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.
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