EuropeAid /C/SV/UA Output 2: Standartization and Certification EU expert: Cornelis Sonneveld NLTE: PhD. Evgenia Novozhilova

Background As of 2003 in the Agro-Industrial Complex the number of all standards is equal to 112, incl. 16 harmonized standards (14 % out of all amount). As of January, 15, 2005 the number of harmonized standards in Ukraine is 23%.

Background For integration of Ukraine into the European Community about 80 % of standards (near 5000 national standards) have to be harmonized with the EU legislation/ CAC requirements.

Background Obligatory certification in Ukraine is performed exclusively by authorities of the state certification system, which doesn’t correspond to world practice and principles of a modern market economy. Establishment of Multiple Agency System for food control with separate activities and responsibilities

Milk and Meat Quality Private sector enumerates almost 3 Mln. cows (67 %), in public sector – 1.2 Mln. heads Marketability of produced milk is extremely low: only 1.4 Mln. tons of milk was delivered to processing companies (33% of produced volumes).

Milk and Meat Quality Merely 359 milk processing plants operate in Ukraine including 62 powerful plants As on data of state control about 50% meat products, 70% milk products from checked total quantity are withdrawn from circulation per year owing to non-conformities with requirements of Ukrainian law about food quality

Standards and Certification Finding # 1 Ukraine has a fragmented structure for the preparation, realisation, implementation, maintenance and supervision of the standards. This leads to gaps and duplication in the implementation.

Conclusion #1 Owing to large number of food products on the market Ukrainian authorities currently have problems to prepare, realise, implement, maintain and supervise the respective requirements.

Recommendation # 1 Reconsider the current end-product orientation of the present system of standards and the role of standard bodies in the light of EU models and international experience.

Finding # 2 The present standards in Ukraine are mandatory documents by which quality parameters become subject to the system of regulatory control. For example: the size of the summer sausage is defined by a compulsory standard.

Conclusion # 2 The system of having compulsory quality standards is in contradiction with the principles and definitions of TBT, EU laws and the principles of a market economy.

Recommendation # 2 Modernize the present mandatory standards system by creating technical regulations from the compulsory requirements such as safety parameters while conformity with standards for quality issues will be on a voluntary basis.

Finding # 3 Some individual norms and limits of the parameters in the standards do not comply with EU requirements and / or Codex Alimentarius. For example, Ukraine conducts analysis of Aflatoxine B1 and M1 in both milk and milk products.

Conclusion # 3 Ukraine lacks knowledge of or capacity to adapt regulations to the Codex and / or EU requirements.

Recommendation # 3 Increase knowledge of EU legislation and Codex Alimentarius through active participation of Codex Alimentarius Commission meetings and Technical Assistance from the EU.

Finding # 4 The wheat standard differs in terms of quality and safety parameters from international standards

Conclusion # 4 With the present quality and safety of wheat and its respective parameters, Ukraine will not be able to realise its full export potential in this sphere.

Recommendation # 4 The quality and safety of the wheat and its respective parameters of the standard to be brought in line with international requirements.

Testing and Technical issues Finding # 5 The system of control in Ukraine is primarily based on end-product testing

Conclusion # 5 The system of end product testing is reactive, inefficient and ineffective and not in line with present international developments.

Recommendation # 5 The HACCP system and ISO standard should be elaborated as an integral part of the strategic food safety approach as well as in to the systems and approach of food industry, food safety education and inspection services.

Finding # 6 Some raw materials and final (composed) products (e.g. antibiotics in fermented milk products [yoghurt / smetana]) are checked on the same parameters applying the same norms and limits.

Conclusion # 6 Checking raw materials and final (composed) products on the same parameters is illogical and leads to additional costs in time and resources.

Recommendations # 6 Make operators primarily responsible for their products (see recommendations from legal component), ensure effective implementation of HACCP in the Food Industry which include sampling plans. Train Food Inspectors in understanding the HACCP system and the respective sampling plans. Adapt any sampling systems to take into consideration sampling taken of raw material.

Finding # 7 Ukraine checks the milks and meat products on the traditional pathogens and does not make reference to the emerging pathogenic bacteria like Listeria monocytogenus and Escherichia Coli O 157 and intrinsic characteristics like Aw (Water Activity parameter).

Conclusion # 7 Ukraine lacks the knowledge or the technology on some emerging pathogenic bacteria like Listeria monocytogenus, and E. coli O 157 and intrinsic characteristics like Aw.

Recommendations # 7 Ukraine to be trained in food microbiology in general and the in the EU newly established microbiological parameters on all food products and be supported in obtaining the relevant technology.

Recommendations # 7 MRL and diagnostics of some emerging pathogenic bacteria like Listeria monocytogenus, E. coli O 157 and intrinsic characteristics like Aw have to be included into normative documentation

Finding # 8 Frequency of sampling for both raw material and end products, as well as the obligatory list of food safety parameters are not based on Risk Analysis and HACCP

Conclusion # 8 Scientifically unjustified sampling leads to ineffective control and additional unnecessary costs for the state organs, producers and consumers

Recommendation # 8 The concept of Risk Analysis should be elaborated and applied to the methodology as well as parameter identification and quantification of chemical and microbiological analysis for sampling.