Instructions (by the Food Standards Agency) are issued today re exports of GM Food and Animal Feed Products to the EU From 1st January 2021 – here.
Please read carefully, below is a summary –
The information applies to UK businesses:
* holding or seeking authorisations for genetically modified (GM) food or feed
* holding or seeking authorisations for animal feed additives
* exporting animal feed products to the EU
* that have applications to update the list of feed for particular nutritional purposes (PARNUTS) pending on 31 December 2020
• that represent companies that are based in non-EU countries which rely on UK representation for EU trade
The business must be established in the EU or European Economic Area (EEA), or have a representative that is established in the EU or EEA for trade to the EU to occur. The EEA includes Iceland, Liechtenstein and Norway.
The role of the representative is to provide assurance that the non-EU establishment complies with EU legislation.
Where EU authorisations are held for GM food or feed, or for animal feed additives, a representative must be established in the EU or EEA. The details of the representative must be sent to the European Commission. This could be a branch of the business which is established in the EU or EEA or another business.
Changes to holder-specific authorisations for GM food or feed, or for feed additives, require amendments to EU legislation which would need to be in place by 31 December 2020. Businesses in the process of such changes must approach the European Commission as soon as possible.
Exporters of feed products to the EU require representation in the EU or EEA. EU countries will each have their own systems for this and businesses should consult with the relevant competent authority in the EU country for further advice on gaining recognition for their representative. The requirement for non-EU country representation would apply to all feed products exported to the EU.
The requirement for non-EU country representation applies to all feed products. This follows the European Commission’s announcement of a revised interpretation of Regulation (EC) 183/2005, Article 24. The FSA is currently seeking clarity on this interpretation, but companies should nevertheless anticipate this revised interpretation and consider designating a representative within the EU or the EEA.
Regulation (EC) No 183/2005 on feed hygiene states that establishments approved by the competent authority shall be recorded in a national list under an individual identifying number. From 1 January 2021, these approval numbers may not be recognised in EU countries.
Please clarify with your third country representative or the competent authority in the individual member state(s) that you wish to export to, to ensure that you are compliant with the rules on third country requirements when exporting to the EU.