REPORT FROM THE COMMISSION on the overall operation of official controls carried out in Member States (2019-2020) to ensure the application of food and feed law, rules on animal health and welfare, plant health and plant protection products
Date: 2022-03-28
Institutions: Directorate-General for Health and Food Safety, European Commission
Subjects: animal feedingstuffs, animal welfare, audit, designation of origin, food inspection, food safety, genetically modified organism, labelling, organic product, plant health control, veterinary inspection

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 28.3.2022  COM(2022) 129 final  REPORT FROM THE COMMISSION on the overall operation of official controls carried out in Member States (2019-2020) to ensure the application of food and feed law, rules on animal health and welfare, plant health and plant protection products {SWD(2022) 73 final}  
 
 
Disclaimer 

The European Commission has drafted and published this report in accordance with Article 114 of 
Regulation (EU) 2017/625. This report aims to improve public availability of information on official 
controls carried out by EU countries, and Commission controls on these, in the areas of food and feed 
safety, animal and plant health, animal welfare, organic farming and quality schemes for agricultural 
products and foodstuffs. Only the Court of Justice of the European Union is competent to interpret EU 
law. Our goal is to keep this information up-to-date and accurate. If errors are brought to our attention, 
we will try to correct them.  

The material used for this report: 

● 

● 

● 

is information of a general nature and is not intended to address the specific circumstances of 
any particular individual or entity; 

is not necessarily comprehensive, complete, accurate or up-to-date; 

is partly provided by national authorities in the EU countries, over which the Commission has no 
control and for which the Commission can take no responsibility. 

Some data or information in this report may have been created or structured in files or formats that 
are not error-free. 

i 

 
 
 
 
Contents 

Executive summary 

Introduction 

Legal framework 

Official controls carried out by EU countries 

General overview 

EU countries’ annual reports 

Organisation and performance of official control systems 

Measures taken to ensure the effective operation of the MANCP 

Actions to ensure business compliance 

Enforcement by national authorities 

Actions to ensure the effective operation of official control services 

Commission control activities in EU countries 

Audits 

Recommendations 

Overview reports 

Highlights from the Commission controls carried out (2019-2020) 

Other Commission control activities 

Entry of animals and goods into the EU 

Residues of veterinary medicinal products and environmental contaminants 
in animals and products of animal origin 

Systematic follow-up of audit recommendations 

General follow-up audits 

Country profiles 

1 

3 

5 

9 

10 

15 

16 

18 

19 

20 

22 

23 

24 

28 

29 

30 

32 

33 

34 

35 

36 

37 

ii 

 
 
Enforcement 

Support for EU countries 

Networks 

Better training for safer food 

Conclusions 

38 

40 

41 

43 

45 

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Executive summary 

This report covers the overall operation of EU countries’ official controls and the 
Commission control activities carried out in 2019 and 2020 to ensure a high level of 
health protection and trust in the food chain, from farm to fork. These controls and 
audits are important to verify that businesses are complying with the legal 
requirements and so that European consumers can be confident that the food they 
consume is safe. They are also key to enabling the smooth operation of safe trade in 
food, animals and plants, both within the EU and with non-EU countries. 

National authorities are responsible for carrying out official controls based on risk. If 
businesses along the food chain do not comply with the relevant legislation, the 
authorities are required to enforce the requirements, ensuring that businesses meet 
these.  

The Commission services control EU countries’ implementation of official controls and 
enforcement activities. The reports from these controls, published on the 
Commission's website, provide a clear picture of EU countries’ performance and are a 
significant part of the review process that ensures EU legislation is ‘fit for purpose’. 

The Commission’s controls show that, overall, EU countries have the necessary 
systems in place to monitor and ensure that businesses are implementing EU 
requirements and to take action where there are non-compliance issues. In some 
countries, the controls identified shortcomings in official control systems, indicating 
that there was room for improvement.   

