Resolution Demanding Better Traceability Of Food Products In Germany

Author:Mr Thomas Salomon, Christiane Alpers and Matthias M. Schweiger
Profession:Hogan Lovells

Once again there is a new attempt in Germany to introduce stricter requirements for food safety - despite the full harmonization approach in general EU food law:

The Federal Council has taken initiative regarding improvement of traceability of food and feed products. On 14 February 2020, it passed a resolution demanding legislative changes from the German Federal Government.

In its reasoning the Federal Council refers to several incidents that affected German consumers in the past. Lack of traceability of products was often mentioned as a problem when trying to resolve incidents quickly.

According to the Federal Council, this has shown how important it is to be able to quickly and effectively trace the delivery routes of food products. The Federal Council demands amendments of the law for consumer protection. It is essential that authorities and food companies are able to trace a food product that they have identified as presenting a risk back to its source, says the Federal Council. Aim is to isolate the risk quickly and ideally prevent products of concern from reaching consumers at all.

Thus, the delivery list has come into focus. Delivery lists are considered to be a central instrument for ensuring and accelerating the traceability of food or feed.

According to the Federal Council, effectiveness can only be achieved where the standards for delivery lists are uniformly set and respected at the level of food and feed manufacturer. The sometimes poor quality (e.g. scanned, poorly legible faxes etc.) and the inconsistency of the data provided by the manufacturers would currently delay the work of the competent authorities and would cause additional work.

Specifically, the Federal Council wishes the government to push for an amendment to the German Food and Feed Code, regulating the obligations to transmit information on the traceability of food. Under the proposal, food and feed manufacturers will be required to...

To continue reading