Exporting to the EU: Don't let habits cost you your market

 

Exporting to the EU: Don't let habits cost you your market

EU regulations are very clear and aim to protect consumer health. However, sometimes Vietnamese businesses are 'careless' which can lead to import bans.

Dr. Ngo Xuan Nam - Deputy Director of the Vietnam National Information and Enquiry Point on Epidemiology and Animal and Plant Quarantine (Vietnam SPS Office), Ministry of Agriculture and Environment - had an interview with reporters of the Industry and Trade Newspaper on this issue.

Looks delicious and beautiful but not really

– The EU is an important market for Vietnamese agricultural and aquatic products in general and processed foods in particular. However, many businesses are hesitant because this is not an easy market. What is your comment on this?

Dr. Ngo Xuan Nam: The EU is a bloc of countries with high and very strict food safety standards in the world – largely thanks to the EU’s strong laws, ensuring safe food for consumers. The Rapid Alert System for Food and Feed (RASFF) is a tool to ensure information that allows for rapid response when risks to public health are detected in the food chain.

The general conditions for introducing a new food into the EU are as follows: The food does not pose a risk to human health, based on available scientific evidence; the intended use of the food does not mislead the consumer, especially when the food is used to replace another food and there is a significant change in nutritional value; when the food is used to replace another food, it does not cause a nutritional disadvantage compared to the previous food.

Regulation (EU) 2017/2470 of 20 December 2017 establishes the Union’s list of novel foods in accordance with Regulation (EU) 2015/2283 of 25 November 2015 on novel foods. In addition, in Regulation (EU) 2015/2283, the term “novel food” includes “traditional third country foods”, i.e. foods traditionally consumed in countries outside the European Union. All novel foods must undergo a food safety assessment before they can be traded within the EU – having been shown to be safe for consumption for at least 25 years.

Vietnam's agricultural products exported to the EU market are new foods including dried basil seeds and fruit-flavored soft drinks containing basil seeds; apple snail meat...

Regarding the dried basil seed product, Vietnam has received two warnings on the RASFF system for this product, with the reason being “unlicensed new food”. The “snail meat” product exported from Vietnam received a warning from the EU with the reason being “unlicensed new food”.

According to Regulation (EU) 2015/2283, snail meat belongs to the “traditional food from a third country” category, because it has been consumed in the Vietnamese market but not yet used in the European market. Snail meat needs to be registered for a license and undergo a food safety assessment process to be included in the European Union’s licensing list.

In addition, Regulation (EU) 1333/2008 of the European Union dated 16/12/2008 on food additives defined “food additives” as follows: “Food additives” are any substances which are not normally food and are not used as a main ingredient of food. Whether or not they have nutritional value, if they are intentionally added to food for technological purposes (such as production, processing, preservation, packaging, transport, etc.), they or their by-products may become part of the food, directly or indirectly.

– Can you share a specific story to note for businesses when exporting processed foods to this market?

Dr. Ngo Xuan Nam: Many food manufacturers, including those in Vietnam, use eggs in their breaded shrimp recipes. According to consumer habits and tastes in many markets, when processing breaded shrimp, manufacturers often add eggs to create a sticky layer.

Eggs help the batter adhere better to the shrimp, preventing the batter from falling off when frying. Eggs also help the breadcrumbs or tempura batter have a crispier texture. The light fatty taste of eggs helps the batter to be less bland, creating a delicious feeling. In addition, egg yolks help the batter have a more beautiful yellow color, while also keeping the batter moist, preventing the product from becoming dry and hard.

However, egg protein can be considered an allergen. In addition, eggs are also a product of animal origin, when present in a composite product exported to the EU market, they must comply with Regulation (EU) 2022/2292, effective from 15/12/2022. Breaded shrimp is also a composite product, because it contains flour (of plant origin) and has changed the characteristics of shrimp (of animal origin).

Currently, the EU only allows egg products from approved third countries to be exported to the EU (such as the United States, Japan, Brazil, etc.). Vietnam wants to export breaded shrimp products with eggs to the EU, it must use eggs originating from the above countries.

Another issue to note is that according to Article 21 of Regulation (EU) No. 1169/2011, eggs are included in the group of allergenic products and must be declared on the product label. If not, the European Union's Rapid Alert System for Food and Feed (RASFF) will issue a warning to the exporting country, along with the necessary measures.

Failure to declare or incorrect declaration of allergens can result in product recalls or import bans into the EU. In the past, there have been many cases of frozen breaded shrimp not declaring egg in the breading, leading to product recalls in Europe. This not only causes economic losses to businesses, but also the entire industry can be affected if the violation is repeated.

Businesses need to carefully study market regulations.

– EU regulations on food safety and animal and plant quarantine often change continuously. What recommendations do you have for businesses exporting to this market?

Dr. Ngo Xuan Nam: Regulations on food safety and animal and plant quarantine of the EU in particular and members of the World Trade Organization (WTO) in general often change, therefore, the Vietnam SPS Office recommends that businesses carefully study EU regulations, especially issues related to food safety, labeling, Regulation (EU) 1169/2011 on providing food information to consumers, as well as the very new Regulation (EU) 2022/2292 on composite products.

Before packaging for export, businesses must label the product fully and accurately, ensuring that all allergens contained in the product are clearly listed, helping consumers to identify and avoid them.

At the same time, strictly control quality through establishing quality control procedures to ensure there is no cross-contamination or omission in the declaration of allergens.

Strict compliance with regulations on allergen declaration, as well as origin requirements for synthetic products, not only helps businesses avoid legal risks but also enhances reputation and ensures consumer safety.

Thank you!

The EU regularly amends and supplements regulations and requirements for the import of agricultural, aquatic and food products. Recently, this market announced that it will apply for the first time the level of inorganic arsenic residue in fish and some aquatic products. Therefore, exporting enterprises need to proactively monitor and update information about the EU market, thereby having plans to adapt and adjust production accordingly.

Detailed information on EU regulations is updated on the website of the Vietnam SPS Office at: http://www.spsvietnam.gov.vn/ or businesses can send specific requests to the official mailbox: spsvietnam@mae.gov.vn for answers.