Comments on CX/FICS 03 /4- “Discussion Paper on Traceability/Product Tracing in the Context of Food Import and Export Inspection and Certification Systems”

13.11.2003

Comments on CX/FICS 03 /4- “Discussion Paper on Traceability/Product Tracing in the Context of Food Import and Export Inspection and Certification Systems”

Dear Ms Backhouse,

EuropaBio appreciate the opportunity to provide comments on the above paper. We strongly believe that the traceability/product tracing work within the Codex Committee on Food Import and Export Inspection and Certification Systems (CCFICS) is both timely and important.

We commend the CCFICS working group (WG) on its thorough analysis of the “elements” of traceability/product tracing in existing CCFICS texts. We agree with the conclusion of the WG that these texts already contain elements of product tracing. Further, we believe that as these texts were not intended to address product tracing, there is no need to expand the texts. We do not support re-opening or redrafting CCFICS texts to include language on traceability/product tracing, and believe that there are better mechanisms to ensure that elements of traceability/product tracing are integrated into food import and export inspection systems.

In considering the work product generated by the second meeting of the WG in September 2003, EuropaBio believes the paper is complete; we commend the WG for accomplishing its mandate.