Two audits by the European Commission’s health and safety unit have looked at checks to ensure fish product safety in Egypt and Croatia.
A remote DG Sante audit, in May and June 2021 in Egypt, identified shortcomings in virtually all areas and made 20 recommendations.
The objective was to verify that systems ensured products exported to the EU comply with the rules. Egypt is approved to send only certain wild catch fishery products to Europe but asked in April 2021 to be authorized to export fish from aquaculture.
A 2009 audit found deficiencies in implementing the control system, low knowledge on Hazard Analysis and Critical Control Points (HACCP) by officials, and poor controls of the cold chain. It also revealed that legislation was not fully aligned with EU rules.
Eurostat data shows the EU imported a yearly average of 2,280 tons of fishery products from Egypt between 2016 and 2020. The top two countries were Italy and Spain and the main product was fresh/chilled whole fish. According Egyptian authorities, it exported 4,980 tons in 2019 and 5,866 tons in 2020. However, this is based on information provided by operators for the audit.
RASFF, traceability and oversight issues
Five related Rapid Alert System for Food and Feed (RASFF) notifications were issued from 2018 to March 2021. One was for undeclared additives and four were because of mercury above the EU legal limit. Egyptian officials could not identify the products implicated, reasons for the notifications, which operators were involved and the EU countries to which items had been exported. They could not demonstrate it received the alerts, investigated them, or that measures to prevent their recurrence were taken.
Auditors found staff were not trained recently and didn’t have all the necessary written procedures or instructions to perform official control tasks.
Data provided showed Egyptian officials were not fully aware of, or couldn’t reliably ascertain, the origin of raw materials used by EU-listed establishments in the manufacture of products for exports. Information points to the existence of sources of raw materials other than the controlled primary fishing vessels, according to the audit report.
Controls of primary production fishing vessels were not carried out effectively as non-compliances were not detected or corrective action was not enforced while EU-approval was retained.
Checks on fishery products for export to the EU includes sampling and testing for heavy metals such as cadmium, lead and mercury but did not cover freshness criteria, histamine, dioxins, parasites, relevant microbes and checks for poisonous products.
The authority did not provide evidence to DG Sante that companies handling products not eligible for EU exports have measures in place to prevent them being sent to Europe.
The General Authority for Fish Resources Development (GAFRD) said the absence of complaints by trade partners shows exports are safe and that the control system works. GAFRD said certain relevant documents that would have helped the audit team understand the system could not be shared by email because of legal issues. The National Food Safety Authority replaced another agency as the relevant body from 2022.
Croatian assessment
The other virtual audit, in Croatia in April 2021, found the system largely met EU requirements.
Croatia produced 16,506 tons of aquaculture products, mostly marine but also freshwater fish, and 63,200 tons of wild capture in 2019.
Effectiveness of the system is sometimes negatively affected by occasional weak coordination between inspectors, leading to inconsistencies during official controls, found the assessment.
From 2018 to the audit date, there were nine RASFF alerts covering fishery products from Croatia. In 2019, two cases concerned ready-to-eat products from the same plant and Listeria monocytogenes.
Despite the two non-compliant Listeria results, the establishment was kept in the same low risk category. However, as it exports products to other EU countries and processes fishery products, it should have already had a high rating.
Another site producing ready-to-eat fish products had two non-compliant results in the same year because of Listeria monocytogenes. The risk status of the establishment was kept at the same medium rating.
The planned frequency of official controls in approved facilities handling fish products is not always met due to human resource constraints. A new risk assessment system will ensure risk-based official controls at primary production from 2022.
In response to the findings, Croatian officials said training will be undertaken for inspectors covering food safety criteria and taking measures to prevent recurrence of microbiological contamination, acting on RASFF notifications, and changing the risk of a facility to a higher category.
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