This requirement must be in regulation. It could be either as a new document or as an addition to 178 as Article 8a. The inclusion is essential for the long term viability of the several millions of small and micro food businesses in the EU. It is only logical that the interests of both the consumers and the suppliers should be taken into account. Neither can survive without the other.
The wording for this additional complementary Article (UEAPME suggest it should be Article 8a) could be:
In order to achieve the free movement of food and feed due account shall be taken of the impact food law and any interpretations may have on food and feed businesses. It shall aim at the prevention of:
- Demands that may not be practical for all enterprises irrespective of size
- Demands that may favour particular sizes of business
- Any other obligations that may jeopardise the supply of adequate safe feed and food.
This would complement the existing Article 8 (178/2002) which says:
Food law shall aim at the protection of the interests of consumers and shall provide a basis for consumers to make informed choices in relation to the foods they consume.
There have been examples where proposed food regulations take no account of practicalities, particularly where smaller FBOs are concerned. In the past the UEAPME Food Forum has been in a position to successfully challenge unworkable proposals. Without that presence there is a danger that impractical measures could be introduced. This would have a disastrous impact on FBOs and in turn, the consumers.
This is not an acceptable situation. The inclusion of this wording in regulation would:
- Reduce the risk of poorly thought through regulations being implemented.
- Reduce the risk of officials trying to override EU food regulations.
- Reduce the risk of 'gold plating' by local officials.
Practical examples of the effect that the non-inclusion of the proposed change would have on food businesses.
Two current issues currently being considered are:
- The proposed full recovery of costs of routine hygiene inspections. A figure of £500 per routine hygiene inspection has been suggested. Food Solution research would suggest that over 100,000 food businesses would close if this were implemented.
- The requirement to show the nutritional values on loose food. The practicalities of the requirement to show all this have not been thought through.
Both of these would fit the criteria of this proposal. There will be more in the future. We have the opportunity now to influence the decision makers if we have your support. If you chose not to act:
You will get what you deserve