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From: Ashok Boss Sharma [mailto:ashok_b_sharma@hotmail.com]
Sent: Friday, 28 November 2003 14:58
To: fao.who.psaforum
Subject: Comments on Papers 1a,1b,1c,2a,2b,2c,3a,3b,3c,3d

From : Ashok B Sharma, New Delhi, India
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Large variations in sanitary and phytosanitary (SPS) norms in the developed world for specific food products have placed the exporters in the developing countries in a difficult situation.

The SPS norms in US differ from that in European Union to a great extent. Dr Antonie Kabwit Nguz in his views on October 13 rightly cited an example that the permissible limit for total aflatoxins in US and Australia in food and feed is 20 ppb while the EU has imposed 1 ppb as the permissible limit for B1. The EU norms are usually higher than the Codex norms. Also the permissible limits for the presence of micro-organisms and bacterial agents in fresh fruits and vegetables and the related guidelines differ largely in the standards formulated within European countries like UK, France and Germany. The European standards in relation to fresh fruits and vegetables differ largely with that in South Africa.

These large variations in SPS norms in the developed world raises doubts about the intention of blocking trade from the Third World.

Dr Antone Kabwit Nguz has also informed us that EU has begun the exercise of harmonising the permissible pesticides residues limits in food since 1993 and this is yet to be completed. At present the EU member countries follow their own norms which vary greatly from country to country. About 100 pesticide have come under regulations in EU member countries. For some of the pesticides used in developing countries on crops meant for exports, the permissible limits of its residues on food and feed have been fixed at the level of determination (LoD). This may make export consignments to Europe liable for rejection. The permissible limits set at LoD level will require more sophisticated and sensitive analytical equipment for detection. The developing countries do not have such technologies for detection.

The supermarkets in Europe, particularly in UK are gradually implementing more stricter norms than country specific official norms and in general are aiming at `zero-tolerance' rather than the fixed MRLs. The supermarkets are the outlets which display imported products. This attitude of the European supermarkets is increasing posing problems for exporters in the Third World.

The SPS norms are gradually becoming a weapon to stop imports. The large variances in norms in the developed countries raises doubts as to whether these norms are fixed purely on scientific basis or for any political reasons. May be the industry in the developed countries wants their governments to find out means of checking the inflow of imports through some suggested non-tariff barriers. The Codex Alimentarius Commission as a global standard setting body is helpless in this case. There is no system of scrutinising the `stringent' norms formulated in the developed countries to find out whether they are scientifically viable or politically motivated and whether it is possible for implementation in the Third World. In global trade the norms set by the importing countries matters most in disputes, though Codex standards are considered as base.

The developing countries need to actively participate in the global standard setting bodies. Sadly, the case with developing countries is that often bureaucrats are sent to attend the meetings of Codex and WHO-FAO bodies. Developing countries should attempt to send requisite contingents of able scientists and food technologists. There is no dearth of manpower expertise in some developing countries. The governments in the developing countries should select experts and food technologists from recognised labs in both private and public sectors, universities. Both the FAO and WHO should update their roaster registers of experts from developing countries. FAO, WHO and the Codex should contact the national codex commissions in different countries. The developing countries should also update the register of experts maintained with the national codex commissions.

The Codex, WHO and FAO should also consider representatives from developing countries' consumer organisations, NGOs, writers on food safety issues and industry in the scientific bodies intended for risk assessment, risk management and risk communication. The global standard setting bodies are at many times handicapped due to non-availability of requisite scientific data relating to specific items and regionwise situations.