WTO and Russian FISH market

February 21, 2012 14:58

Recently Pollock Catchers Association issued their proposals to Russia's Concept of WTO membership, reports www.megafishnet.com.

In this document the authors mention that Russian fish import grew up in tonnage during 1993-2005.  Increase was great: from 50 to 1085 th.MT. At the same time average price was $350-500 mainly because of tax evasion.  In 2000th volume was more or less stable about 1000 th.MT, but declared price went up and topped $2000.

Starting from 2008 there was a substantial increase of catch and respective production of domestic products.  However, even taking into account increased competition, the price of imported fish is not going down.  Just the other way round, in 2009-2010 average price reached maximum.  The reason for it is successful use of WTO regulations on technical barriers and veterinary control.

It's necessary to say that the main document regulating biosecurity is Agreement on sanitary and phyto sanitary measures. The major elements of control system are a legal document (Health or Veterinary Certificate) and procedure of risk assessment.  Both are absolutely necessary for making a decision that products and/or quality control systems meet requirements.

A number of control systems are present at WTO countries.  Generally, there are two approaches.  The first - Importer country grants Exporter country the right to estimate product security and safety basing on importer country regulations.  We all know that sometimes the system doesn't really work properly as some countries protecting national producers apply "soft" approach to quality checks.  In many cases national control bodies in China and Vietnam check documentation superficially, fully trusting producer.

It's worth mentioning that according to Russian legislation it is the importer who is responsible for quality and who bares all the losses.

Another approach is applied when the right to export is granted as a result of inspection of each and every plant by competent officers from importing country.  This is approach declared by EU.  Special commission from EC is to visit every facility every year.  The latest visit to Russia took place on summer 2011.  However, meeting Chinese and Vietnamese processors, we know that there are plants there which have not been visited by a European inspector for long years.

Another approach is used in USA.  An exporter is to register with Food and Drug Administration (FDA) - this is a simple procedure done through Internet.  Further on the number and a proof that HACCP plan is in place at the processing plant are to be passed to importer who communicates with FDA.

Actually, FDA runs risk assessment and makes laboratory tests.  For example, every shipment from China is to be checked at Chinese territory.  Anyway, any shipment can be tested on arrival to USA.

China is the biggest processor of products made of imported raw material.  There are 5000 processors, 1840 of those have been registered by Chinese authorities as exporters.  Just 159 have been registered for export to EU including 17 fishing boats and 120 trawlers-processors.  As the processors supply countries with tough quality regulations, the Chinese authorities impose restrictions on imported raw material. Any supply to China is possible after registration of exporting facility in AQSIQ by appointment of Competent Authority of exporter country.  The facilities list is compiled by producer country, basing on sporadic checks by AQSIQ expert teams. 

It's worth mentioning that no system is perfect.  Many countries insist on presenting HACCP certificates, but the question is the choice of critical control points.  For example, there are just 2 CCPs at most Chinese factories: metal detector of raw material and packed product.  At some Vietnamese factories there is just one CCP. 

Current data from Russian authorities show that fish is the most risky product, proportion of bad test results is ten times higher here than in any other kind of food.  According to the tests 5.3% of the product doesn't meet microbiological limits, 5.2% - chemical restrictions, 2.9% - glazing.  This is average, but in some regions the figures are shockingly high, up to 88% in Novgorod region.  It mainly concerns imported fish products.

It is necessary to develop a detailed plan to guarantee food safety for fish products.  On PCA opinion, it is to be based on risks assessment, and include regular onsite checks by Russian experts teams and monitoring of the products quality both before shipping and in Russia.

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