FSAI Brexit Event Presenter: Aoife Moran Date: March 13, 2019 - The Food Safety Authority of Ireland
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FSAI Brexit Event Presenter: Aoife Moran Date: March 13, 2019
Overview Introduction • Introduction to Food Drink Ireland • Ireland – UK trading relationship • Stakeholder Engagement • Preparedness • Regulatory divergence after Brexit • Specific areas of concern • Brexit – Key asks for Agri-food FDI Regulatory and Environment Committee Meeting FSAI Brexit Seminar: 13 March 2019
Tackling your
industry
Headlineneeds is in Body copy is in Arial Regular and is set at
16pt. Do not over-crowd slides with text and
Competitive, sustainable
primary production and
visuals.
Arial Bold and manufacturing
Maintain a world class
Support investment with
Main trade association for the tax measures and
is set at 32pt
food and drink industry in Ireland
food safety regime
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pretium nec. Sed at est tempor, sagittis urna
finance
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150 food and drink members – dolor, sit amet condimentum orci mattis vitae.
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manufacturers and suppliers Avoid discriminatory Effective
measuresvestibulum
on food and mattis venenatis. Donec turpis
implementation of
drink grocery sector
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legislation
sem.
Minimise economic disturbance of Investment in
Brexit and maintain access to international market
FDI Regulatory
Title of Presentation:
and Environment
Lorem IpsumCommittee
lpsimna InMeeting
Arial 9pt UK market development
Industry led focus on research,
innovation and skills development
Dairy
Food Chain
Product
Associations
Consumer Renderers
Foods Petfood
Cold Stores
Bread
FDI represents over Breakfast
Meat Cereals
150 companies Confectionery
across meat, dairy, Beverages
consumer foods and
Industry
alcoholic and non- Initiatives
alcoholic beverages
Food Safety & Regulatory Affairs
FSAI Brexit Seminar: 13 March 2019
FDI • Committee Chairperson – Vivienne
Crowley (Glanbia)
• Approximately 180 Committee members
Regulatory • Representative from Food Safety
Authority of Ireland present
and • Guest Presenters
Environment • Current Priorities:
• Food Safety
Committee • Labelling
• Nutrition and Health
• Brexit
FSAI Brexit Seminar: 13 March 2019
Irish food and drink trade flows
• Irish Exports - €13.6bn (2017) (€5.2bn to UK) EU 27 / UK food
• UK Exports to Ireland - €4.1bn (2017) and drink trade
• 52% of beef exports go to UK flows - €45bn
• About 22% of dairy exports
• 53% of cheese, 29% of butter and 12% of SMP
• 80,000 tonnes of cheddar cheese
- about 80% of all cheddar imported by the UK
• 66% of prepared consumer foods exports
• Route to market - 850,000 trucks travel by ferry
between Ireland and Britain (45% are perishable food and drink)
• Vast majority of perishable products to Continental Europe transit through the
UK (the ‘UK Land-bridge’), in certain categories this can exceed 90%
FSAI Brexit Seminar: 13 March 2019
Potential Disruption to Logistics Clearance through Dublin Port • Agri-Food imports from UK will have to undergo SPS checks • Documentary, ID and Physical checks required by EU legislation • The level of checks intended to be performed must be accompanied by the necessary resourcing Landbridge - Transit Arrangements • UK is major route for Agri-Food traffic between Ireland and Continent (both ways) • Massive disruption in Dover-Calais channel expected • Need for clarity on transit arrangements, particularly SPS provisions FSAI Brexit Seminar: 13 March 2019
Regulatory Divergence after Brexit
Regulatory divergence after Brexit – Stakeholder Engagement FSAI Brexit Seminar: 13 March 2019
Regulatory divergence– challenges
EU Law
• General Food Law, incl. secondary legislation More than 700 new EU laws
• Official food and feed controls have been introduced into the
Over • RASFF U.K. since the Brexit
• EFSA referendum, adding to the
2,000 • Applications (e.g. novel foods, health claims, estimated 19,000 EU
food improvement agents)
(EU) • Consumer information regulations, directives and
other rules that are already
• Common Agricultural Policy (CAP)
laws • EU quality certification schemes (PDO, PGI, part of U.K. law. If that rate
TSG, organic, etc.) continues, a further 1,260
affecting European laws will have
‘Soft’ policy (mixed competence)
agri- • Nutrition and public health policy
become applicable in the U.K.
by the end of March 2019,
food! • Audio-visual Media Services Directive
(AVMSD) when the U.K. leaves the EU.