The Commission systematically follows up on its audit recommendations to EU 
countries and, where necessary, makes use of other enforcement tools. In addition, it 
supports EU countries by providing technical assistance and training through the 
Better Training for Safer Food initiative and technical meetings of EU countries’ 
experts. 

The EU countries reported the results of their 2020 controls in a harmonised 
electronic format for the first time. The Commission and national authorities 
developed a guidance document to support this. However, not all countries submitted 
all their data in the format required, and one did not report at all. The Commission 
will continue to work with national authorities to improve the completeness of data 
for future annual reports. 

During 2020, the COVID-19 pandemic posed challenges for national authorities and 
the Commission in completing their controls and audits. Carrying out at least some of 
these controls and audits remotely served to maintain the safe flow of animals, 

1 

 
 
plants and goods and prevented shortages of supply under the unusual COVID-19 

conditions.    

2 

 
 
 
Introduction 

The EU aims to ensure a high level of health protection and trust in the areas of food 
and feed safety, animal and plant health, animal welfare, organic farming and 
geographical origin schemes (protected designation of origin, protected geographical 
indication, traditional specialties guaranteed, PDO/PGI/TSG). The people living in the 
EU rightly expect high standards in these areas. 

There is a comprehensive EU legal framework in place to ensure consistent controls 
throughout the food and feed chain, from farm to fork, and appropriate monitoring, 
while ensuring an effective single market and trade with non-EU countries. 

One of the pillars of the EU’s integrated food safety policy from farm to fork is that 
each EU country must have an effective official control1 system, based on the Official 
Controls Regulation2, to verify and, where necessary, enforce businesses’ compliance 
with EU standards throughout the food and feed chain. EU countries must draw up 
multi-annual control plans (MANCPs) that cover all areas governed by EU agri-food 
legislation. 

The Commission plays an important role in the overall control framework at EU level3 
and it carries out controls, including audits, in the EU countries to verify that their 
national authorities are meeting their control obligations.  

EU countries must submit an annual report to the Commission4 on the 
implementation of their official controls in line with their MANCP. 

For its part, the Commission produces a report5 on the operation of official controls in 
EU countries, taking account of: 

● 

the annual reports submitted by the national authorities on their control 
activities, and; 

● 

the outcome of Commission controls carried out in the EU countries. 

1 

‘official control’ means any activity carried out by the competent authority in an EU country to 
verify compliance with food and feed law, rules on animal health and welfare, plant health and 
plant protection products and that animals and goods meet the requirements. 

2  Regulation (EU) 2017/625. 

3  Article 116 of Regulation (EU) 2017/625. 

4  Article 113(1) of Regulation (EU) 2017/625. 

5  Article 114 of Regulation (EU) 2017/625. 

3 

 
 
                                                      
This report covers the years 20196 and 2020. It consists of a review of:  

  EU countries’ annual reports covering the years 2019 and 2020;  
  Commission control activities in EU countries;  
  Commission follow-up and enforcement actions and support provided to 

national authorities.  

It provides a compilation of comparable data into EU-wide statistics for the year 
2020. These data will, over time, enable trends in controls and non-compliance issues 
to be identified. 

The report is accompanied by a staff working document which provides more detail 
on the controls and audits carried out by the national authorities and by the 
Commission in the areas of the food chain that fall under the Official Controls 
Regulation. 

6  The requirement for EU countries to submit their annual reports using the new standard model 
form applies from the year 2020. The reporting requirements for 2019 were under the previous 
Regulation. As 2019 was a transitional year between the two versions, this report combines both 
years. 

4 

 
 
 
 
 
                                                      
Legal framework 

Under the ‘General Food Law’7, businesses along the food chain have primary 
responsibility for ensuring that food is safe. Specific EU regulations deal with the 
requirements for organic production and the labelling of organic products8 and for 
quality schemes for agricultural products and foodstuffs (PDO/PGI/TSG)9. 

EU countries are obliged to verify that businesses respect the applicable EU 
legislation, and enforce this where necessary. Their MANCPs describe the systems of 
official controls for this purpose. 

The Official Controls Regulation sets out the requirements for these control systems, 
for the MANCP10 and for carrying out official controls. The most relevant requirements 
relating to the official control systems and the MANCP are as follows: 

● 

the scope includes: 

— 

food and food safety,  

— 

the deliberate release into the environment of genetically modified organisms 
(GMOs) for the purpose of food and feed production,  

— 

feed and feed safety,  

—  animal health,  

—  animal by-products,  

—  animal welfare,  

—  plant health,  

—  plant protection products,  

—  organic production and labelling of organic products, 

— 

the use and labelling of protected designations of origin, protected geographical 
indications and traditional specialities, and 

7  Regulation (EC) No 178/2002. 

8  Council Regulation (EC) No 834/2007 on organic production and labelling of organic products. 

9  Regulation (EU) No 1151/2012 on quality schemes for agricultural products and foodstuffs. 

10  Articles 109, 110 and 111 of Regulation (EU) 2017/625. 

5 

 
 
                                                      
— 

● 

intentional violations of the rules perpetrated through fraudulent or deceptive 
practices; 

national authorities must describe their strategic objectives and the risk 
categorisation of the official controls in their MANCP; 

● 

the MANCP needs to be made public, with certain limited exceptions. 

The Official Controls Regulation includes provisions for continuous improvement of 
official controls11. Figure 1 shows how the results of official controls are important in 
supporting EU countries in assessing the effectiveness of their control system and 
making improvements as necessary. In addition, changes to legislation, emerging 
issues and market information can result in changes to the control plan. 

Figure 1 – official control systems - continuous improvement 
cycle 

• Improve
• Legal changes
• Emerging issues
• Market information

• Audit
• Analysis of results
• Verification
• Assessment of 
effectiveness

Act

Plan

Check

Do

• Objectives
• Risk based 
prioritisation
• MANCP
• Resources

• Official controls
• Samples
• Follow-up of non-
compliance
• Sanctions
• Reports

The Official Controls Regulation requires the Commission12 to carry out controls in the 
EU countries, who must rectify any issues identified in these13. 

11 Articles 5(1)(a), 6(1), 12(2), 12(3), 109, 110 and 111 of Regulation (EU) 2017/625. 

12  Article 116 of Regulation (EU) 2017/625. 

13  Article 119 of Regulation (EU) 2017/625.  

6 

 
 
 
 
                                                      
The EU countries must submit their annual reports in electronic format to further 
facilitate the compilation of data. The Commission has created a standard model 
form14 for this purpose, working with the national authorities. The Commission 
developed a dedicated digital platform for submitting annual reports in this new 
format. In addition, the Commission-chaired network of EU countries’ representatives 
on the functioning of the MANCP developed a guidance note15 on how to fill in the 
form, to assist national authorities in meeting the new reporting requirements.  

The model form covers information on amendments to the MANCP, the results of 
official controls, the non-compliance issues detected, and measures taken to ensure 
the effective implementation of the MANCPs.  

The aim of the standardised format is to: 

● 

● 

● 

ensure the uniform presentation of EU countries' annual reports; 

integrate other existing reporting requirements; and 

facilitate the collection and transmission of comparable data, the compilation of 
these into EU-wide statistics and the preparation of Commission reports on the 
operation of official controls across the EU. 

National authorities used the electronic, harmonised form for the first time to report 
on the official controls carried out in 2020.  

EU countries must carry out their official controls with a high level of transparency. At 
least once a year, they must publish relevant information on the organisation and 
delivery of these controls. They may decide to do this by publishing the annual report 
submitted to the Commission.  

During the COVID-19 pandemic, there were movement restrictions in practically all EU 
countries. These impacted negatively on countries' capacity to deploy staff for official 
controls, particularly those that required a physical presence on-the-spot, laboratory 
analyses for control purposes, or the signing and issuing of official certificates on 
paper. In March 2020, the Commission implemented temporary measures16 in order 
to maintain the smooth functioning of the internal EU market and to ensure the free 
circulation of goods. These facilitated: 

14 Regulation (EU) 2019/723 on the standard model form to be used for the annual reports submitted 

by Member States 

15 Commission Notice on a guidance document on how to fill in the standard model form.  

16 Regulation (EU) 2020/466 on temporary measures during certain serious disruptions of EU countries’ 

control systems due to coronavirus disease (COVID-19). 

7 

 
 
                                                      
● 

● 

● 

the authorisation of individuals to carry out official controls; 

the use of electronic data and acceptance of copies of certificates; 

the use of videoconferencing and other remote communication tools for official 
controls. 

8 

 
 
Part 1 
Official controls 
carried out by EU 
countries 

9 

 
 
 
 
 
 
 
1 
General overview 

The production and distribution of food from farm to fork consists of various chains, 
covering a broad range of areas and activities.  

Table 1 provides an overview of the total number of entities in the food chain, official 
controls carried out, non-compliance issues identified, administrative sanctions and 
judicial actions taken throughout the food chain, in 2020, at EU level17. 

Table 1 – official controls – 2020 – general figures 

Total entities in 
the food chain 

Official controls 
carried out 

Non-compliance 
issues 
identified 

Administrative 
sanctions 
applied 

Judicial actions 
taken 

16 834 486 

4 125 695 

654 955 

388 268 

12 699 

Figure 2 provides an overview of the official controls carried out by EU countries in 
2020, from farm to fork18. It shows the number of operators, official controls carried 
out, non-compliance issues identified and administrative sanctions applied, split by 
the different activities in the food chain19. 

Table 2 shows the top five sectors of the food chain, in absolute figures, for the 
number of entities, official controls carried out, non-compliance issues identified and 
administrative sanctions applied.  

17 The figures are the sum of 26 EU countries, as Malta did not send its annual report by the deadline. 

18  This figure does not include controls related to plant health (i.e. issuing plant passports and 

applying the ISPM15 mark to wood packaging to show it was treated to prevent the spread of 
insects, seeds and fungi), the marketing of plant protection products and the sustainable use of 
pesticides outside agriculture. 

19  National authorities do not have to report the number of entities active in animal transport; the 
data requested for official controls and non-compliance issues for slaughterhouses and game 
handling establishments were the number of carcasses or the weight, therefore a total cannot be 
used. 

10 

 
 
 
 
                                                      
The staff working document accompanying this report20 provides a further breakdown 
of these figures across the different areas of the food chain. 

20 Commission staff working document accompanying the document: report from the Commission on 
the overall operation of official controls carried out in EU countries (2019-2020) to ensure the 
application of food and feed law, rules on animal health and welfare, plant health and plant 
protection products. 

11 

 
 
 
                                                      
      Figure 2 – Official controls carried out by EU countries - 2020 

12 

 
 
 
Farming - plants 

# 

Number of operators 

Farming - animals 

Number of official controls 

Farming - mixed 

Aquaculture 

Fishing 

Hunting 

Animal feed 

Transport of animals 

Slaughterhouses and game 
handling 

Food production 

Animal by-products processing 

Food distribution 

Wholesale and retail 

Food service 

Food contact materials 
producers 

Number of non-compliance 
issues 

Number of administrative 
sanctions 

13 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 2 – Official controls 2020 – general overview 

Entities 

Official controls 

Non-compliance 
issues 

Administrative 
sanctions 

Farming 

8 233 476 

Food wholesale 

3 957 451 

Food service 

2 509 326 

Food production 

1 234 557 

Animal feed 

248 634 

Animal transport   969 746 

Food wholesale 

850 550 

Food service 

844 865 

Food production 

730 057 

Farming 

443 684 

Food service 

226 092 

Food wholesale 

167 746 

Food production 

117 313 

Farming 

92 280 

Animal transport  16 793 

Food wholesale 

131 761 

Food service 

112 787 

Food production 

70 329 

Farming 

51 243 

Animal transport  7 787 

14 

 
 
 
 
 
 
 
 
 
 
 
 
 
2 
EU countries’ annual reports 

The use of the new standard model21 form on the digital platform facilitates 
reporting, by electronic means and in a uniform way, of the outcome of official 
controls, the type and number of cases of non-compliance and the measures taken. It 
allows these to be more easily compiled into EU-wide statistics. 

The legal deadline for submitting the electronic report is 31 August. Because this 
platform was used for the first time for the 2020 annual reports, the platform was 
opened again on 15 October 2021 to allow for late reporting. Despite this, Malta did 
not submit its report in time to be included in this report. 

Due to the change in reporting, some EU countries encountered problems in gathering 
the data in the format required. It was also more difficult for EU countries to compare 
the results of their controls with those from previous years. 

The report platform contains some text boxes to describe the relevant topics. The 
national authorities provided less information than in the previous years’ reports, and 
less than envisaged in the guidance note.  

Regarding animal welfare, in general, the EU countries provided neither an analysis of 
the most serious findings, nor their action plans to prevent or decrease recurrence. 
This makes it impossible for the Commission to provide a summary in that regard. 

Similarly, the information provided on controls targeting fraudulent and deceptive 
practices was very limited. 

21 Commission Implementing Regulation (EU) 2019/723. 

15 

 
 
    
                                                      
3 
Organisation and performance 
of official control systems 

The EU countries have set up official control systems to verify the application of the 
legal framework by food and feed businesses. 

In their MANCPs, the national authorities set out their strategic objectives. The 
guidance for completing their annual reports invites them to include a table with the 
results of performance indicators used to measure these objectives. Most EU 
countries did not provide such an overview of the results of their indicators. Some 
positive examples to note are as follows: 

● 

Belgium includes barometers for food safety, animal health and plant health in 
its public annual report (up to the 2019 reporting year, this was the report sent 
in to the Commission). The comparison of the barometer results for different 
years allows readers to see whether the situation in these areas is improving or 
not. 

● 

Finland provided some examples of how the results of official controls can lead 
to changes in targets or objectives:  

■ 

■ 

the high number of deficiencies observed on animal welfare during 
transport led to an increase in the frequency of official controls on the 
welfare of animals during transport; 

for the sampling of fertilisers, the number of deficiencies they identified 
was relatively high for the low number of samples taken, which gives an 
indication of successful risk-based targeting of controls; 

■  market surveillance of the seed trade showed fewer deficiencies than 

compared to previous years. On the other hand, approximately 30% of the 
cases led to sanctions, showing an improvement in the effectiveness of 
controls. 

All EU countries faced problems in implementing the full inspection programmes, due 
to the restrictions put in place to contain the COVID-19 pandemic. 

16 

 
 
   
Other factors leading to national authorities not completely implementing their 
planned programmes included staffing levels, resources and preparations for Brexit. 

Official controls during a pandemic 

The various restrictions put in place to contain the spread of COVID-19 and the 
impact that these had on the deployment of staff resources, made it more difficult 
for EU countries to carry out all official controls as initially planned for 2020. While 
there was flexibility in how to carry out official controls, national authorities had to 
reconsider their business continuity plans and prioritise control activities seen as 
absolutely essential while addressing pandemic-driven changes in placing food on the 
EU market, such as the increase in e-commerce and take-away services. 

Actions taken by national authorities included: 

● 

● 

postponing and/or reducing the number of controls carried out in certain areas 
(based on risk assessment); 

reducing the time needed on-the-spot by conducting the documentary part of 
the control remotely; 

● 

using remote audit techniques. 

17 

 
 
 
 
 
 
 
4 
Measures taken to ensure the 
effective operation of the 
MANCP 

The MANCP's objective is to ensure that official controls are carried out in a manner 
that is risk-based and efficient across the entire agri-food chain, in compliance with 
the Official Controls Regulation.  

When official controls identify non-compliance issues, national authorities need to 
take action to ensure that the business remedies the issue and prevents further 
occurrences22.  

National authorities are also required to verify the effective operation of the official 
control system, and to take the necessary actions to rectify any shortcomings 
identified in their control systems23. 

22 Article 138 of Regulation (EU) 2017/625. 

23 Article 12 (2) and (3) of Regulation (EU) 2017/625. 

18 

 
 
 
                                                      
4.1 
Actions to ensure business compliance 

Some annual reports provided examples of actions by national authorities.  

EU countries run public information campaigns and provide guidance and training to 
businesses, to help them comply with food safety rules.  

Belgium, the Netherlands and Sweden include the results of private (third party) 
assurance schemes in their official control systems. Belgium and Finland noted that 
inspection results are better in businesses certified under these schemes. 

Finland publishes sector-specific reports. It noted that key ways of improving 
effectiveness include increasing interaction with all interested parties. As a result, 
official controls and their published results contribute to improving the operating 
conditions and competitiveness of companies, for example, by supporting their ability 
to engage in international trade and through the proactive prevention of problems.  

Poland publishes summary information of the results of the controls carried out by its 
Trade Inspectorate. It adds practical tips for consumers on how to choose products 
and to prevent being misled. It also publishes administrative decisions imposing fines 
on businesses for placing on the market products of insufficient commercial quality, 
including adulterated products. 

19 

 
 
      
4.2 
Enforcement by national authorities 

The EU countries apply a range of enforcement actions, from verbal and written 
warnings, through to seizure and destruction of goods and the (temporary) removal or 
restriction of approvals of businesses. Administrative fines are used as a dissuasive 
measure. Referral to Court remains as a last resort.  

National  authorities  must  have  effective,  proportionate  and  dissuasive 
sanctions/penalties in place24.  

Table 3 shows the number of administrative sanctions applied across the different 
parts of the food chain. Table 4 shows these sanctions across the different areas and 
Table 5 shows the number of judicial actions taken across the different areas. 

Table 3 – administrative sanctions – activities - 2020 

24  Articles 54 and 55 of Regulation (EC) No 882/2004 (until 14 December 2019) and 137, 138 and 

139 of Regulation (EU) 2017/625. 

20 

AquacultureFishingFoodcontactmaterialsHuntingABPFooddistributionFeedAnimaltransportFarmingFoodproductionFoodservicesFoodwholesaleretailSanctions17627532835515755472618077875124370329112787131761020000400006000080000100000120000140000 
 
  
 
                                                      
Table 4 – administrative sanctions – areas - 2020 

Table 5 – Judicial actions taken - 2020 

21 

Deliberatereleaseinto theenvironment ofGMOsfor thepurposeof…Animalby-products:Prevention andminimisation ofrisks tohuma…Protectivemeasuresagainstpests ofplantsFeedandfeedsafetyPlantprotectionproducts -sustainable useofpesticidesUse andlabellingofPDO/PGI/TSGAnimalhealthAnimalwelfareFoodandfoodsafety(includingfarming,huntingandfishing)Administrative86290434011323914331154272265829944307756050000100000150000200000250000300000350000Deliberatereleaseinto theenvironment ofGMOsfor thepurposeof food…Protectivemeasures againstpests ofplantsAnimalby-products:Prevention andminimisation ofrisks tohuman…Use andlabellingofPDO/PGI/TSGFeedand feedsafetyPlantprotectionproducts-sustainable useofpesticidesAnimalhealthAnimalwelfareFoodand foodsafety(includingfarming,huntingandfishing)Judicial03613021158170192721969687020004000600080001000012000 
 
 
 
4.3 
Actions to ensure the effective operation of official 
control services 

EU countries must carry out audits on their own control systems, or have audits 
carried out on themselves, and have control verification procedures25 in place to 
ensure compliance and that the control systems are effective. 

The annual reports included limited information on these audits and other verification 
activities assessing the effectiveness of the official control systems. 

Sweden described some benefits from cooperation between the different authorities. 
The initial stage of good control practice focused on two areas, namely the control 
procedure and ethics in the job role. They developed guidelines and an online training 
course. One of the overall goals is that the cooperating authorities take joint 
responsibility for the entire food chain, including being prepared for unplanned and 
unforeseen events. Good control practice involves a shift towards a different control 
culture and the creation of a system for equivalence between their systems. 

To ensure the effectiveness of its official control system, Germany included three 
operational objectives in the MANCP, relating to the professional standard of the 
audits, risk-focused audit planning and the effectiveness of official controls. 

25 Articles 6 and 12 of Regulation (EU) 2017/625 

22 

 
 
    
 
 
 
 
 
                                                      
Part 2 
Commission control 
activities in EU 
countries 

23 

 
 
1 
Audits 

The Directorate for Health and Food Audits and Analysis in the 
European Commission’s Directorate-General for Health and Food Safety verifies 
whether the EU legislation on food and feed safety, animal health, animal welfare, 
plant health, organic farming and geographical origin schemes (PDO/PGI/TSG) is 
properly implemented and enforced in the EU countries. The main tool used is the 
audit.  

We carry out these controls on a regular basis and in cooperation with the competent 
authorities in the EU countries. 

One frequent element of the audits is on-the-spot verification, where Commission 
experts engage with the national authorities carrying out official controls. Experts 
from EU countries regularly assist Commission experts in this task. 

These controls aim to: 

● 

verify the application of food and feed law, rules on animal health and welfare, 
animal by-products, plant health and plant protection products, the sustainable 
use of pesticides, genetically modified organisms, organic production and 
labelling of organic products, the use and labelling of protected designations of 
origin, protected geographical indications and traditional specialities; 

● 

verify the functioning and organisation of national control systems and the 
competent authorities; 

● 

investigate and collect information 

—  on official controls and enforcement practices; 

—  on important or recurring problems with applying or enforcing the rules; 

— 

in relation to emergency situations, emerging problems or new 
developments. 

24 

 
 
 
DIRECTORATE-GENERAL FOR HEALTH AND FOOD SAFETY 

DIRECTORATE HEALTH AND FOOD – AUDITS AND ANALYSIS 

We publish our annual work programme, and a mid-year update, on 

the Commission website. 

analysis work and how it benefits people in the EU. 

Watch our short videos to see how we organise our audit and 

The 2019-2020 audit and analysis programmes26 focused on: 

● 

● 

● 

● 

● 

● 

antimicrobial resistance; 

better preparedness for, prevention of and response to human, animal and plant 
health threats; 

safe and sustainable food and food production systems; 

effective implementation of EU food legislation; 

sustainable food production that improves the welfare of animals; 

effective, efficient and reliable controls. 

In 2019 and 2020, we carried out 170 audits and similar checks on the official 
control systems of the EU countries.  

Chart 1 shows the number of audits carried out spread over the EU countries. Chart 2 
shows the number of audits per control area. 

26 The work programmes are published on the Commission website. 

25 

 
 
 
                                                      
Chart 1 – Audits carried out - EU countries – 2019-2020 

26 

 
 
 
 
 
 
 
 
 
Chart 2 – Audits carried out per control area – 2019-2020 

The reports of the individual audits are publicly available on the Commission’s 
website. 

Commission controls during a pandemic 

Travel restrictions imposed due to the COVID-19 pandemic necessitated a rethink on 
the way we carry out our controls and the use of remote audit methods in certain 
areas. 

