SIPA contributed to FRUCOM’s response to the public consultation on the draft regulation on detailed rules on the operations to be carried out during and after documentary checks, identity checks and physical checks. FRUCOM’s response can be seen here.

The draft regulation provides information on the number of packages to be selected from a consignment in order to perform identity checks and physical checks. The draft regulation stipulates that 1% of the items or packages in the consignment, a minimum of 2 items or packages and a maximum of 10 items or packages should be selected. The draft regulation then allows the competent authority to exceed the maximum. This is confusing. The draft regulation needs to clarify the conditions under which 1% of the consignment or 10 items may be exceeded; without this clarification the other selection parameters are not enforceable.

SIPA also contributed to FRUCOM’s response to the public consultation on the draft regulation of frequency rates for identity checks and physical checks on imports of animal products. FRUCOM’s response can be seen here.

SIPA’s contribution focused on:

-there should be a provision to reduce the frequency of checks, not only to increase it;

–categories of products subject to checks are defined very broadly (e.g. category II includes meat, fish, eggs, poultry, etc). and should be made more specific, since an increased frequency will apply to a category as a whole and not to specific foods.