ACTION PLAN OF TURKEY

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1 ACTION PLAN OF TURKEY Response of the Competent Authorities of Turkey to the recommendations of Mission report ref. DG (SANCO)8199/2006 in order to evaluate official controls over the production and processing of milk, dairy products and casings intended for export to the EU 1) To improve co-ordination of the competent authorities involved in the sectors evaluated. The necessary activities to improve coordination of the competent authorities numbered Provincial Directorates By the Instruction dated involved in the sectors evaluated shall be were disposed to perform their activities in carried out. coordination with each other (see Annex 1) Provincial Directorates of Agriculture were also instructed on this matter during the Evaluation Meeting, held at the General Directorate of Protection and Control, between the dates of November 30 and December 3,

2 2) To urgently ensure that competent authorities responsible for official controls over food-processing establishments exporting to the EU have full control over all relevant parts of food-processing establishments. The competent authority responsible for official controls over food-processing establishments exporting to the EU performs full control over all relevant parts of foodprocessing establishments. The exception of this issue is the case when there is a special store-room with customs seal in the establishment being investigated which needs an official request by Customs Administration. When the competent authority identifies on location that the Customs store-house is sealed, it controls the content of the sealed area over official documents. As a result of the inspection of the seal and the sealed area and its surroundings, if it is deemed necessary depending on infringements, legal s are taken, as per Article 342 of the Customs Regulation. Within this context, the Customs Directorate which have used the customs seal is contacted, to open the customs area and may carry inspection in this area, too. This issue being practised shall be included in the scope of the Instructions Concerning Inspection of the Milk Establishments to be Approved for Exportation to the EU (18/05/ ). The was completed. Necessary information about this recommendation has already given in the second column, Action proposed by Competent Authority. Also, by the Instruction dated numbered 27240, Provincial Directorates were charged to perform full control on each and every part of food establishments (see Annex 1, Article 5). 3

3 3) To devise training, in particular for the officials involved in official controls over establishments exporting to the EU, and over holdings to be certified disease free, regarding the EU specific requirements. Within the framework of the Twining In accordance with the recommendations of Project on Restructuring and Strengthening the mission, particularly official controls of The Food Safety and Control System In over food processing establishments and Turkey, No. TR-04-IB-AG-02, training over holdings to be certified diseases free, studies are being carried out. Apart from training of staffs is going to perform first this, the first training on amendments in quarter of circulars and instructions being effected in With the scope of Twining Project on relation to establishments intended for export Restructuring and Strengthening of The to the EU and milk holdings supplying milk Food Safety and Control System In Turkey, to these establishments, and the EU No. TR-04-IB-AG-02, training of staffs requirements were given by GDPC to the about HACCP prenciples and audits are staff of the assigned Provincial Directorate going to perform first half of Control Division Unit and Animal Health Division Unit, on May 8, In accordance with the recommendations of the mission, such training activities shall be continued concentrating on the subjects identified by the mission (free establishments, requirements of heat treatment, etc.). 4

4 4) To adjust the provisions In accordance with the recommendations of (legislation or administrative the mission, administrative procedures shall procedures) to take full account of be established and put into effect in the The administrative procedure is going to specific EU requirements related shortest time possible. These procedures complete and send to the PDs in first quarter to animal health controls and shall be executed in compliance with the of production of milk and milkbased Council Directives 64/432/EEC and products for the sector intending to export to the EU. 91/68/EEC, for tests conducted in relation to animal health control, in the holdings supplying milk to the establishments intending exportation of milk and milk products to the EU, and shall include the requirement that all establishments producing milk and milk based products identify the conditions specified in Directive 2004/438/EC as CCP in their HACCP plans. 5

5 5) To urgently introduce provisions (legislation or administrative procedures) to take full account of the provisions of Council Directive 96/93/EC. The Table comparing the Council Directive A proceeding has been started concerning 96/93/EC with the Turkish Legislation is counterfeit certificates. Information and given in Annex... The General Directorate documents will be asked from the competent of Protection and Control shall give authority of Germany for this pupose. In this instructions concerning the correction of the scope, it shall be required to notify the name determined deficiencies. of the importer, payment account of the imported product and name of the related company and whether the company has any connections with Turkey, if it works in Germany. According to these obtained documents, in cases where illegal points into a Turkish company, necessary legal procedures shall be carried out and the European Union Commission sall be informed about the result. The draft Circular for Issuing Health Certificate of Animals and Products of Animal Origin has been completed and presented to the related departments of GDPC (Annex 2). After that step, it will come into force. 6

6 6) To urgently implement and supervise reliable certification procedures, in particular with regard to export certification for commodities currently authorised for export to the EU. Working on a software program* for export certificate is going on. According to that draft program; all veterinary officers Software program* is envisaged to complete in end of the January of 2007, after then authorized for issuing export certificate will Instruction is going to be given to authorized be designated and they will have their user officer who issue export veterinary healt name in order to access program and certificate download export health certificate. Export health certificate will be prepared according As mentioned in the draft Circular on to requirements of importing country and put Issuing Health Certificate for Animals and web site by the CA of the central unit. Products of Animal Origin (Annex 2), under Inspection of Provincial Directorates and of Therefore, issued export Health Certificate Competent Persons for Certification, by the authorized officer will be monitored Provincial Director of the department by the competent authority of central unit. Health Certificate number will be given by computer automatically. Issued Health Certificate will be both original and copy, copy version will be stored in the issued province. (*: Veterinary Information System Project, Code TR , which is a sub-project of the Support Project for Harmonization of the Turkish legislation to the European Union Veterinary Acquis.) responsible for certification, GDPC and Board of Auditors are responsible for controlling the certification procedure. 7

