern to producers and consumers in importing countries, especially the EU. We now look in detail at each country’s status with regard to FMD and BSE.
2.
2
.1.1.
FMD and FMD status
Each May, during its general session, OIE establishes an official list of FMD-free countries and zones (List of foot and mouth disease free countries, Resolution No. XX, Recognition of the FMD status of member countries). Table 2.3 shows the FMD status of the developing countries that will be examined in this case study (at the time the case study was conducted):
Table 2.3: OIE FMD status
(Source: OIE website, www.oie.int)
Argentina: zone situated south of the 42 o parallel South “FMD free zone, where vaccination is not
practised”
Argentina: zone situated north to the 42 o parallel South “FMD free country with vaccination”
(status restored, 7 July 2003)
Botswana “FMD free country without vaccination” (status suspended with effect from 20 Jan. 2003)
Brazil: states of Bahia, Espírito Santo, Mato Grosso, Mato Grosso do Sul, Minas Gerais, Paraná, Rio de Janeiro, Rio Grande do Sul, Santa Catarina, São Paulo, Sergipe, Tocantins, the Federal District, and Rondônia.
“FMD free zone, where vaccination is practised”
Chile “FMD free country, where vaccination is not practised”
Colombia: Northwest region of Choco Department “FMD free zone, where vaccination is not practised”
Namibia: zone designated by the Delegate of Namibia in a document addressed to the Director General on 6 Feb. 1997
“FMD free zone, where vaccination is not practised”
Paraguay “FMD free country without vaccination” (status suspended with effect from 4 Nov 2002)
Uruguay “FMD free country with vaccination” (status restored, 22 May 2003)
Only meat coming from “FMD-free without vaccination” zones is eligible for access to the most demanding export markets and sold at premium prices. Therefore, the product coming from “FMD-free without vaccination” zones must be segregated from the product coming from “FMD-“FMD-free with vaccination” zones. Only certain parts of Argentina, Colombia and Namibia are recognized as FMD free without vaccination. Indeed, many FMD outbreaks have occurred recently in most of the countries in this case study: in Argentina, 2 565 outbreaks were identified from July 2000 to January 2002, resulting in fresh meat imports bans and restrictions put in place by importing countries. Uruguay remained FMD free for several years in the 1990s and had been declared “FMD free without vaccination” by the OIE in May 1996. However, following FMD outbreaks in 2000 and 2001, it lost its “FMD-free country without vaccination” status and was submitted to export restrictions by the EU. On 22 May 2003, it regained an “FMD-free country with vaccination status”. In November 2002, an FMD outbreak occurred also in Paraguay, close to Brazil’s border, resulting in the loss of Paraguay’s status as “FMD free country without vaccination”. Botswana’s “FMD free country without vaccination” status was also recently suspended (January 2003).
Animal diseases (such as FMD) levels are very low in Namibia and occur in only a small region limited to the extreme north of the country. At the time this case study was conducted, Chile was the only South American beef-exporting nation to have been entirely classified as “FMD-free without vaccination”. All the hopes of the authorities concerning meat exports expansion are based on this status.
A poor control of cattle movement and a lack of traceability systems are often blamed for the spread of FMD. This highlights the necessity of implementing traceability systems in the main beef-exporting nations.
2.
2
.1.2.
BSE
Third countries or regions wishing to export into the EU are also subjected to the determination of their BSE status on the basis of a risk assessment. They are classified into five different categories (see Paragraph 2.2.3.5.). According to the provisional “BSE status” classification, Argentina, Brazil, Uruguay, Paraguay, Chile, Botswana, Namibia and Swaziland have been classified as GBR (Geographical BSE Risk) I by the Scientific Steering Committee (SSC); they are part of the countries included in the list of Annex XI of Regulation [EC] No. 999/2001 as last amended by Commission Regulation (EC) No 1003/2003 and are thus considered as “countries free of BSE”.
2.
2
.1.3.
FVO inspections
As these countries are important meat exporters to the EU, the Food and Veterinary Office (FVO) of the European Commission carries out inspection missions in these countries. For instance, several missions were carried out in Argentina, Brazil, Paraguay, Uruguay, and Botswana in order to:
• evaluate the animal health situation;
• assess the systems in place;
• determine the controls and measures taken by the competent authorities to address FMD issues;
• to carry out general reviews of BSE and BSE-related control measures in place.
