Primary producers


12. Do fishing vessels and aquaculture farms need to be approved for export to EU ?

Only primary producers that comply with the general and specific EU criteria shall be allowed to supply factories that export to EU. Fishing vessels and aquaculture farms are primary producers that shall be registered in a national register (see here). Criteria to comply with for fishing vessels are in Regulation (EC) 852/2004, Annex I and Regulation (EC) 853/2004 Annex III, section VIII. Criteria to comply with for aquaculture establishments are in Regulation (EC) 852/2004, Annex I for general hygiene, use of medicines and use of feed (see also the question below).

13. What are the EU requirements to Good Aquaculture Practices?

There is not a specific document stipulating EU requirements to good aquaculture practices. However several requirements to aquaculture farms which supply raw materials for further export to EU are disbursed in the general food hygiene regulation, in the regulation regarding the use of veterinary medicines, in the regulation regarding feed hygiene and in the regulation regarding animal health. Requirements are briefly listed below:The farmer shall not use veterinary medicines and other chemical substances which are prohibited to use in fish and crustaceans (Regulation (EC) 2377/90, Annex 4 and Directive 96/22(EC)). The farmer shall keep records on purchasing, possession, and administration of veterinary medical products (Directive 2001/82, Art 69 and Regulation (EC) 852/2004, Annex I, ch. II and Regulation (EC) 852/2004, Annex I, ch. II )The farmer shall purchase and use only veterinary medical products which are authorized for marketing by the competent authority and which is are adequate labelled in compliance with requirements. (Directives 2001/82(EC) and 2004/28(EC), specifically articles 9, 11, 58, 59, 60, 61The farmer shall purchase feed products only from feed producers which are registered as compliant with EU criteria by the national competent authority. Regulation (EC) 183/2005 Article 5 and Annex I If the farmer produce feed in the farm, it shall be documented, trough monitoring and record keeping, that potential hazards are identified and controlled and that the input and output are traceable one step before and one step after the production. The farmer shall apply feeding practices which minimize the risk of biological, chemical and physical contaminationThe farmer and his advisers shall be able to recognize symptoms on diseases, specific to his animals, which are subject to prevention and control of spreading in EU (Directive 2006/88(EC)). See here.

14. May we have wood in the fishing vessels that supply to factories approved for export to EU?

Surfaces in contact with fishery products in a fishing vessel shall be of suitable material, smooth and easy to clean and with surface coatings which are durable and non-toxic (Regulation (EC) 853/2004, Annex III, section VIII, ch. I). The underlying understanding is, that wood can be accepted if surface coating allows it to be cleaned and disinfected.

15. Do all fishing vessels need to carry ice for preserving of the catch of fresh fish?

It is required that fishery products are protected from sun or any other source (e.g. temperature) as soon as possible after taking on board and further that they are chilled as soon as possible. However when chilling is not possible, fishery products must be landed as soon as possible. (Regulation (EC) 853/2004, Annex III, section VIII, ch. II). The underlying understanding is that small boats which are fishing for few hours not far from the coast may not use ice. However the requirements to freshness of raw materials may never be compromised.

16. What kind of documentation does the primary producer need to keep in regard to food safety?

Primary producers rearing animals, such as aquaculture farms shall keep records on the nature and origin of the feed, administration of veterinary medicines or other treatments, incl. withdrawal periods and the occurrences of diseases.Other primary producers, e.g. fishing vessels, need to keep records relating to the activities that controls possible hazards, this may in practice be the supply of ice, the temperature controls and the cleaning and disinfection activities. (Regulation (EC) 852/2004 Annex I, ch. III). Small coastal fishing vessels which are on the sea less than 24 hours are exempt from keeping the obligation to keep records by new Regulation (EC) 1243/ 2007. The definition of small coastal vessels is in Regulation (EC) 1198/2006 article 26.


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