• Unfair Commercial Practices (UCP) Directive Politico Brexit Files, 25th
June 2017
‘Emerging’ EU policy/regulatory fields
• Sustainability (food waste, packaging, animal
welfare)
FSAI Brexit Seminar: 13 March 2019Preparedness Notices FSAI Brexit Seminar: 13 March 2019
Some specific areas of concern FSAI Brexit Seminar: 13 March 2019
Labelling – Examples
Irish/EU Regulations UK – No Deal Scenario
EU specific logo Not allowed from 29
March 2019
Must have UK business
EU Business address Group B, address
RM 1123,
Sligo,
Ireland
Continued use of EU
Any Comments or questions? IE mark until end 2020
EU assigned health Please Call Mon-Fri – 8am – 6pm, 1234
1850 000 0000 or Visit Group B EC
mark (foods of animal soups.ie If exporting to EU, must
origin) use new UK health mark
FSAI Brexit Seminar: 13 March 2019Labelling – Uncertainties
Irish/EU Regulations Instant Vegetable Broth
Legal Name Ingredients: Semolina from durum wheat, dehydrated vegetables in varying proportions (30%) (onions, corn, carrots, tomato,
celery, garlic, green beans), Salt, dried butter (Milk), Autolyzed yeast extract, molasses, spices, non-fat milk, natural flavours,
honey, turmeric spice & colour
Ingredient List Allergy Advice: for allergen advice including cereals containing gluten see ingredients in bold
Allergen Information Contains 3 sachets, Store in a cool dry place
Instructions:
1. Empty the contents
Instructions for use
Nutrition declaration and of the sachet into a
mug
nutrients per portion 2. Pour in 190ml of
boiling water, let
settle for 2 min and
enjoy
Caution hot
Best Before End Minimum date of
Additional Supplementary 09/2019 durability
Information
FSAI Brexit Seminar: 13 March 2019Labelling – Uncertainties
White Paper July 2018 –
• There are wider food policy rules that set marketing and labelling requirements.
It is not necessary to check these rules are met at the border, because they do
not govern the way in which products are produced, but instead determine how
they are presented to consumers. These rules are most effectively enforced on
the market, and as such it is not necessary to incorporate them into the
common rulebook.
FSAI Brexit Seminar: 13 March 2019Nutrition and Health Claims
• In Ireland/European Union, Nutrition and Health claims are laid out by Regulation (EC) No
1924/2006 – No Change
• No Deal - The Nutrition (Amendment etc.) (EU Exit) Regulations 2019
• Law governing:
• nutrition and health claims,
• the addition of vitamins,
• minerals and other substances to foods,
• and the composition and labelling of foods for specific groups and food supplements
• Continue the existing regulatory regime closely – possible for future modifications to lists,
annexes, registers
• Changes technical in nature – eg. amendment of EU-specific references
• Guidance being developed – confirm process for making claims and submitting scientific
dossiers
FSAI Brexit Seminar: 13 March 2019Nutrition and Health Claims
• If the UK can no longer access advice from EFSA, the government will establish an ‘expert
committee’ to take on this role
• For nutrition and health claims, the UK Government is in the process of establishing the UK
Nutrition and Health Claims Committee (UKNHCC), which will be a committee of Public Health
England (PHE).
• The UKNHCC’s role will replace that of the European Food Safety Authority (EFSA) Panel on
Nutrition, Novel Foods and Food Allergens (NDA) to provide evidence-based scientific opinion
on any new nutrition and health claims made within the UK post-exit.
FSAI Brexit Seminar: 13 March 2019Additional points for consideration Food Contact Materials • Declarations of compliance for FCM notified by the UK Ingredients • Permissible Food Improvement Agents – additives, flavourings, enzymes Pesticides and Biocides • Differing MRLs in the EU and UK Voluntary Schemes • Example – Front of Pack Labelling FSAI Brexit Seminar: 13 March 2019
Brexit – Key Asks for Agri-food
Clarity/Grace Period – No Deal
• In the absence certainty, companies are limited in the changes they can make, eg. labelling
• Such changes take time to implement, significantly longer than 2/3 weeks
Transition Period of Sufficient Duration
• Will take time to agree a future trading relationship
• Companies need time to adapt to new arrangements
Future Trading Relationship
• Establish a mechanism that will allow for keeping EU and UK food standards under the
scope of veterinary legislation as well as under food law in general, as closely aligned as
possible
• Introduce a mutually acceptable food inspection system, regarding imports from third
countries
• Ensure a continued close relationship between the UK and EFSA.
FSAI Brexit Seminar: 13 March 2019Useful Links European Commission Brexit Preparedness Notices EU food law https://ec.europa.eu/info/sites/info/files/file_import/eu_food_law_en.pdf Biocidal products https://ec.europa.eu/info/sites/info/files/file_import/biocidal-product_en.pdf Plant protection products https://ec.europa.eu/info/sites/info/files/file_import/plant_protection_products_en.pdf Exploitation and marketing of natural mineral waters https://ec.europa.eu/info/sites/info/files/file_import/natural_mineral_waters_en.pdf FSAI Brexit Seminar: 13 March 2019
Useful Links UK Department of Environment, Food and Rural Affairs Food labelling changes after Brexit https://www.gov.uk/guidance/food-labelling-changes-after-brexit Importing animals, animal products and high-risk food and feed not of animal origin after EU Exit https://www.gov.uk/guidance/importing-animals-animal-products-and-high-risk-food-and-feed-not-of- animal-origin-after-eu-exit UK Department of Health and Social Care The Nutrition (Amendment etc.) (EU Exit) Regulations 2019 – Draft Legislation https://www.legislation.gov.uk/ukdsi/2019/9780111179864/contents The Nutrition (Amendment etc.) (EU Exit) Regulations 2019 – Consultation Response https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/7812 22/The_Nutrition_Amendment_-_consultation_response.pdf FSAI Brexit Seminar: 13 March 2019
Thank you FSAI Brexit Seminar: 13 March 2019
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