Microbiological contamination in fruit from Ukraine for export to Europe might not be detected, according to findings from an audit.

A DG Sante assessment in Ukraine in June 2021 focused on viruses and bacteria in fresh and frozen soft berries like raspberries and blueberries. DG Sante is the European Commission’s unit for food safety and health.

The audit found there was no official system for monitoring, sampling and analyzing fruit for export to the EU for microbial contaminants. This means any contamination during harvesting, handling and freezing will not be detected, said auditors.

The COVID-19 pandemic meant the audit was based on a review of documentation and control records, interviews with staff from the State Service of Ukraine for Food Safety and Consumer Protection plus presentations from the Ukrainian Berries Association.

Exports of soft fresh and frozen fruit from Ukraine to the EU included 18,266 tons of raspberries and 9,894 tons of cultivated blueberries in 2020. In the past year, only three border rejections for fruit from Ukraine have been raised on the RASFF portal – all were notified by Poland due to mold in frozen raspberries.

Difference in controls along chain
Official controls at primary producers was, at the time of the audit, in the early stages and delays were caused by the COVID-19 pandemic. According to risk assessment criteria, primary production is classed as a negligible risk category and planned controls are once every two years. They use generic checklists and do not specifically address Good Agricultural Practices (GAP) like field toilets and handwashing facilities, use of manure, or types of irrigation including water used.

The majority of primary producers of food of non-animal origin (FNAO) are not registered yet in the state system of market operators so are not covered by official controls. This database was in the process of being merged with another one which will allow authorities to consider all such producers when planning controls.

As producers of soft berries were subject to very few official controls, some products are exported without having had official or private checks for microbiological safety, said auditors.

Risks associated with the lack of oversight in primary production is mitigated as all processors and exporters are subject to official controls and, in most cases, are certified against international food safety standards by third parties which carry out periodic inspections.

Authorities accept certificates and declarations from third party assurance systems for signing official export certificates. However, private certification schemes are not formally recognized by the authorities and there is no official verification on the reliability of the assurances they provide.

The audit team evaluated checks at two freezing companies in two regions. Inspectors did not verify if firms have an environmental sampling plan in place and/or effective procedures to detect Listeria monocytogenes.

For frozen berries, GAP certification is not always required by EU importers and is not obligatory for raspberry farmers. Collectors of wild blueberries are not inspected by official or private bodies.

Official analysis for viruses like norovirus or Hepatitis A are not carried out. Laboratory staff said there were deficiencies in the sampling of frozen berries for norovirus and appealed for help to receive contaminated samples from abroad for testing.

Results from dairy audit
Another audit, in March 2021, looked at Ukraine’s system for milk and dairy products exported to the EU.

DG Sante found the official control system for the production of milk and dairy products provides many of the guarantees on compliance of exported products with the relevant EU hygiene requirements.

Official veterinarians (OVs), who are permanently present at establishments, issue export health certificates. They are state employees paid from the state budget so avoid any conflict of interest.

Some legislation and documented procedures need updating to reference rules such as EU regulation No 605/2010 which sets the requirements for raw milk and dairy products intended for export to Europe and other documents reference repealed legislation.

An adequate approval and delisting procedure for plants wishing to export milk and dairy products to the EU is in place. However, in some cases examined by the audit team, implementation was not in line with EU requirements.

A recently delisted establishment had not been inspected for national and EU compliance for the past three years. This is not in line with EU rules and no guarantees were available that the plant had fulfilled EU requirements.

The audit team noted that when raw material other than raw milk is supplied from another EU-listed Ukrainian site or another country and used to produce milk or dairy products for the EU, accompanying documents on the eligibility of the batch are missing or do not have the relevant information. This undermines the reliability of the certification system, said auditors.

Ukrainian authorities said the main non-compliances related to hygienic requirements for production facilities, rare cases of problems with raw milk criteria such as results of plate count and somatic cell count, and some cases related to food traceability.