14/ 05/ 2012

As a result of EBA’s lobbying efforts the State Veterinary and Phytosanitary Service of Ukraine (hereinafter – SVPS) issued the Letter №15-3-2-14/4045 of 8 May 2012 that simplifies the procedure of documentary accompaniment of finished foodstuffs of animal origin in the process of their internal distribution.

Background: According to the Order of SVPS “On Approving the List of Goods Subject to Veterinary Certificates” of 26 January 2010, finished food products were to be accompanied by veterinary certificates of Form No. 2 (hereinafter – Form 2) in the process of their internal circulation within the territory of Ukraine. However, this requirement contradicted with the article 2 of the Law of Ukraine “On Veterinary Medicine” No. 2498-ХІІ of 25 June 1992 which says that this Law does not concern the products of animal origin for human consumption in the process of their production and internal circulation.

The use of Form 2 at every stage of internal distribution to the end consumer was inexpedient due to the following reasons: every batch of finished goods is accompanied by quality certificate issued by producer where all relevant information according to the Law “On Safety and Quality of Food Products” No. 771/97 of 23 December 1997 is indicated; packaged foodstuffs are marked and every batch is accompanied by consignment document so that their identification can be easily done if needed; there is an official veterinary doctor controlling all production processes at every plant (according to the Laws on safety and quality of food products and on veterinary medicine); with the entry into force of the Law “On Responsibility for Damage Caused due to Defects in Products” No. 3390-VI of 19 May 2011, responsibility of producers and suppliers is formalised. Furthermore, in EU countries as well as in Russia food products turnover is not accompanied by veterinary documents.

The mandatory issuance of Form 2 at every stage of internal circulation complicated food and dairy producers’ operations and led to significant veterinary expenses, consequently increasing the cost of production, while not preventing falsified products appear on the shelves.

Therefore, EBA Dairy, Food and Retail Committees have been strongly advocating the cancellation of Form No 2 for finished foodstuffs at each stage of their distribution through a number of meetings with the leadership of the SVPS and numerous appeals to the relevant state authorities.

As a result of the joint Round Table hold on 12 April 2012, the SVPS issued the Letter which explains that for internal circulation of finished foodstuffs of animal origin the official (authorized) veterinary doctors issue the veterinary certificate for each batch of finished foodstuffs that remains within the producing facilities. Further circulation of foodstuffs is done given the availability of producer’s declaration issued in accordance with the Article 21 of the Law of Ukraine “On Safety and Quality of Food Products” where the producer indicates the number and date of veterinary document’s issuance.

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