The difference between info sheet 64 and 65 of the Dutch Food and Consumer Product Safety Authority (NVWA)
To whom do the info sheets apply?
Every food company is responsible for the food safety of the products which it markets. For this purpose, companies must draw up and implement HACCP procedures. All the food safety risks are recognized, prevented and reduced or eliminated in these procedures.
The NVWA has drawn up info sheet 64 and 65 to give a guideline about the management of raw material risks. Info sheet 64 is a guide for industrial companies which produce food. Info sheet 65 concerns companies which trade in consumer products, without preparing, processing or handling the food. In practice, info sheet 65 is used by distributors, dealers, wholesalers and retailers.
Consumer products that are imported from third countries (countries which are not a member of the European Union) must meet the provisions of info sheet 64 instead of info sheet 65.
In what way do the info sheets differ in practice?
Info sheet 64 describes that for all the raw materials and/or ingredients, it must be determined what the actual risks are. For these risks, further control measures are necessary. In the calculation, a manufacturer may include to what extent the raw material is used in the own end product. The use in the next chain may not be included and of course an unsafe raw material may not be diluted. A specification or a statement from the supplier is an insufficient guarantee of the actual risks. Not a single control step may be omitted.
Distributors, dealers, wholesalers and retailers must make an estimate themselves of risky products which could form an actual risk for the consumer. This does not mean that all potential risks of each individual product, ingredient and raw material must be charted. That is the responsibility of the suppliers/manufacturers (info sheet 64).
However, to obtain a sufficient guarantee in the chain, the control measures that the suppliers/manufacturers take must be checked.
How are the risks managed?
The NVWA accepts the following control possibilities:
- The supplier supplies an ISO 17025 accredited and batch-linked analysis from which it appears that the raw material is safe.
- The company itself can have an ISO 17025 accredited analysis carried out on the supplied batch.
- Companies can carry out (have carried out) an audit, aimed at least at the management of the raw material risks.
- The supplier is affiliated to a chain guarantee system (Riskplaza).