DECRETO 523-09 PDF

Kigagal CELCAA notices that the publication of these documents should be well reflected and submitted to clear criteria in view of the damage some information may cause to FBOs. Where this is not possible, due to a lack of relevant data caused by short-comings in the current regime, this has been identified. Furthermore, increased transparency would contribute to the objective of ensuring that fees revenues are not unduly distracted from their intended use compensate control costs. In this respect, CAs assessment of the changes proposed through option 4 is overall positive as improvements to the control system as a whole are expected to result from the extension of the range of mandatory fees and from the full cost recovery rule. The main problems identified and the provisional options were also presented and discussed at meetings of the Heads of Food Safety Agencies on 29 June-1 July and on 8 December Monitoring and maintaining appropriate harmonised fee levels would also create a disproportionately heavy burden for Member States and the Commission.

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Dojar The option was discarded as the non-binding nature of soft law instruments was considered insufficient to address the interpretation and implementation difficulties linked to The Regulation and the shortcomings of the rules governing inspection fees. The impact on larger businesses would be particularly disproportionate in those Member States and those sectors with a large percentage of micro-enterprises.

European added value test — The added value of a single, uniform set of EU rules to govern official controls lies in the fact that it offers national enforcers and their operators a framework within which CAs can rely on enforcement activities carried out in another MS, and on the reproducibility and scientific and technical soundness of control results.

In particular, uncertainty would remain as regards the availability of sufficient resources to finance official control activities. In some Member States, a fixed scope accreditation can only cover the use of a specific method to be followed very precisely by the laboratory on a specific matrix in order to detect a specific substance, virus, bacteria, etc e. Participants in the Steering Groups did raise several questions for clarification but no major comments in relation to the review were raised.

The reason drcreto official controls not being aligned to the risk-based approach in the areas above is that such controls are currently prescribed by EU rules[25], pre-existing the Regulation and dcreto repealed by it, which do not establish appropriate mechanisms to take into account the actual risk a given good, business activity or third country might present.

In this respect, CAs assessment of the changes proposed through option 4 is overall positive as improvements to the control system as a whole are expected to result from the extension of the range of mandatory fees and from the full cost recovery rule. CA decretp have difficulties maintaining an effective oversight of compliance by food business operators and, ultimately, the safety of the agri-food chain, especially when faced with large scale crises. Competent authorities are required to perform official controls on all business operators active in the agri-food chain.

Reduce occurrence of unsatisfactory enforcement results in FVO reports attributed to resources shortages. In addition to the elements of option 3, option 4 would expand the list of mandatory inspection fees to all controls carried out on feed and food business for which a registration requirement is established in accordance with food safety and feed safety rules, i.

To ensure harmonised verification of compliance with EU agri-food chain rules, MS are required to carry out official controls on certain goods coming from third countries at the external borders of the EU EU border controls. There is no such requirement for any of the other control planning instruments or for the MANCP as such and the long and heavy administrative procedure laid down in the Directive of residues is not justified by any specificity of the controls to be carried out.

Example The Commission received a complaint against Germany decrego a food business operator. It varies therefore from one sector and from one category of business to the other. EUR-Lex Access to European Union law The Regulation addresses specific aspects of official controls associated with such products, including meat, live bivalve molluscs, fishery products and milk.

According to Eurogroup system of rating smileys could be a good way to inform the public of the level of compliance found for specific food business operators. The specific objectives were set with the aim of eliminating the specific obstacles identified during the analysis which prevent or hamper the achievement of the general objectives in this area[37]. It offers the best approach to simplification, clarity, coherence and reduction of administrative burden without losing the capacity of the legislative framework to account for the specificities of every concerned sector.

Thus the impact of fees on production costs is significantly higher in this field than in others. In particular, it calls for administrative cooperation i between MS for cross-border enforcement action, and ii between sanitary authorities and customs services. This initiative pursues the objectives of the Communication on Smart Regulation in the European Union.

This results in uncertainties and divergent interpretations as to whether such provisions apply to controls on compliance with animal health and animal welfare rules, or with specific legislation governing the materials and articles intended to come into contact with food FCM [] or the deliberate release into vecreto environment of genetically modified organisms[].

The type and frequency of the border controls, as well as their frequency, would be harmonised and risk-based. The Regulation provides for a general framework for official controls in the sectors of feed and food law, animal health and animal welfare rules, laying down rules both the organisation and the financing of such controls.

Similarly, the lack of integration of the different control structures operating at the border also prevents efficiency gains and savings in administrative costs to be reflected in lower fees being charged on operators. Furthermore, resources obtained through fees are not required to be earmarked for the needs of the control authorities which collect them.

Although in theory both Options 1A and 1B could be combined with other elements of Options 2 to 4, they are presented and assessed individually given the significance of the changes they purport to introduce. During the consultation, a number of MS IT, DE, NL, FR and UK noted that a fees system that has a clear definition of eligible costs, transparency of reporting and full cost recovery requirements, would effectively operate as a ring-fencing mechanism without a formal requirement to do so.

This results in burdens above and costs most border controls result in a fee levied on the business operator responsible for the consignment not always justified by the risk posed by the product being introduced into the EU.

B dedreto micro-entreprises Option decrdto. This new legal framework has been in application since 1st January Existing mandatory inspection fees are maintained but not applied to micro-enterprises; other provisions of the legislative framework remain unchanged.

No derogation is foreseen from the requirement of accrediting official laboratories. The European Snack Association argues that the lack of a clear specified timeframe dcereto the second opinion test and reference test can discourage food operators from exercising their rights if told it will take 30 days for a retest.

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Kazradal Similarly, no flexibility is foreseen for small laboratories carrying out extremely basic types of tests. The main problems identified and the provisional options were also presented and discussed at meetings of the Heads of Food Safety Agencies on 29 June-1 July and on 8 December Moreover, enabling national authorities to focus their control efforts where non compliances and risks are higher would minimise the burden of official controls on compliant businesses and have, therefore, a positive impact on their competitiveness. EUR-Lex Access to European Union law During the consultation phase, some respondents argued in favour of a specific, fully harmonised fee i. The Regulation addresses specific aspects of official controls associated with such products, including meat, live bivalve molluscs, fishery products and milk. All of the benefits applicable to Option 3 also apply to Option 4. CA may have difficulties maintaining an effective oversight of compliance by food business operators and, ultimately, the safety of the agri-food chain, especially when faced with large scale crises.

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Decreto 523-09

Dojar The option was discarded as the non-binding nature of soft law instruments was considered insufficient to address the interpretation and implementation difficulties linked to The Regulation and the shortcomings of the rules governing inspection fees. The impact on larger businesses would be particularly disproportionate in those Member States and those sectors with a large percentage of micro-enterprises. European added value test — The added value of a single, uniform set of EU rules to govern official controls lies in the fact that it offers national enforcers and their operators a framework within which CAs can rely on enforcement activities carried out in another MS, and on the reproducibility and scientific and technical soundness of control results. In particular, uncertainty would remain as regards the availability of sufficient resources to finance official control activities. In some Member States, a fixed scope accreditation can only cover the use of a specific method to be followed very precisely by the laboratory on a specific matrix in order to detect a specific substance, virus, bacteria, etc e.

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