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Guidelines for the Health Certification of Consignments of Foodstuffs Destined for Export to other Countries from South Africa

Department of Health

Directorate: Food Control

October 1999

Table of Contents

  1. Introduction
  2. Definitions
  3. Background Information Related to the Issuing of a Health Certificate
  4. Types of Health Certification
  5. Responsibilities of the various Role Players Involved in Health Certification
  6. Criteria for Health Certificates
  7. Other Parties Involved in the Certification of Foodstuffs Destined for Exports
  8. Role of the Codex Committee on Food Import and Export Inspection and Certification Systems (CCFIECS)

References

  1. Introduction

Since returning to the international arena, many export opportunities are presented to producers/ manufacturers in South Africa of, amongst others, foodstuffs on overseas markets. This resulted in a drastic increase in the exportation of consignments of all kinds of foodstuffs to countries all over the world, including the rest of Africa. This has lead to an increase in requests received by the health services at the various levels of the health system for the issuing of certificates related to various health related aspects regarding the status of the foodstuffs destined for export from a food safety point of view. These certificates are normally required by the relevant authorities controlling the importation of foodstuffs of the countries where the consignment exported from this country are destined for and is considered to be part of the essential documentation which a prospective exporter of foodstuffs must obtain to ensure the success of its overseas business venture.

At present, no health related food safety or food control legislation in South Africa provides for any arrangements or requirements related to the issuing of a health certificate for consignments of foodstuffs destined for export. In view of the serious implication for the country, (internationally, politically and economically), which this matter, if handled in an irresponsible and unprofessional manner by officers of the various health authorities can have, a need was identified by the Department of Health, Directorate: Food Control for the development of this guideline document.

The aims of the guideline are therefore to:

bulletAssist health authorities, more specifically the Environmental Health Services of provinces and district or local authorities to address the issuing of health certificates in a systematic and internationally acceptable manner.
bulletAssist prospective exporters, (manufacturers or their agents), of foodstuffs with information related to the issuing of health certificates and how, amongst others, to obtain such certificates.
bulletEnsure uniformity regarding the issuing of health certificates by all the health authorities in South Africa based on national and international norms and standards set in this regard.
bulletProvide information on other role players involved in the certification of foodstuffs related to matters other than health, as well as examples of documents related to health certificates for utilisation by health authorities.

The information contained in this document is mainly based on and updating of the official documents previously issued by this Department on the matter in question, as well as on the decisions of the Codex Committee on Import and Export Inspection and Certification Systems (CCIEICS), including the General Requirements (Volume 1A) of the Codex Alimentarius Commission.

  1. Definitions

"Certifying officer" refers to a person such as an Environmental Health Officer, who is employed by a competent health authority within the national health system and who has been specifically authorised, or by virtue of his official functions related to food control authorised to compile, sign and issue a health certificate related to the compliance to health requirements of a consignment of foodstuffs destined for export as based on the criteria specified by the importing country.

"Competent Health Authority" refers within the national health system of South Africa to the relevant national, provincial, district or local authority which is mandated to attend to food safety/control matters, including the issuing of a health certificate as described by these guidelines and as determined by the relevant authority of the importing country who required the certificate in question. Within the present arrangement, the Directorate: Food Control of the Department of Health is the competent authority at a national level, while at the other levels mentioned, the Environmental Health Services will be the authority unless otherwise arranged.

For the purpose of these guidelines, any reference to a "Competent Authority", will refer to a party other than a health authority who is also involved in the certification of consignments of foodstuffs destined for export, such as the Department of Agriculture or the South African Bureau of Standards (SABS), depending on the foodstuff and/or reason for certification under consideration.

"Consignment of foodstuffs" refers to a specific batch/lot of foodstuffs as specified on the relevant export documentation of the exporter and which can be identified by the certifying officer for inspection/sampling purposes, depending on the nature of the certification as determined by the importing country.

"Export" refers to the exporting of consignments of foodstuffs produced/processed/manufactured in South Africa and destined for any other country.

"Exporter" refers to a person or body requesting a health certificate as described by this guideline, including the producer/manufacturer of the consignment of foodstuffs destined for export, or his agent/assignee.

