FSAI Brexit Event. Presenter: Aoife Moran Date: March 13, 2019
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1 FSAI Brexit Event Presenter: Aoife Moran Date: March 13, 2019
2 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
3 Tackling your industry Headline needs is in Arial Bold and Main trade association for the is set at 32pt food and drink industry in Ireland 150 food and drink members manufacturers and suppliers Part of Ibec Body copy is in Arial Regular and is set at 16pt. Do not over-crowd Competitive, sustainable slides with text and visuals. Maintain a world class food safety regime Morbi tristique ipsum dui, eget placerat finance velit pretium nec. Sed at est tempor, sagittis urna at, consequat purus. Integer dictum lacus dolor, sit amet condimentum orci mattis vitae. Donec convallis tempus nisi. Nunc Avoid discriminatory measures on food and primary production and manufacturing Support investment with tax measures and Effective implementation of grocery sector legislation vestibulum mattis venenatis. Donec turpis drink justo, tristique vel egestas in, scelerisque at sem. FDI Title Regulatory of Presentation: and Environment Lorem Ipsum Committee lpsimna In Meeting Arial 9pt Minimise economic disturbance of Brexit and maintain access to UK market Investment in international market development Industry led focus on research, innovation and skills development
4 FDI represents over 150 companies across meat, dairy, consumer foods and alcoholic and nonalcoholic beverages Dairy Consumer Foods Meat Industry Initiatives Food Chain Product Associations Renderers Petfood Cold Stores Bread Breakfast Cereals Confectionery Beverages Food Safety & Regulatory Affairs
5 FDI Regulatory and Environment Committee Committee Chairperson Vivienne Crowley (Glanbia) Approximately 180 Committee members Representative from Food Safety Authority of Ireland present Guest Presenters Current Priorities: Food Safety Labelling Nutrition and Health Brexit
6 Irish food and drink trade flows Irish Exports bn (2017) ( 5.2bn to UK) UK Exports to Ireland - 4.1bn (2017) 52% of beef exports go to UK 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 EU 27 / UK food and drink trade flows - 45bn 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%
7 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
8 Regulatory Divergence after Brexit
9 Regulatory divergence after Brexit Stakeholder Engagement
10 Regulatory divergence challenges Over 2,000 (EU) laws affecting agrifood! EU Law General Food Law, incl. secondary legislation Official food and feed controls RASFF EFSA Applications (e.g. novel foods, health claims, food improvement agents) Consumer information Common Agricultural Policy (CAP) EU quality certification schemes (PDO, PGI, TSG, organic, etc.) Soft policy (mixed competence) Nutrition and public health policy Audio-visual Media Services Directive (AVMSD) Unfair Commercial Practices (UCP) Directive Emerging EU policy/regulatory fields Sustainability (food waste, packaging, animal welfare) More than 700 new EU laws have been introduced into the U.K. since the Brexit referendum, adding to the estimated 19,000 EU regulations, directives and other rules that are already part of U.K. law. If that rate continues, a further 1,260 European laws will have become applicable in the U.K. by the end of March 2019, when the U.K. leaves the EU. Politico Brexit Files, 25 th June 2017
11 Preparedness Notices
12 Some specific areas of concern
13 Labelling Examples Irish/EU Regulations UK No Deal Scenario EU specific logo Not allowed from 29 March 2019 EU Business address EU assigned health mark (foods of animal origin) Group B, RM 1123, Sligo, Ireland Any Comments or questions? Please Call Mon-Fri 8am 6pm, or Visit Group B soups.ie IE 1234 EC Must have UK business address Continued use of EU mark until end 2020 If exporting to EU, must use new UK health mark
14 Labelling Uncertainties Irish/EU Regulations Legal Name Ingredient List Allergen Information Instant Vegetable Broth 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 Allergy Advice: for allergen advice including cereals containing gluten see ingredients in bold Contains 3 sachets, Store in a cool dry place Nutrition declaration and nutrients per portion Additional Supplementary Information Instructions: 1. Empty the contents of the sachet into a mug 2. Pour in 190ml of boiling water, let settle for 2 min and enjoy Caution hot Best Before End 09/2019 Instructions for use Minimum date of durability
15 Labelling 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.
16 Nutrition 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
17 Nutrition 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.
18 Additional 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
19 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.
20 Useful Links European Commission Brexit Preparedness Notices EU food law Biocidal products Plant protection products Exploitation and marketing of natural mineral waters
21 Useful Links UK Department of Environment, Food and Rural Affairs Food labelling changes after Brexit 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 The Nutrition (Amendment etc.) (EU Exit) Regulations 2019 Consultation Response 22/The_Nutrition_Amendment_-_consultation_response.pdf
22 Thank you
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