The EU’s directorate-general for health and food safety has published the results of its audit of India’s shrimp export controls, conducted Nov. 20-30 2017. The Seafood Trade Intelligence Portal (STIP) — which has links to Dutch organization Solidaridad, and has been working to facilitate talks between Indian exporters and EU importers — noted it was surprised by some of the outcomes of the audit. Note, the EU commission is not likely to take action on current policies before the audit report of the residue monitoring plan audit carried out in April this year is also published, STIP said. “I must say that I am, myself, slightly surprised by the fact that the report does not only include negative conclusions on the level of control on primary production, but also on the overall manpower of the Indian institutions and the level of cooperation between the various institutions; and the incomplete follow-up of recommendations of the 2014 audit,” wrote STIP director Willem van der Pijl. “In general, the report is a bit more negative than I had expected based on earlier news from Indian and EU sources. However, the recommendations at the end of the report seem to be rather limited compared to the number of negative conclusions throughout the report.” The European Commission has concluded with three new recommendations for Indian authorities, mainly centered around the relevant authorities better cooperating to ensure effective inspections (see final subhead below). The headline for the audit’s overall conclusion was positive; that “the official control system currently in place for the EU fishery products export chain is based on legislation and control procedures which, if implemented as foreseen, should be capable of providing adequate assurance that such exports meet many of the requirements set out in the EU health certificate”, the report reads. However, this official control system does not apply in respect of aquaculture farms for domestic production, which in many instances share the same water and streams as farms providing material for export, auditors found. “While these domestic producers were identified as a risk for neighboring export farms, they are not covered by an official registration and inspection system.” The EU team also had concerns over the fact that landing sites and fishing vessels are registered and inspected, but cooperation between the various competent authorities and the recording of inspections “are not sufficient to ensure full compliance with the legislation in place”. Again, auditors were satisfied that when it comes to the listing and control of EU listed establishments, the system as documented covers EU requirements adequately “with only minor shortcomings”. However, it was not happy with corrective actions put in place to address deficiencies identified by the EU back in its 2014 audit report. And, as a bottom line, the report states: “The deficiencies identified in the course of the current audit, both in terms of the control system’s coverage as well as in its implementation, do not allow the competent authorities to provide, and attest to, all the guarantees set out in the EU health certificate.” Views on EIC, MPEDA Undercurrent News sources had speculated, when rumors of EU issues with Indian farmed shrimp first began to circulate, that the problems were more political than they were quality-based. Of the Indian institutions responsible for monitoring the quality of exported shrimp, the EU auditors said the Export Inspection Council (EIC), Export Inspection Agency (EIA), and Marine Products Export Development Authority (MPEDA) structures and organization; the independence of staff; and their control and enforcement powers; “allow them to perform their assigned tasks”. There are adequate procedures in place for an official control system, the report adds, and the procedures for the supervision of control staff ensure effective verification of their performance and are suitable to detect and address non-compliances in the implementation of the official control system. But, auditors felt that only India’s state-level fisheries department had a sufficient number of official staff to achieve an adequate level of control over primary production, including domestic production — which they worry could impact on the water quality of export farms. “The staff numbers of EIA and MPEDA are limited in comparison with the numbers of aquaculture farms and fishing vessels which provide raw material to EU export facilities — too low to control effectively the primary production sector.” The auditors were concerned the systems in place do not cover every individual pond, but rather only each “farm”. Elsewhere, the EU report found the official system for approval and listing establishments exporting directly to the EU is adequately implemented. It also found there is an official control system in place covering the production chain of fishery products intended for export for the EU; controls of fishing vessels and landing sites have improved compared to 2014, because EIA has introduced a basic inspection scheme for fishing vessels, landing sites and auction halls, it said. However, deficiencies were found in several cold stores, like incorrect temperature registration, too high temperatures and inadequate storage, undetected by the relevant authorities. Other issues were cropping up in the fishing sector which, in some states, would have been detected by either the state fisheries department of the EIA, but the two do not cooperate. Improvements on 2014? As mentioned above, the EU report was not entirely satisfied with how Indian authorities have followed up recommendations made in 2014. On fishery landings, the competent authority was expected to have implemented an official control system to monitor primary production within a realistic time frame; the state fisheries department does not adequately record the results of inspections to facilitate effective follow-up, while EIA has just recently started to do inspections. Authorities were asked to ensure aquaculture farms that supply EU-approved establishments are regularly inspected; EIC has started to implement inspections at farm level, but with only a 2% frequency, the audit found. Moreover, incidences of “rapid alert system for food and feed” (RASFF) follow-ups do not lead to inspections of nearby sites, in all cases. Fishing vessels, landing sites and first sale sites are still not inspected with regularity, the report adds. New recommendations The European Commission has given three new recommendations based on the outcomes of the November 2017 audit, STIP noted: 1) The competent authority should take measures to enhance cooperation between the different services to achieve an adequate number and range of inspections covering the identified risks, in particular regarding contamination of water by neighboring aquaculture premises; 2) It should take measures to enhance the cooperation of inspection services regarding the implementation and recording of vessel and landing site inspections; and 3) It should ensure that fishery products destined for export to the EU are stored under hygienic conditions to provide full guarantees. Full Report is available at: https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=2&cad=rja&uact=8&ved=0ahUKEwj54PvuxYrbAhUIK8AKHXpXAkoQFggtMAE&url=http%3A%2F%2Fec.europa.eu%2Ffood%2Faudits-analysis%2Fact_getPDF.cfm%3FPDF_ID%3D13669&usg=AOvVaw1HBIgyOsyCnls43DSV82nl