"Food safety" refers to the assurance that food will not cause harm to the consumer when it is prepared and/or eaten according to its intended use.

"Food Control" means a mandatory, regulatory activity of enforcement by the competent health authority to provide consumer protection and ensure that all food during production, handling, storage, processing and distribution is safe, wholesome and fit for human consumption; conform to safety requirements; and are honestly and accurately labelled as prescribed by law.

"Health Certificate" refers to an official written document issued and signed by a certifying officer employed by a competent health authority, containing full details of the food safety related status of a consignment of foodstuffs destined for export, as prescribed by this guideline and in compliance with the criteria specified by the relevant authority of the importing country, and where "Health Certification" has a similar meaning.

"Importing country" refers to any country to which a consignment of foodstuffs produced/processed/manufactured in South Africa is destined to be exported to.

"Safe (or fit) for human consumption" when referring to the health status of a consignment of foodstuff(s) certified as based on this guideline and when including the mentioned phrase in the contents of a health certificate, means compliance of the specific consignment to all the health related legislative requirements of South Africa for the foodstuff(s) in question.

  1. Background Information Related to the Issuing of a Health Certificate

The following information is included in the guideline to ensure that a uniform approach is followed by the various competent health authorities; to emphasise the importance of ensuring that this matter is dealt with in a responsible and professional manner by all concerned; and to prevent problems related to the certification as presently experienced.

3.1 Internationally, certificates have become increasingly important for facilitating trade, including health certification of foodstuffs destined for export and it has become an established component of trade activities related to any kind of foodstuff. While there is a steady increase in reliance on certificates, it is however possible to conduct trade between countries without their use.

Certificates, including for health related matters, have developed independently over the years with the result that there can be a great variation between countries in content requirements. The difficulties presented to, amongst others, health authorities, relate to the issue of health certificates that meet the needs of the importing country and the lack of consistency between countries in relation to the specific information needed for clearance of consignments of foodstuffs at the point of entry.

3.2 The Foodstuffs, Cosmetics and Disinfectants Act, 1972 (Act 54 of 1972) at present contains no provisions related to export matters. A competent health authority, including local authorities authorised in terms of Section 23 of the mentioned Act, should therefore be aware that any activity related to the certification of foodstuffs destined for export is not covered by the Act.

In view of the economic importance of, amongst others, the exportation of foodstuffs to the development of the country, it is important for the health authorities concerned to ensure that they are capable to assist prospective exporters regarding the health certification of consignments of foodstuffs destined for export. This aspect should therefore be considered an essential element of the food control related service rendered by these authorities to the food industry of the country.

3.3 Due to the international implications, which the health certification of the foodstuffs in question can have for the country, both from an economical and political point of view, it is crucial for the competent health authorities involved in the certification process to ensure that it is carried out in a responsible and professional manner. The indiscriminate issuing and signing of health certificates is not just unethical, but could also lead to great embarrassment for those concerned; loss of trade opportunities; and damage the reputation of the country as an exporter of high quality and safe foodstuffs. A situation where, for example, a certifying officer of a competent health authority certifies that a specific consignment of foodstuffs has been sampled and found to comply to compositional standards, (chemical or microbiological) which is then rejected by an importing country at the time of entry based on the results of their own sampling which indicates that the consignment does in fact not comply, will not be acceptable and may even result in financial claims against the health authority involved.

The responsibility to ensure that a health certificate contains the correct and true information is that of the certifying officer and the competent health authority involved.

3.4 It is the prerogative of the importing country to indicate which aspects related to a consignment of foodstuffs destined for that country must be certified, as well as by whom the certification should be carried out and in what format they require the certification. Although the Codex Alimentarius Commission has set guidelines regarding the Principles for Food Import and Export Inspection and Certification, which is further discussed and elaborated on by the relevant Codex Committee of the Commission, importing countries in most cases determine their own requirements in this regard.

In general, the less sophisticated countries, (developing countries), require less stringent certification than the more sophisticated countries, which in many cases only accept certification carried out by a body assigned or accredited by such country to deal with this matter. Certificates containing declarations such as "fit for human consumption", and/or, "the foodstuff certified is freely available in this country", will in some instances be sufficient for certain importing countries, but should where possible not be included on official certificates without proper verification of the health status of the consignment under consideration.

