The European Commission’s health and safety unit has published findings from two assessments looking at controls on fish in Mexico and Belgium.

A DG Sante audit in Mexico in November 2022 assessed the systems covering checks on fishery products exported to Europe.

Auditors found that although the official control system covers the entire production chain and is operated by an authority with the necessary powers and resources, its effectiveness is hampered by several shortcomings in critical areas.

Since January 2018, three Rapid alert System for Food and Feed (RASFF) reports have been issued for tuna products from Mexico because of histamine, mercury, and cold chain problems.

Ensuring safe exports
One issue is the national legal framework does not cover all EU requirements. This means practices are accepted as they meet national provisions but not EU rules.

Differences include cadmium and lead limits and histamine sampling requirements, which vary from EU rules. Freezing and temperature requirements are also different.

Auditors found that officials did not have sufficient knowledge to perform several control tasks correctly or effectively. Shortcomings were also identified in maintaining the list of EU-approved establishments and laboratory performance.

Inspectors and certifying officers from State Commissions for the Protection against Sanitary Risks (COEPRIS) showed adequate food safety knowledge but not EU rules. Commission Federal for the Protection against Sanitary Risks (COFEPRIS) staff were familiar with EU rules, except for recent amendments to legislation. However, they did not demonstrate the skills and knowledge required to assess the freezing process.

“These shortcomings undermine both the reliability of official controls along the production chain and the confidence that can be had in the veracity of the guarantees provided in respect of the EU requirements contained in the EU official certificate. As a result, incorrectly certified product was exported to the EU,” according to the audit report.

In response to 11 recommendations, Mexican authorities proposed a range of actions, including training, updated guides and documents, and working with operators to meet EU requirements.

Belgian audit
The audit in Belgium in November and December 2022 found that overall, the organization and operation of official controls were broadly effective.

However, certain elements undermine the reliability of the system. These include allowing several firms to produce under the approval of another operator and the granting of approval to factory vessels without operators being able to demonstrate compliance with all legal requirements, as they are not required to have HACCP-based procedures, even though they cook shrimps and produce ready-to-eat (RTE) food.

Auditors said the procedures for official sampling and associated actions taken following these controls may allow food products to be placed on the market despite non-compliant results.

There have been five recent RASFF alerts concerning fishery products from Belgium, with three in 2020 and two in 2021. They included incorrect use-by dates, dioxins, and Listeria in shrimp.

Auditors found the enforcement system means that less severe non-compliances are up to the operators’ discretion to address. They said this may impact the correction of possibly multiple or minor issues and prevent their re-occurrence.

At auction halls, certain unhygienic practices jeopardize food safety, such as the placing of containers with fishery products directly on the floor, moving them around often through pools of water, and stacking containers on top of each other, leading to contamination of the product, during loading and transport, according to the report.

Procedures for sampling for microbiological criteria state that inspectors initially collect one sample instead of the five required by EU regulation. Also, follow-up procedures detail that if any subsequent testing following an initial non-compliant finding gives a compliant result, all measures imposed on the lot concerned are lifted, and products can be placed on the market.