Jerome Erbacher (Jerome.Erbacher@noaa.gov)
30 Nov 1999 13:51:34 -0500
Below is a report just in from Europe on seafood import problems with
tips on how to do it.
The report is by Eric Fleury
US Mission to the EU
NMFS European representative
____________________________________
Jerome E. Erbacher
International Trade Specialist
Web Master Fx1
Please visit our Web Page At:
http://www.nmfs.gov/trade/
Tel: 301-713-2379 x144
Fax: 301-713-2384
E-mail: Jerome.Erbacher@noaa.gov
Mail: U.S. Department of Commerce
National Oceanic and Atmospheric Administration
National Marine Fisheries Service
Office of Industry and Trade
SSMC 3 Room 3670
1315 East West Highway
Silver Spring, Maryland 20910
____________________Forward Header_____________________
Subject: EU - import problems
Author: Eric.Fleury@mail.doc.gov
Date: 11/30/1999 11:51 AM
1997 was a record year with an average of at least 2 containers blocked a week.
1998 was pretty good as the beginning of 1999 (a French vet even called me to
acknowledge our efforts) with only 10 problems. Unfortunately we are again on
the wrong path. Since the beginning of November 99, I intervened in more than 30
cases. Few shipments have been rejected, but some were delayed by up to 2 weeks.
In few cases, everything has been done correctly, but the establishment was not
yet on the up-dated list sent by FDA. However in most cases, the problem should
have been avoided. Few simple steps would save a lot of money and headaches to
exporters and importers.
1) Labels must be checked against information written on the certificates.
Especially when goods were stored in a public coldstorage, further more when
fish have been re-packed there, double-check labeling. Too often, there are 2
CFNs on the same cartons; or the CFN on the carton is the coldstorage number
(this is right if they re-packed) but the certificate indicates a processing
plant (where goods were first processed). Too often, nobody is able to say
exactly what is in the container, except the type of product !
2) For frozen fish, when a shipment includes goods from several processing
establishments or different species, I suggest that at least one carton of each
establishment/species is placed at the door of the container. This is to avoid
unloading the container in a port when it should have been trucked to its final
destination, just to find at least one carton of the other(s)
establishment(s)/species.
3) When pre-printed boxes bearing all CFNs of the group are used, one must make
sure that one CFN is marked.
4) Certificates must be fully completed. Do not forget one mention such as the
temperature. Indicate all types of products included in the shipment (for ex.
H&G and fillets). The name and address of the consignee must be indicated and it
must be a company established within the EU.
5) When preparing labels or printed boxes, the CFN must be controlled: is there
7
digits?, is it the exact number? A very simple question, but it happened 3 times
in the last month.
It has never been a problem for US authorities (FDA or NMFS) to issue a new
certificate that supersedes a previous one. But it takes at least 3-4 days to
have the new original delivered to European ports. That means demurrage,
coldstorage fees, etc.
One more time, the most important labeling information are : country of origin
approval number
Those two items must be written or printed "indelibly". The most desirable way
would be to have them pre-printed on packages/cartons. In cases where stick-on
labels may be used, they must not be easily destructible when attempts are made
to remove them, i.e. tear into small pieces.
Until recently, not all Member States were fully implementing inspection
requirements. Especially the identity check was not done as required by the EU
legislation. Since September, ALL Member States inspectors check labels for the
two mentions. Without those mentions, it is impossible to have goods cleared.
All those shipments will have to be returned to the USA for re-labeling before
going back. It is not because some Member States did not enforced the EU
legislation in the past, that it doesn't exist. On purpose, I never made any
differences based on the actual enforcement by National authorities. Now the UK,
Denmark, Germany, etc. do the same thing than France or Spain. The Netherlands
and Belgium are now the more difficult.
Those two mentions (USA, CFN) must be on all individual packages as defined by
Directive 79/112:
Quote
" pre-packaged foodstuff " shall mean any single item for presentation as such
to the ultimate consumer, consisting of a foodstuff and the packaging into which
it was put before being offered for sale, whether such packaging encloses the
foodstuff completely or only partially, but in any case in such a way that the
contents cannot be altered without opening or changing the packaging.
Unquote
A consumer is, for this legislation, a person, or a caterer for example (not a
processing plant).
Best regards
Eric Fleury
US Mission to the EU
NMFS European representative
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