  1. Types of Health Certification

Various types of health certification, based on by whom it is carried out as well as for what purpose it is required, exists which for clarity purposes is described as follows:

4.1 Voluntary and Official Certification

Voluntary certification refers to those situations where an importing country is satisfied that the exporter self carries out the required certification, or arranges for a third party, in other words, not the competent health authority, to carry out the certification on his behalf. This is also referred to as "company certification".

Official certification refers to the certification process that can only be handled by a competent health authority in this country as recognised by the importing country and that the documentation resulting from the process will be considered as officially issued by the relevant authority.

This guideline is intended mainly for use by officers employed by the various health authorities and is therefore aimed assisting with the issuing of official health certificates.

4.2 Compliance Certification

Compliance certification can be divided into the following types based on the various aspects related to the safety for human consumption of the consignments in question:

  1. Product related compositional and/or labelling requirements: Certification of compliance to the compositional characteristics, (chemical and/or microbiological) of a specific foodstuff and/or its labelling as based on the provisions of the Foodstuffs, Cosmetics and Disinfectants Act, 1972 (Act 54 of 1972) and more specifically the wide range of regulations published thereunder. Where no provision is made in the mentioned legislation for a compositional or labelling requirement which health certification is requested for by the importing country, without specifying its own requirement, the requirements specified in the relevant codes of practice or guidelines of Codex Alimentarius will be applicable. In some instances, the importing country will specify its own requirements, which a competent health authority should verify and include in the certificate.
     
  2. Facility related structural and/or hygiene requirements: Certification of compliance to the structural and/or hygiene related requirements of the facility where the consignment has been produced or manufactured as based on the provisions of the Health Act, 1977 (Act 63 of 1977) and more specifically the food handling and food premises related regulations published under the Act, as well as the provisions of the relevant by-laws of local authorities where applicable.

In addition, various hygiene related codes of practice or guidelines have been developed by Codex Alimentarius, and if requested by the importing country, the competent health authority should apply these requirements.

  1. Contamination related requirements: Certification of compliance to the requirements of Act 54 of 1972 related to aspects such as pesticides, heavy metals and radio-active residue’s, as well as filth and other substances such as insect and plant parts which can be present in foodstuffs. All the mentioned contaminants are associated with the environment in which food is produced or processed and should meet acceptable levels as prescribed by the relevant regulations or guidelines.
     
  2. Food Treatment related requirements: Certification of compliance to the requirements of approved processes by which foodstuffs can be treated to ensure the safety thereof such pasteurisation, UV treatment, irradiation, etc.
     
  3. Safety Management systems related requirements: Certification of compliance to the requirements of a HACCP system, or a similar system based on the principles and process of a HACCP system as specified in the relevant guideline of Codex Alimentarius. HACCP auditing and certification can only be conducted by a person or body suitably assigned or accredited to conduct the mentioned activities, and a competent health authority will have to base this kind of certification on documented evidence submitted by the exporter in this regard.

In conclusion, it is important to note that a competent health authority may be approached by an importing country for the certification of any one of the above-mentioned; or for all of it; or for any combination of more than one of the requirements as stated. In all cases, the certifying officer must, however, be very certain what needs to be certified when requested to do so.

  1. Responsibilities of the various Role Players Involved in Health Certification

Various role players are involved in the health certification process and it is important that they have clarity on what their respective responsibilities are to ensure that the matter is dealt with in an effective and professional manner. The following is a description of the responsibilities of the different role players which should be applicable under normal circumstances:

  1. The Importing country:

Although the purpose of the guideline is not intended for use by countries to which foodstuffs from this country is exported to, it was considered to be necessary to give an indication of what can be expected from the relevant authorities in such countries when requesting health certification. It will be the responsibility of the exporter to ensure that the aspects mentioned hereafter, are attended to by the importing country:

  1. An exporter and/or competent health authority should only be asked to certify matters which can be reasonably expected to be within its ability to ascertain, or be in a position to obtain such information from another authority or other source at its disposal
  2. What from a health point of view needs to be certified and the criteria or requirements to be certified. must be clearly stated in writing, including which level of the competent health authority in this country will be required to issue the health certificate in question.
  3. If specific requirements regarding the format and contents of the health certificate requested is required, clear written instructions together with an example of the certificate should be made available to the exporter and/or competent health authority.
  1. The Exporter:
  1. Ensure that full details of the certification required by the importing country as described above are included in the written request for the health certification of a consignment of foodstuffs submitted to the competent health authority, (national-, provincial- or local authority), as determined by the importing country.
  2. Ensure that that all written requests for certification as described under point 1 above takes place prior to consignments of foodstuffs destined for export leaves the premises where it can be inspected and/or sampled by the competent health authority in question.
  3. Pay all costs related to the health certification as requested incurred by the competent health authority, if requested to do so, and as determined by the health authority in question. This may include, inter alia, costs related to the despatch and analysis of samples and administrative costs such as travelling etc.
  1. The Competent Health Authority:

After receiving a written request by an exporter containing clear details of the requirements of an importing country, as described above, as well as taking into account the aspects mentioned under Chapter 3 of these guidelines, the competent health authority must ensure the following:

  1. Ensure that a procedure for the effective processing of requests for certification received is established and that staff properly aquatinted with the contents of this guideline attends to the requests in question.
  2. In preparation for the certification of a consignment based on a written request received from an exporter, take steps to verify whether the foodstuffs comply to the requirements as stated by the importing country by means of the results of, inter alia, inspection reports, analysis of sample reports, etc.
  3. Ensure that no certification of consignments which have already been removed from the exporters premises or been shipped is carried out.
  4. Ensure that the contents of drafted certificates are fully understood by the certifying officer employed by such an authority and that it meets all the requirements of the importing country as stated by the exporter.
  5. Ensure that proper record is kept of the certification carried out by such an authority, including the allocation of a unique reference number for each certificate issued and keeping of copies of all documents verifying compliance of the consignment in question.
  1. The Certifying Officer:
  1. Only an officer properly authorised by the relevant health authority by means of an official document of authorisation or deriving from his normal official duties, may carry out the certification of consignments.
  2. Ensure that the contents of certificates issued by him are based on correct, true and prior verified information and meet the needs of the importing country.
  3. Ensure that certificates contain full details related to the information required for the contents of such certificates as specified by this guideline.
  4. Ensure the following regarding the proper processing and record-keeping of all certificates handled by him:
  1. Certificates should always be issued and presented to the exporter in the original. Only one original certificate in respect of each consignment should be issued.
  2. A copy of the certificate (clearly marked "COPY") should be kept as a record by the health authority.
  3. Where for any good reason (such as damage in transit) a duplicate certificate is issued, it must be clearly marked "DUPLICATE" before being issued.
  4. The issuing of so called "standing certificates" to be used again for the export of further consignments at a later stage is not permitted.
  1. When signing a certificate, the officer must ensure that:
  1. The certificate contains no deletions other than those required by the text of the certificate.
  2. Any alterations of the certified information must be initialled and stamped by the certifying officer.
  3. The certificate bears the signature, name, address and official position of the certifying officer in clear lettering and, where appropriate the qualification of the officer.
  4. Wherever possible, the officer should sign, stamp and complete any manuscript portions in a colour of ink which does not readily photocopy, i.e., colour other than black.
  5. The certificate bears the date on which the certificate was signed and issued and, where appropriate, the time for which the certificate will remain valid.
  6. No portion of the certificate is left blank, so that it can be completed by some person other than the officer.
  1. When analysis of samples of a consignment is required, ensure that if not sampled by the certifying officer, the sampling is carried out by an authorised person and not by the exporter; that each consignment is appropriately sampled; and, that the samples derive from the consignment to be exported.
  2. No officer should be involved in the issuing of a certificate which relates to a consignment in which the official may have a financial gain
  1. Criteria for Health Certificates

In general, certificates should contain essential information that meets the requirements of the importing country and the information requested should be no more than that which is necessary for the application of relevant legislation and/or standards specified by such country,

The information contained in certificates should be kept simple and for security and practical reasons be restricted to a single page that may utilise the reverse side.

Regarding the contents and format of health certificates, the certifying officer must ensure that, unless specified otherwise by the importing country, the following information is included in a certificate:

  1. Technical information: These information pertain to the certificate identification, as well as identification of the particular consignment, including:
bulletDetails of the consignment, including identification and volume of the product and lot/batch numbers of the foodstuffs;
bulletDetails of the exporter and, if required, the consignee in the importing country;
bulletDetails regarding the mode and time of transport and product destination;
bulletThe identity of, and details on, the competent health authority involved; and
bulletUnique identification number of the certificate.
  1. Statement of origin: The place of origin of a consignment may be derived from the technical information provided in the certificate, for example, the origin may be same country as the exporter. Where, however, omission of the country of origin may lead to confusion or be misleading, this information should be specifically declared.
  2. Health attestation: The certificate should include an attestation by the competent health authority of the compliance of a consignment to the relevant health requirements as specified by the importing country.
  1. Other Parties Involved in the Certification of Foodstuffs Destined for Exports

To enable health authorities to assist prospective exporters regarding the certification of consignments by the relevant authorities other than health, a short description of the role of the National Department of Agriculture and the South African Bureau of Standards (SABS) regarding the matter in question is included in the guideline.

7.1 National Department of Agriculture

Various Directorates of the Department are involved in the certification of certain aspects of foodstuffs. The Directorate: Veterinary Public Health attends to the export of fresh meat in bulk, chilled and frozen, including poultry, as well as in some cases on the request of an importing country, to animal products such as egg products. The certification includes the health related compliance of the foodstuffs in question, as well as compliance to the Sanitary and Phytosanitary (SPS) related requirements of the relevant World Trade Organisation agreements.

The Directorate: Plant Production, Health and Quality Control also attends to certification related to SPS requirements of those foodstuffs covered by the regulations published in terms of the Agricultural Products Standards Act, 1990 (Act 119 of 1990), as well as for the quality of the foodstuffs in question for which regulations related to export standards have been promulgated. The Directorate also appoint assignees to deal with the certification of certain products destined for export, such as the Perishable Products Export Control Board (PPECB) for, amongst others, fresh fruit. The certification mentioned includes safety related aspects, such as pesticide residues, and the relevant assignee is normally recognised or accredited by the importing country.

7.2 South African Bureau of Standards (SABS)

Based on compulsory specifications published by the SABS in terms of the Standard Act, 1993 (Act 29 of 1993), the Bureau attends to the certification of the following foodstuffs destined for export:

bulletCanned fish, marine molluscs and crustaceans
bulletFrozen prawns (shrimps), langoustines and crab
bulletFrozen rock lobster
bulletFrozen fish and marine molluscs
bulletCanned meat
bulletSmoked snoek

Although not a government department or authority, the SABS is considered to be the competent authority to certify consignments of the mentioned foodstuffs and as such is also normally recognised or accredited by the importing country for this purpose.

In conclusion, health authorities should where necessary assist exporters by referring them to the relevant authority as described above for the certification of the foodstuffs and/or aspects mentioned.

  1. Role of the Codex Committee on Food Import and Export Inspection and Certification Systems (CCFIECS)

The CCFIEICS is one of the world wide general committees of the Codex Alimentarius Commission, a joint body of the FAO and WHO attending to the formulation of standards for food moving in international trade. The Committee attend to, amongst others, the principles for food import and export inspection and certification.

During the drafting of these guidelines, an attempt was made to incorporate the decisions of the Committee related to the certification of foodstuffs destined for export into the document and any further developments in this regard will be taken into account when up-dating the document.

References

Codex Alimentarius: Principles for Food Import and Export Inspection and Certification, Volume 1A, 1995.

Department of Health Memorandum: Voedsel, Kosmetika en Ontsmettingsmiddels: Riglyne ten opsigte van Uitvoersertifisering, Pretoria, August 1991.

Report of the Fifth Session of the CCFIEICS, Codex Alimentarius Commission, FAO/WHO, Rome, March 1997.

Report of the Sixth Session of the CCFEICS, Codex Alimentarius Commission, FAO/WHO, Rome, March 1998.

 

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