2.
2
.2. Implementation of new traceability standards in
developed countries: a brief overview
2.
2
.2.2.
The situation in other developed countries
Japan
As part of Japan’s ongoing response to the detection of BSE in domestic beef in 2001, a new legislation mandates the implementation of a traceability system for domestic beef. This law established a farm-to-table traceability system based on a ten-digit cattle identification number assigned to each animal at birth. The system built on an existing ear-tag identification programme implemented shortly after the detection of BSE.
The traceability requirements also apply to imported cattle once the animal has reached Japan. The same labelling requirements as for domestic beef would apply for exporting countries with a traceability system. Countries without a traceability system require a label stating “This beef is from a country with no traceability program”. The domestic law went into effect in June 2003 and full implementation is expected in December 2004. Each piece of meat sold in Japan will have a code on the label corresponding to the individual animal identification number, making it possible to track the date of birth, gender, breed, producer(s), transfer records, date of slaughter or death, date of import, etc. (USDA, 7/1/2003).
On 20 May 2003, one case of mad cow disease was discovered in Canada. As a consequence, the United States of America and Japan banned all Canadian beef and cattle. Japan then requested its imports of US beef to be certified as free of Canadian product.
Australia
In Australia, concern over food safety in Japan and in other export markets appears to be regarded as a marketing opportunity – this is underlined by Australia’s move towards full traceability. Currently, Australian producers apply a registered tail tag number identifying their ranch on all cattle leaving that ranch. The current system allows trace-back of carcasses and cuts to the ranch of origin.
The Australian beef industry plans to soon begin using a fully integrated, electronic system that links three technologies:
• the National Livestock Identification Scheme (NLIS), which uses radio frequency tags to identify and track cattle;
• the European article number (EAN) bar-coding technology already used worldwide in the processing and retail sectors;
• the electronic data interchange (EDI), an electronic messaging system.
The State of Victoria has made electronic ear tagging compulsory for all cattle born on or after 1 January 2002 except for calves less than six weeks old sold for slaughter. Eventually, all cattle will be identified and all livestock transactions will be registered into the NLIS database. Some Australian ranchers are resisting the idea of a compulsory system, citing cost, difficulty of implementation because of large ranch sizes, and problems with the new technology. However, others are adopting the technology because it will be required for beef exports to the European Union (Clemens and Babcock, 2002).
The United States of America
Although the United States of America is more reluctant to implement traceability systems than the EU countries, discussions concerning traceability are currently under way.
It was anticipated that a national animal identification plan would be unveiled by a public–private team (USDA’s Animal and Plant Health Inspection Service, state veterinary officers, livestock industry groups) for commenting and reviewing by October 2003. The first phase of the plan will require the setting-up of standardized premises identification numbers for all operators, processing plants, markets, and so on. The second phase, which should be in place by 2006, would necessitate individual identification for cattle in trade.
Another recommendation is that the movement of animal units or individuals is recorded into a central database or a seamlessly linked database infrastructure. The aim is to develop a national programme for animal health purposes that would be able to identify all premises and animals that had direct contact with a foreign animal disease within 48 hours of its discovery. This plan has been worked on for several years, but the recent BSE case in Canada and the resurgence of bovine tuberculosis in some states in the USA have reinforced the need to introduce it: the importance of trace-back is recognized broadly (USDA, 2003) (Clapp, 2003a).
Canada
Canada is also studying the implementation of a traceability system.
2.
2
.3. Requests for export to the EU countries
As the EU is the main export market for all the developing countries considered here, it is worth giving details of the conditions these countries must comply with in order to export fresh bovine meat to the EU countries (Barcos, 2001; Ammendrup and Füssel, 2001).
2.
2
.3.1.
Establishment of lists of authorized countries
Under the provisions of Directive 72/462/CEE (modified several times), taking into account the health situation in third countries, the Council draws up a list of the third countries or parts of the countries from which the importation into the EU of bovine fresh meat is authorized. This list is established by taking into account:
