Food Additives Under DCFTA Policy Paper

At the same time, it requires an extensive approximation of norms and regulations in various sectors, including food additives. New regulations required by approximation can cause high compliance costs, particularly in the food processing sector which is underdeveloped in Georgia compared to EU countries. The AA and DCFTA do not obligate Georgia to copy laws verbatim from the EU. Rather, approximated laws need not be more trade-restrictive than necessary to fulfill a legitimate objective. This policy paper covers approximation requirements from the AA and DCFTA in the area of food additives. Food additives are only one element of food safety. Food safety also includes a number of hygiene-related matters, ingredients, flavorings, and enzymes; these other elements are not part of this policy paper. The authors of this policy paper met with key informants (experts), representatives of government and business, and organized a public-private dialogue to understand concerns vis-à-vis new food additive requirements. Also, e-mail communication was used with representatives of several EU and Member Countries' institutions involved in food safety. Their comments and insights were synthesized into a number of policy issues and recommendations for solving the root causes of the policy issues as shown in this policy paper. The DCFTA requires approximation to EU regulations concerning food additives. Food additives and this policy paper concern primarily Regulation (EU) No. 1333-2008 (food additives) and less so Regulation (EU) No. 1331-2008 (common authorization procedure), plus a number of implementing regulations for both. To the end, food additive regulation rests on a list of substances that can be added to foods for a technological objective. Regulation (EU) No. 1333-2008 contains a positive list of food additives that are permitted, as well as the types of foods in which particular food additives can be used. Use of the Community list is mandatory. Countries can specify more restrictive limits on food produced in their country but they cannot impose that more restrictive list on foods produced elsewhere and sold in their country. Georgia's regulations on food additives are out of date and do not at all meet the approximation requirements of the association agreement. Georgia does not have the delegated competencies or staff that would permit enforcement of food additive requirements if they existed. Knowledge of modern food additive technologies is limited among Georgian food operators. Food businesses in Georgia lack access to effective informational tools and methods. The laboratory infrastructure for testing for food additive infringements is weak. Funding for most food additive matters is very limited. To address these challenges, the authors recommend that Georgia adopt the Community List of Food Additives (shown in Regulation (EU) No. 1333-2008) equivalently. Businesses and government should be given sufficient time for implementation. Regulations should be created to enable official but voluntary certification of foods as meeting the requirements of the Community List. Imported food additives must be controlled more rigorously. Food businesses should have access to effective informational tools and methods. A network of accredited laboratories should be created for food additive testing. A project should be undertaken to set a budget for all the preceding recommendations.