Report from the Commission to the European Parliament and the Council on existing legal provisions, systems and practices in the Member States and at Community level relating to liability in the food and feed sectors and on feasible systems for financial guarantees in the feed sector at Community level in accordance with Article 8 of Regulation (EC) No 183/2005 of the European Parliament and of the Council of 12 January 2005 laying down requirements for feed hygiene {SEC(2007)1066}
Date: 2007-08-14
Institutions: European Commission
Subjects: animal nutrition, food industry, food inspection, foodstuffs legislation, guarantee, insurance, producer's liability, product safety

COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 14.8.2007 
COM(2007) 469 final 

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 

on existing legal provisions, systems and practices in the Member States and at 
Community level relating to liability in the food and feed sectors and on feasible systems 
for financial guarantees in the feed sector at Community level in accordance with Article 
8 of Regulation (EC) No 183/2005 of the European Parliament and of the Council of 
12 January 2005 laying down requirements for feed hygiene 

{SEC(2007)1066} 

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EXECUTIVE SUMMARY 

When  large-scale  incidents  occur,  society  has  to  bear  the  costs  of  withdrawal,  transport, 
storage and destruction of feed, food and animals, as well as the costs of analysis and other 
administrative outlay. Who should pay? 

The  principle  that  feed  business  operators  are  liable  for  any  infringements  of  the  relevant 
legislation on feed safety and for the direct consequences of the withdrawal from the market, 
treatment and/or destruction of any feed, animals and food produced therefrom is laid down in 
Article  8  of  Regulation  (EC)  No  183/20051  on  feed  hygiene.  However,  with  regard  to 
financial guarantees in the feed sector, the legislator chose not to make financial provision in 
the  Regulation.  The  Commission  is  however  required  to  submit  a  report  to  the  European 
Parliament and to the Council and, where appropriate, a legislative proposal. The purpose of 
this report is to set the scene for an effective system of financial guarantees for feed business 
operators. A full version of this report in English is found in the annex. 

Firstly,  the  report  examines  the  existing  legal  provisions,  systems  and  practices  relating  to 
liability and to financial guarantees in the feed and other sectors at Community and national 
level.  Secondly,  it  proposes  a  feasible  and  practicable  system  of  financial  guarantees  at 
Community level. The report analyses various options for financial guarantees and therefore 
the analysis may be wider than the options envisaged by Article 8. 

Financial  guarantees  in  the  feed  sector  are  a  technically  feasible  option,  if  coverage  and  a 
triggering mechanism are clearly established. The financial impact for feed business operators 
is variable but would depend mainly on the extent of the coverage. However, the introduction 
of compulsory financial guarantees is not a popular measure amongst feed business operators. 
Moreover,  the  insurance  sector  has  not  developed  products  that  would  satisfy  a  demand  for 
financial guarantees if this were to become immediately mandatory. 

Therefore, due to the complexity of the issue and the difficulty to put it immediately in place, 
the Commission proposes to launch a broad public debate about the different options within 
two  years  of  the  publication  of  this  report,  followed  by  further  analysis  of  the  costs  of 
financial  guarantees  and  the  assessment  of  the  possible  outcome  of  such  measure.  In  the 
meantime,  the  Member  States  are  not  expected to  require  feed  business  operators  to  submit 
proof  that  they  are  covered  by  financial  guarantees.  On  the  basis  of  experience  gained  over 
the coming years, it might be necessary to accommodate unforeseen issues and/or emerging 
policy.  The  Commission  would  then  consider  the  need  for  legislative  proposals  to  address 
those  issues  via  the  co-decision  procedure  involving  the  Council  and  the  European 
Parliament. 

1 

Regulation (EC) No 183/2005 of the European Parliament and of the Council of 12 January 2005 laying 
down requirements for feed hygiene. OJ L 35, 8.2.2005, p. 1. 

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LEGAL BASIS 

Article 8 of Regulation (EC) No 183/2005 of the European Parliament and of the Council of 
12  January  2005  laying  down  requirements  for  feed  hygiene  requires  the  Commission  to 
“submit to the European Parliament and to the Council […] a report on financial guarantees in 
the feed sector” in order “to prepare for an effective system of financial guarantees for feed 
business  operators.”  […]  “In  addition  to  examining  the  existing  national  legal  provisions, 
systems and practices relating to liability in the feed sector and related sectors, the report shall 
be  accompanied,  where  appropriate,  by  legislative  proposals  for  such  a  feasible  and 
practicable guarantee system at Community level. Those guarantees should provide cover for 
the  total  costs  for  which  operators  could  be  held  liable  as  a  direct  consequence  of  the 
withdrawal  from  the  market,  treatment  and/or  destruction  of  any  feed,  animals  and  food 
produced therefrom.” 

PRELIMINARY STUDIES AND DISCUSSIONS 

In order to help the Commission with this report, an external consultant was commissioned to 
carry out a study on “Financial Guarantees in the Feed Sector”, focusing on: 

– 

– 

– 

a  cost  analysis  of  previous  incidents  when  feed,  food-producing  animals  and  food 
produced therefrom had to be withdrawn from the market; 

a  review  of  the  existing  legal  provisions,  systems  and  practices  at  Community  and 
national  level  (in  EU-25  and  one  non-EU  EEA  member2)  relating  to  liability  and 
financial guarantees, mainly in the food and feed sector; 

a  cost  and  feasibility  assessment  of  the  impact  of  different  options  for  financial 
guarantees in the feed sector. 

For  this  study,  an  extensive  stakeholder  consultation  took  place  in  2005  in  the  form  of 
meetings  and  written  questionnaires.  The  meetings  were  held  with  European  organisations 
representative of feed business operators and of the insurance sector. The questionnaires were 
sent  to  European  and  national  organisations  of  feed  business  operators  and  to  national 
competent authorities. 

In  addition  to  this  study,  the  Commission  received  comments  from  several  European  and 
national  organisations  of  feed  business  operators  and  other  interested  parties,  representing 
primary feed and food producers, livestock farmers, feed cooperatives, manufacturers of feed 
additives,  premixtures  and  compound  feedingstuffs,  cereal  millers,  storage  operators, 
transport undertakings and the insurance sector. 

2 

Answers  were  received  from  24  competent  authorities,  comprising  all  EU-25  Member  States  except 
Greece and Malta, plus Norway, the only one of the three non-EU EEA members participating in the 
survey. 

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LIABILITY IN COMMUNITY LEGISLATION 

The Treaties do not provide an explicit legal basis empowering the Community to regulate 
liability.  In  the  absence  of  such  provisions,  Community  rules  related  to  liability,  when 
available,  are  based  on  sector-specific  competences,  such  as  public  health,  environment, 
agriculture and transport. 

FORMS AND PROVIDERS OF FINANCIAL GUARANTEES 

The potential forms of financial guarantees that have been analysed are: insurance, either as a 
voluntary insurance scheme or a compulsory one, bank guarantees and bank savings, sectoral 
pooling  systems  such  as  those  that  can  be  created  into  the  form  of  a  mutual  insurance 
company,  and  special  funds  with  public  participation  or  backup.  For  each  of  these,  it  is 
important to understand the conditions under which the market would be able and willing to 
provide such a product.  

Compulsory solutions mean that there is a need to make sure that all feed business operators 
obliged to comply with this requirement actually do so. Therefore, enforcement would be the 
responsibility  of  the  competent  authorities,  in  the  framework  of  the  registration  process  or 
other official control activities. 

A  problem  such  a  compulsory  insurance  scheme  would  need  to  resolve  would  be  how  to 
ensure financial guarantees also for those operators who would be perceived too risky to be 
underwritten by any insurance company or other guarantee provider. 

Insurance solutions 

Could the recalls be insured? 

An  insurance  can  be  a  solution  to  cover  a  risk  when  the  principles  of  predictability, 
independence,  stability and rarity  are fulfilled. Predictability means that the probability of a 
recall over time and the whole population to be insured can be calculated. This would seem to 
be  the  case:  statistics  exist  at  least  of  the  major  recalls  and  their  reasons.  However 
consequential  impacts  such  as  further  recalls  due  to  a  recalled  ingredient  would  have  to  be 
excluded  due  to  their  large  unpredictability,  and  would  rather  then  fall  to  the  scope  of  the 
insurances  taken  by  the  operators  down  the  chain.  Independence  means  that  the  claimant 
should not be able to cause a recall himself. This is more difficult: such recalls that are clearly 
due to the claimant's negligence or other reasons due to him would have to be excluded from 
the  insurance.  Stability  means  that  the  amount  of  recalls  and  their  average  values  should 
remain rather stable or their changes in time can be estimated. Rarity means that at least very 
large recalls would be exceptional and rare occasions. The recalls would seem to fulfil both 
criteria of stability and rarity. 

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Compulsory or voluntary insurance? 

Insurance can be compulsory, which means that all participants have to take an insurance to 
cover the risks in question. A compulsory insurance is normally substantially cheaper than a 
voluntary one because it spreads the risk over all actors.  

A voluntary insurance solution often includes the difficult problem of anti-selection: the ones 
that expect that they will need the insurance – that is, they expect to have to recall products – 
will take the insurances. This will mean that the risk for those insured in general is higher and 
hence  higher  premiums.  Moreover  regarding  the  financial  guarantees,  the  question  is  what 
would  a  voluntary  solution  mean  for  those  who  would  choose  not  to  take  the  voluntary 
insurance – what would be accepted as their financial guarantee? 

Deductible, reinsurance, risk management 

Insurance  normally  contains  a  deductible,  either  as  a  percentage  or  an  absolute  amount,  or 
their combination. This means that the claimant will be responsible for any expenses up to the 
limit  indicated  by  the  deductible  and  the  insurance  company  will  cover  the  rest  of  the 
expenses.  Normally  the  insurance  company's  part  has  no  upper  limit.  For  very  big  claims, 
however, the insurances are usually reinsured by reinsurance companies, which take over the 
risk  of  very  big  claims  for  the  first  insurer.  Insurance  coverage  must  be  well  and  clearly 
defined,  and  any  risks  where  those  insured  can  impact  the  claim  should  be  excluded, 
following  the  principle  of  independence.  Often  risk  can  be  mitigated  by  preventive  actions 
and good risk management by those insured. This is often reflected in the premium level and 
can  be  an  encouraging  factor  to  reduce  the  risk  of  recalls.  Finally,  sometimes  the  insurance 
products  include  a  right  to  collect  additional  premiums  to  cover  exceptional  losses.  This 
would mean that after a major claim year the premiums would normally be adjusted to meet 
the new risk level but also an additional payment would be collected to ensure compensation 
to those claimants with major losses. 

Insurance premium 

In general the insurance premium is calculated taking into account the factors that impact the 
risk:  some  areas  of  business  may  have  a  higher  probability  for  recall,  obviously  larger 
business  may  have  larger  risks  and  losses,  and  for  example  location  may  have  an  impact. 
Claimless years might mean a lower premium; risk prevention may also reduce the premium 
level. Naturally the level to which the deductible is set may have a significant impact on the 
expenses to the insurance company and hence premium. The deductible should normally be 
set  at  a  level  where  the  expenses  due  to  recalls  smaller  than  that  level  can  be  in  normal 
circumstances covered by the operator himself. 

How much would an insurance cost? 

The feed business operators have a history of handling any smaller recalls themselves, and it 
would seem that there is no specific reason to change this procedure. However, for the large 
claims that have significant spread and serious impacts their funds would be insufficient. This 
would seem to indicate that an insurance solution with a rather large deductible could be an 
appropriate solution. 

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At  present  the  cost  of  an  insurance  system  is  perceived  by  feed  business  operators  as  a 
competitive disadvantage as there are fears of very large expenses. However, if the insurance 
solution  for  the  financial  guarantee  would  be  limited  to  very  high  risks,  the  insurance 
premiums could very probably be quite reasonable. For example if the level of a deductible 
was  set  to  the  level  of  an  operator's  annual  income  or  turnover  –  it  would  cover  only  very 
major recall losses – the insurance premium would not be significant. At present we are aware 
of around EUR 3 billion of expenses due to few major recalls, over some 5 million operators 
during the last 5 to 10 years, in a livestock market with a turnover of about EUR 129 billion in 
2005  (EU-25).  A  rough  calculation  –  it  should  be  noted  this  should  be  seen  only  as  a  very 
rough  and  inaccurate  indication  of  the  level  of  expenses  involved  –  would  mean  that  the 
actual  expenses  of  major  recalls  divided  equally  per  operator  per  year  result  then  only  in 
EUR 60 to 120. 

What could be a feasible insurance solution? 

As the operators have been able to tackle the smaller risks by themselves up till now, it would 
seem  feasible  if  they  continue  to  do  so  also  in  the  future.  However,  they  would  need  the 
safeguard  of  financial  guarantees  against  the  expenses  and  consequences  of  larger,  major 
recalls.  A  feasible  solution  to  ensure  financial  guarantees,  should  it  be  based  on  insurance, 
could  thus  be  an  obligatory  insurance,  covering  all  operators,  with  a  significantly  high 
deductible. This solution, however, would need to be accepted by the insurance industry and 
the  reinsurers  –  there  should  be  insurers  offering  the  products  in  all  relevant  countries.  In 
some  EU  countries  such  solutions  already  exist  as  product  liability  insurances,  but  none  of 
them are compulsory. The feed recall insurance could be part of or an extension of scope of 
such insurance. 

Private solutions 

If  no  obligatory  solutions  would  be  imposed  on  the  operators,  they  could  for  example  take 
voluntary insurance cover as described above. They could also protect themselves simply with 
bank savings.  

Bank savings would however mean economically a significantly larger amount of money set 
aside  into  bank  accounts  or  other  forms  of  savings  in  case  of  these  recalls  than  the  money 
needed in other alternatives, and would hardly be an efficient solution from the point of view 
of the society. Moreover no normal savings could cover possible, if not very probable, major 
recalls. Should savings be sufficient for a financial guarantee, a solution would need still to be 
found for the cases when the recall expenses exceed the savings amount.  

As a combination of an insurance to cover for the rare major recalls and savings to cover the 
"normal" recalls, this could probably nevertheless be a feasible solution. 

A voluntary  insurance as a  stand-alone product  as a solution for  financial guarantees would 
have some obvious problems: firstly, not everyone would take the insurance. What would be 
the financial guarantees of the rest of the operators? Secondly, a voluntary insurance would 
probably not be very popular as its insurance premium could prove to be quite high. This is 
due to the fact that those covering themselves with insurance often are those who have a high 
probability  of  needing  the  insurance  cover  soon,  that  is,  they  have  a  high  probability  for  a 
recall. Also the insurance industry would want a wide enough market interest to underwrite 
such insurance. 

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Another  feasible  combination  could  be  that  the  obligatory  insurance  with  a  high  deductible 
would be complemented by a voluntary cover of lower risks. In this case the operator would 
buy an additional insurance cover with a lower deductible. 

Bank guarantees 

Providing  a  bank  guarantee  is  another  possibility.  This  would  mean  in  practice  that  the 
operator would purchase a guarantee from the bank to an amount agreed. This amount would 
be  released  in  those  cases  predetermined  between  the  operator  and  the  bank.  Usually  such 
guarantees tend to be more expensive than corresponding insurance products and availability 
could prove a problem as banks might not be willing to offer such guarantees. 

Pooling 

The question is whether the coming together of all feed business operators, or those which are 
at the same stage in a particular sector, into a pool for the purpose of covering the feed recall 
costs  of  members  is  a  suitable  financial  guarantee  within  the  meaning  of  the  proposed 
Regulation. If widespread backing could be obtained for such a project and if its effectiveness 
could be ensured, then it might be implemented in different ways either as an alternative or 
complementary to mandatory insurance in the market. In practice this would probably mean 
the establishment of a special mutual insurance company for the purpose of covering this risk 
in a particular sector. An association of operators could provide the necessary guarantee funds 
(initial capital) and the management expertise or take on supervisory responsibilities for this 
pool or mutual company. Such a pool would probably need to be European wide to contain a 
basis  large  enough  to  ensure  solvency  for  the  pool.  Premiums  to  be  collected  from  the 
members  of  such  a  pool  would  be  defined  more  or  less  similarly  to  the  definition  of  any 
insurance premium. Further, contrary to insurances with annual premiums, the money would 
not  be  lost  in  case  of  "no  recall"  but  would  be  available  in  the  future.  So  the  fee  could 
eventually  be  reduced.  A  pool  could  also  contain  obligations  to  its  members  for  further 
additional payments in case of very bad claim years. 

Special funds 

The  situation  is  quite  different  when  public  redistribution  systems  are considered,  including 
the participation of the responsible competent authorities, as has been the case, for example, 
for the coverage of losses resulting from livestock epidemics in some EU countries. Public-
private  partnerships  can  take  different  forms,  ranging  from  state  institutions  such  as  social 
insurance  agencies  to  privately  organised  funds  with  mandatory  membership  and  state 
supervision.  All  problems  pertaining  to  insurability  are  easily  eliminated  when  the  state 
ensures  payments  from  the  fund  in  the  event  of  loss.  This  can  be  managed,  for  example, 
through state participation, through subventions in the form of partial absorption of the loss, 
through pre-financing of large losses to be levied later, or through other forms of guarantees. 

A  problem  related  to  special  funds  is  that  they  constitute  a  significant  state  intervention, 
which contradicts free market principles and needs to have a clear justification, as is the case 
with  natural  disasters  or  livestock  epidemics.  Furthermore,  the  state  evens  out  deficits  by 
assuming uninsurable risks and offering reinsurance cover for peak excess losses, ending up 
by deploying public funds to remedy damage caused by private operators. 

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MID-TERM NON-LEGISLATIVE ACTIONS 

Due to the complexity of the issue and because a system of financial guarantees is difficult 
to put immediately in place, this report will be followed by a broad public debate. Therefore 
the Commission proposes: 

– 

– 

– 

– 

to  open  the  debate  about  the  different  possibilities  of  financial  guarantees  with  the 
operators, the insurance sector, Member States and other stakeholders, as well as to 
encourage  providers  of  financial  guarantees  to  develop  products  that  could 
respond to a future increase in demand for financial guarantees, taking into account 
the coverage and trigger mechanism suggested in this report; 

to open discussions with the Member States in order to promote: 

principles  of  best  practice  on  risk  management  in  respect  of  feed  and  food 
withdrawals,  especially  in  the  event  of  large-scale  incidents,  with  a  view  to 
developing guidelines on this subject; and 

clarification on the issue of liability related to feed and food withdrawals. 

Such intermediate steps should be concluded within a period of 2 years after the publication 
of  this  report.  Until  then,  the  Member  States  are  not  expected  to  require  feed  business 
operators  to  submit  proof  that  they  are  covered  by  financial  guarantees.  Moreover,  the 
Commission will further analyse the costs of financial guarantees, followed by the assessment 
of the possible outcome of such measures. 

CONCLUSIONS 

Food  and  feed  business  operators  at  all  stages  of  production,  processing  and  distribution 
within  the  business  under  their  control  must  ensure  that  food  or  feed  products  satisfy  the 
requirements  of  food  law  which  are  relevant  to  their  activities  and  must  verify  that  such 
requirements  are  met.  Although  liability  rules  concerning  food  law  in  general  must  be 
adopted  at  national  level,  feed  business  operators  are  liable  under  Community 
legislation  for  any  infringements  of  the  relevant  legislation  on  feed  safety.  However,  so 
far they are not required to submit proof of a financial guarantee to ensure that they can pay 
the costs for which they are liable. 

Except for expenses arising from additional official controls, Community legislation does 
not specifically govern liability in the food sector, instead requiring the Member States to lay 
down  measures  themselves.  With  regard  to  the  feed  sector,  there  are  Community-specific 
grounds  for  liability  in  the  field  of  feed  hygiene,  but  the  practicability  of  this  depends  on 
national  legislation,  which  determines  the  legal  relationships  and  obligations  that  constitute 
liability as well as the facts, circumstances and conditions under which such relationships and 
obligations arise. The national systems surveyed are characterised by certain differences as 
regards  liability.  Moreover,  withdrawals  ordered  by  the  competent  authorities  generally 
depend on the legislation of the Member State, risk assessment and administrative discretion. 
Consequently this means that the financial risk of a feed business operator related to liability 
claims for possible feed withdrawals and disposal may differ by country. 

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Financial guarantees in the feed sector – such as in the form of insurance, bank guarantees, 
savings,  pooling  and  funds  –  are  in  principle  a  technically  feasible  option.  However,  the 
degree to which it would in practice be possible for feed business operators to obtain cover 
depends on the design of any system of financial guarantees. There is a risk that a system of 
financial  guarantees,  not  appropriately  designed  and  not  taking  into  account  criteria  for 
insurability,  could  lead  to  a  situation  where  cover  could  be  almost  unobtainable  on  the 
private  market  or  only  for  prohibitively  high  premiums.  Limits  of  coverage  and  trigger  of 
financial guarantees should be clearly established.  

Although product liability insurance exists in some Member States, little practical experience 
exists  especially  with  recall  insurance  in  the  feed  sector.  At  present  there  is  no  accurate 
knowledge on where the premium level would be set on such insurance, for example when it 
would cover events of large-scale feed withdrawal and disposal – that is, the deductible would 
be set to a considerably high level. Some schemes are nevertheless either already operational 
or under preparation in the compound feed sector. Most insurers are at present very reluctant 
to  enter  this  market,  although  some  seem  to  be  willing  to  take  this  risk  under  very  strict 
underwriting conditions. The main question therefore is not whether such insurance cover for 
feed withdrawals and disposal is available (it is in some countries), but how, when and under 
what conditions would major European insurers be willing to enter this market. 

The  insurance  sector  is  opposed  to  a  compulsory  system  of  financial  guarantees  in  the 
feed  sector  –  in  general,  introduction  of  any  compulsory  insurance  would  be  strongly 
opposed  by  the  insurance  sector  due  to  obvious  problems  related  to  such  solutions.  The 
national insurance associations surveyed the approach some years ago and cautioned against 
any developments in product recall insurance for the feed sector. Moreover, they doubt that 
such  a  system  would  enable  feed  business  operators  to  fulfil  the  requirements  as  regards 
financial  guarantees  or  meet  the  policy  objectives  of  transferring  withdrawal  and  disposal 
costs from the public to the private sector. Nevertheless, product liability insurances already 
exist in some Member States and their structure and scope is not far from the coverage sought 
here. 

A  large  number  of  representatives  of  feed  business  operators  are  also  opposed  to  a 
system of financial guarantees and, if such a system were to be set up, they would prefer 
it  to  be  voluntary.  One  advantage  of  a  voluntary  system  is  the  possibility  to  conclude 
contracts  according  to  the  specific  needs  and  conditions  of  individual  operators,  without 
pushing  out  of  business  operators  that  are  not  willing  or  able  to  participate.  The  main 
disadvantages  of  this  option  are  that  the  premium  would  be  likely  to  be  high,  and  if  not 
mandatory,  there  might  be  a  low  percentage  of  covered  operators,  even  more  so  due  to  the 
high level of the premium. If that were the case, liable operators affected by an incident but 
not  covered  by  financial  guarantees  would  have  to  find  the  means  to  afford  the  withdrawal 
and  disposal  costs.  If  they  could  not  afford  them  or  did  not  pay,  this  would  ultimately 
compromise the objective of avoiding the spending of public funds for feed safety incidents. 
Therefore  it  is  unlikely  that  such  a  system  would  reduce  the  financial  burden  on  public 
authorities  in  large-scale  crises,  and  the  pressure  on  governments  to  support  affected 
businesses would remain. 

Some  competent  authorities  support,  and  others  could  envisage,  a  system  of  financial 
guarantees, but are divided over whether such a system should be compulsory or not. 

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The  revised  Lisbon  Strategy  identified  simplification  as  one  priority  action  for  the  EU.  It 
aims at achieving growth and jobs in Europe and therefore focuses on those elements of the 
acquis  that  concern  the  competitiveness  of  enterprises  in  the  EU.  Its  overall  objective  is  to 
contribute  to  a  European  regulatory  framework  that  fulfils  the  highest  standards  of 
lawmaking,  respecting  the  principles  of  subsidiarity  and  proportionality.  In  this  respect 
simplification is intended to make legislation at both Community and national level less 
burdensome, easier to apply and thereby more effective in achieving the goals. 

The  measures  laid  down  in  the  Regulation  on  feed  hygiene,  such  as  provisions  for  the 
sourcing of feed, traceability, hygiene, HACCP principles and registration, together with other 
food  safety  legislation,  are  important  steps  taken  with  the  aim  of  reducing  the  risks  and 
preventing the occurrence of accidents. The full implementation of all those measures by 
feed  business  operators  should  help  to  reduce  the  likelihood  of  major  feed  and  food 
incidents  similar  to  those  witnessed  in  recent  years.  The  new  official  controls  framework, 
which  is  currently  being  implemented  by  the  competent  authorities  for  verifying  business 
operators'  compliance  with  the  law,  could  become  another  efficient  tool  for  strengthening 
feed and food safety.  

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