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For Your Information F9/09: Russia: Listing of Dairy Premises

New Zealand Food Safety Authority
Date: 16.2.09 (4)
From: Phil Ward, Market Access Counsellor (Europe)

1 Background

1.1 The Russian veterinary authority, Rosselkhoznadzor, is progressively implementing a premises listing regime similar to that operated by the European Union. Meat premises were listed several months ago and fish premises were visited by Russian auditors in December and final approval of listing is awaited.

1.2 Rosselkhoznadzor has written to NZFSA seeking a list of dairy premises by 1 March 2009. Rosselkhoznadzor has made it clear that any list proposed by NZFSA should only include those individual premises with a history of trade with Russia and which currently have contracts with Russian importers for their products. NZFSA must also provide guarantees that these premises are under NZFSA’s constant control and will implement Russian veterinary and sanitary requirements and norms in full. NZFSA is seeking an English copy of the norms.
Note: Rosselkhoznadzor checked the fish premises against information from their importers and rejected those without identifiable trade.

1.3 The dairy regime of unique location identifiers allocated to each processing department and store at the site is not a requirement under the Animal Products Act except for multi-site RMPs where a unique location identifier for the site is necessary for traceability. The simplest approach for any situation is one ID covering all the regulatory needs of the physical site. For example ‘DAIRY1’, comprising the range of buildings and facilities at a single site is made up of one or more RMPs identified as DAIRY1/01, DAIRY1/02, etc. The identifier DAIRY1 is also used for labels and country listings. There is no need for dairy and other animal products operations at the same site to have different IDs. One ID can cover everything.

1.4 A variation to the above is common in the dairy industry. A single site identifier for labels and country listings is issued in addition to the RMP identifier. This has the benefit of the label and country listings number remaining stable despite fluctuations in RMP numbering but is more difficult to administer. NZFSA and operator records must maintain the linkages between listing and RMP numbers and the result must be transparent to foreign auditors. Extra flexibility comes with a higher chance of audit failure. Audits by foreign governments will increase in the future.

1.5 Either of the options in the previous two items is satisfactory for Russia. It is not inconceivable that other variations will confuse the Russians and cause listing problems that may lead to a disruption of trade. Multiply IDs per site issued for regulatory purposes are sometimes considered suspect by foreign auditors because this can inadvertently allow delisted premises to continue operating under one of the other IDs.

2 Action

2.1 Operators of processing premises who can fulfil the requirements of existing trade and identification of Russian clients should submit their application by 26 February, either directly or via the company head office, to the Programme Manager (Compliance), NZFSA Compliance and Investigation Group. lindsay.nicholls@nzfsa.govt.nz

2.2 The template for the list is reproduced below. The ‘administrative-territorial unit’ is described in clause 3.9.3 of the Russia OMAR. ‘Types of products’ and ‘plant production capacity’ are generic refer to the full range of products at the premises. ‘Sequence number’ and ‘type of plant activity’ are left blank.

List of New Zealand plants producing milk and dairy products

Disclaimer: This ‘For Your Information’ is intended for use as a guideline only and should not be taken as definitive or exhaustive. NZFSA endeavours to keep this information current and accurate. However, it may be subject to change without notice. NZFSA will not accept liability for any loss resulting from reliance on this information.