7 7) To implement animal health Draft Regulation on control of Brucella and The studies about preparing the final controls in line with Council Tuberculosis, a copy of which was given to Regulation on control of Brucella and Directive 64/432/EEC and the mission team, prepared based on the EU Tuberculosis is going to complete and send Council Directive 91/68/EEC as Directives 64/432/EEC and 91/68/EEC has to the PDs in first quarter of In this appropriate on holdings intended not been published yet. In order to meet the context, Circular numbered 2006/28 on for the supply of EU compliant EU requirements until the publication of the Control of Approved Holdings, is going to milk. Draft Regulation, the Circular on Control of revised and sends to PDs at same time. Approved Holdings, No. 2006/28 that is being implemented in holdings supplying milk of EU standards shall be revised to 8) To review the evaluation of one of the establishments visited processing casings and to reconsider the proposal to the Commission services to list this establishment. fulfil the EU requirements. Instructions were given to the Provincial Directorate with communication dated and no , not to issue export certificate until the mentioned firm corrects its deficiencies. As stated, Action Proposed by Competent Authority of this report, the directive is given to PDs by GDCP not to issue import certificate mentioned firm until corrects its deficiencies. İstanbul PD asked the mentioned firm to correct their deficiencies. After inspection of that firm, PD decided the deficiences are corrected and informed last situation of firm to the GDPC and the issuing of certificate for export to EU are started again at Instructions and İstanbul PD report are given in Annex 3, Annex 4 and Annex 5, respectively. 8

8 9) To ensure that casings are only reexported In the Instructions of the General Directorate to the EU provided they come from countries and of Protection and Control ( /17819 and /26432), there exists the A new veterinary health certificate for importation of casings intended for dispatch establishments listed in provision that when the casing to the EU was prepared and the veterinary Commission Decision establishments approved for exportation to health certificate in question is enclosed for 1999/120/EC (as amended) and the EU use imported raw materials, your consideration (Annex 6). the certificate provided on importation of casings should be made from After taking your confirmation on enclosed importation to Turkey provides all countries/establishments which have been veterinry health certificate it will come into guarantees required for export approved by the EU, that traceability is force. certification to the EU. provided, and that the country of origin is specified in the health certificate. To this end, the certificate drawn up for exportation the EU shall be revised. 10) To update the model certificate for exports of casings to the EU and ensure appropriate controls over export certification. Model certificate for export of casings to EU Health certificate for export of casings to will be updated to comply with Commission EU was updated to comply with Decision 2003/779 EC Annex IA Commission Decision 2003/779 EC Annex IA and is enclosed for your consideration (Annex 7). After taking your confirmation on enclosed health certificate it will come into force. 9

9 11) To ensure that official controls in milk-processing establishments proposed for approval for export to the EU take specific EU requirements into account. In accordance with the recommendations of The was completed. By the the mission, administrative procedures shall Instruction dated numbered be established and put into effect in the Provincial Directorates are shortest time possible, to continue the reinstructed by GDPC to control the official controls. companies in means of fulfilling EU conditions during inspections which take place for approval purposes. Furthermore, a new additional Instruction about heat requirements regarding to approve establishments has been signed and come into force (Annex 8). 12) To ensure that food business operators initiate reliable own checks to ensure compliance of raw milk with the criteria set out in annex III, section IX of Regulation (EC) No 853/2004. As specified in Annex III, Part IX of Directive 853/2004, establishments processing raw cow s milk have established their systems and started operation to conduct milk quality on holding basis with respect to TBC and SCC for products intended for exportation to the EU. In order to meet this requirement fully in other raw milk entering the holding, measures are being taken to correct this situation in compliance with Article III, 1(b) of part IX, Annex III of Directive 853/2004/EC. These programmes being implemented shall be monitored by the Provincial Directorates. According to the Instruction dated numbered (see Annex 9), the food business operators must be initiate reliable own checks to ensure compliance of raw milk with the criteria set out in Annex III, section IX of Regulation (EC) No 853/2004. Besides, PDs are instructed by GDPC to perform detailed analysis of self control results and traceability procedures implemented by establishments. (See Article 7 of Annex 1). 10

10 13) To ensure full internal traceability in establishments that also process non-eu eligible raw material (casings or milk-based products). As per Article 18 of the Regulation on Market Necessary official procedure related Monitoring, Control and Inspection of Food and traceability already given in the column, Substances and Materials Intended to Contact Action Proposed by Competent Authority Food and Responsibilities of Establishments, of this report. Furthermore, a new the establishments producing food must have a instruction was given to the PDs regarding system to ensure and monitor traceability in all to audit of internal traceability of stages of raw material supply, production, processing, storage, distribution, selling and establishments (See Articles 7, 9 and 10 of consumption, in order to identify a material Annex 1). expected or envisaged to be found in food, foodstuff, or plant or animal from which the food is obtained. They should record all the particulars concerning the subject and submit them to the competent authority. At the same time, they must review the traceability system at least once a year to verify that the system is operational and to record the system, and must label and identify the food and substances and materials intended to contact food they offer in the market, covering lot no and/or serial no and/or production no and/or code no and other particulars, to facilitate traceability, provided that compliance with the Turkish food legislations is ensured. Taking into account the recommendations of the mission, this issue shall be followed up by the competent authority. 11

11 14) To ensure that official laboratories involved in official analyses of milk-based products intended for export operate quality control schemes for the analyses required. Instruction was communicated to the Necessary information is given second laboratories of the Ministry in 2002 by the column of this report. GDPC to conduct their activities on the basis of sound quality management and to get accreditation. Thus, the laboratories attached to the Ministry are continuing their accreditation efforts within a defined schedule. As of August 7, 2006, 9 Provincial Control Laboratories and the Etlik Central Veterinary Control and Research Institute Directorate have been accredited. These efforts shall continue. 12