Marek Zadernowski – When one size food rule does not fit all in Europe

Pan European food safety regulations leave a room for interpretation and could be more precise to help the food industry across Europe be more compliant. 

Marek Zadernowski is a consultant, specialist in quality management and safety in a food sector, based in Olsztyn, Poland. He is a member of Polish Association of Food Technologists and a fellow of the UK Royal Society of Public Health. He tells how the cultural and legal differences across Europe, leave wide enough gap in the interpretation of national regulations, opening the door to uncertainty.

Do you believe that food traceability regulations are sufficient?
Yes and no. The EU traceability regulations are a voluntary partnership between the regulators, who rule with the interest of consumers in mind, and the food industry, which has a responsibility to abide by the rules. Present form of legislation leads to a certain degree of freedom in the implementation of specific requirements. However, their effectiveness largely depends on the good will of the food producers and on the competence and knowledge of inspectors. 

In the case of horse meat found in Irish burgers, it was suggested that the meat was of Polish origin. If it is true, it proves that traceability regulations work, even though horse meat was traced back after the fraud happened. But we also have to remember that, under EU rules, the food producers’ obligations are limited to their own capacity to trace the meat. The purchasing of raw materials from a third party supplier is based on mutual trust. There are no 100% reliable methods to control the content of all the merchandise all the time. 

What changes need to be introduced?
The problem with these regulations is that they do not take into account cultural differences and variations of legal systems across the EU. As a result, in many countries, including Poland, the food producers do not find it easy to abide with the requirements imposed by the regulations. In my opinion, the rules should be much precise. A good example can be the requirements applying to traceability included in the Regulation (178/2002 Art. 18) giving only general rules described as  “operators shall have in place systems and procedures”  The food industry is also uncomfortable with the level of flexibility of documentation form and flexibility surrounding interpretation of specific requirements. There is a dire need for clarifying how best to interpret the regulations.

Moreover, we have to reshape the role of food inspection and monitoring agencies by exactly defining their role. Their current level of monitoring may not be sufficient to be effective when the number of test samples is limited by cost constraints. However any action undertaken even in limited scope, significantly increase the level of food safety. In my opinion regulation referring to the food testing should also be regularly reviewed and extended by the methodology based on statistics.

How could industry and the regulator restore the trust of consumers?
Human memory is fleeting. The consumers’ trust will come back and the producers know about it. After the initial fall of meat consumption, trust will grow back. In quality management we say that high quality products are those that fulfill customers’ requirements. In this case, the cardinal requirement is food safety. In most of cases, the motivation for any actions will be money and profits not public health. Those who want to get back to business sooner must persuade their customers that they have adequate resources to assure such safety. There is also a risk that instead of using proper corrective action the industry will try to do it only by relying on marketing tools

Moreover, in a few months, the monitoring activity of official food control bodies will decrease. This is because they do not have enough financial resources to maintain a high level of control all the time.  If we are really serious about change with limited financial resources, we should persuade consumers that we have well-constructed regulations that can be easily adapted to unexpected situations and inspected properly.

For further information on Call +39 02 725 46 305. Email us at Or visit our Facebook, YouTube or Twitter.