A total of 43 of the 2019-2020 audits were carried out totally remotely, including 
using videoconferencing in place of face-to-face meetings. These provided a certain 
level of evidence. Remote visits to the facilities of business operators to ascertain the 
implementation of official controls were, however, not possible.    

The Official Controls Regulation requires the Commission to draw up an annual or 
multi-annual control programme27 to verify how EU agri-food chain legislation is 
being implemented in the EU countries. The programme for 2021-202528 was 
adopted on 23 October 2020.  

27  Article 118 of Regulation (EU) 2017/625. 

28 Implementing Decision (EU) 2020/1550 on establishing the multiannual programme of controls for 
the period 2021-2025 to be carried out by Commission experts in the EU countries to verify the 
application of Union agri-food chain legislation. 

27 

 
 
 
 
                                                      
2 
Recommendations 

Our audits generally lead to recommendations for corrective action. EU countries are 
required to take the necessary actions to address these29 and describe them in action 
plans. 

The controls carried out in 2019-2020 resulted in a total of 527 recommendations to 
EU countries. Chart 3 provides an overview of these per sector. The accompanying 
staff working document provides a further breakdown of the figures over the 
different audited areas. 

Chart 3 – recommendations made over the sectors audited – 
2019-2020 

29  Articles 117(a) and 119(a) of Regulation (EU) 2017/625. 

28 

 
 
 
 
 
                                                      
3 
Overview reports 

Overview reports group the findings and conclusions of a series of 

Commission controls carried out in a specific area to give a general picture at EU 
level. These reports identify what is working, or not, in relation to the implementation 
of controls and the application of legislation. They also provide a good opportunity to 
share examples of good practices observed in EU countries. These reports feed into 
EU policy and can also provide the basis for exchanges with EU country experts as 
part of the Better Training for Safer Food initiative to discuss common problems and 
to share good practices. 

Table 4 – Overview reports published in 2019 and 2020 

Report number 

Topic 

2017-6304 

Avian influenza 

2018-6525 

Overview report on the safety of imported food 

2018-6537 

Overview report on internet sales of food 

2018-6780 

Biocides 

2018-6810 

Audits of official controls in EU countries 

2019-6788 

Measures to tackle antimicrobial resistance through the 
prudent use of antimicrobials in animals 

2019-6789 

AMR monitoring in zoonotic and commensal bacteria 

2019-6865 

Plants for planting and seeds 

2019-6876 

Plant health – import controls 

2019-6834 

Welfare of animals exported by road 

2019-6835 

Welfare of animals exported by sea 

2017-6246 

Overview report on shared practices in slaughter hygiene 

2020-7100 

2020-7105 

Overview report - official controls on feed additives, their 
ingredients and traceability 

Official controls on hygiene, traceability and trade 
requirements of processed animal proteins. 

29 

 
 
4 
Highlights from the Commission 
controls carried out (2019-
2020) 

The audits in the area of food safety highlighted particular challenges faced by the 
competent authorities in EU countries in relation to: 

● 

● 

● 

ready-to-eat foods (of animal origin), where a need for training and other 
support for officials and a lack of systematic reviews of businesses limit the 
follow-up of deficiencies identified in businesses' procedures to prevent cross-
contamination and sampling and testing; 

horse meat, where audits following up on the horse meat scandal identified 
issues with horse passports, databases and controls of the recording of non-
permitted treatments; and 

food of non-animal origin, where there is room to improve the controls on frozen 
soft fruit and vegetables. 

We organised a series of audits to take a deeper and broader look at the overall feed 
sector, including animal by-products, because previous audit series had revealed 
some systemic weaknesses. These audits found that there was still a need to improve 
the traceability of processed animal proteins. 

Audits on animal health looked at disease prevention, preparedness for outbreaks and 
response capacity. The information obtained regarding African swine fever and highly 
pathogenic avian influenza helped to develop a number of strategic papers and 
Commission policies on managing these diseases. 

Regarding zoonoses: 

● 

for Salmonella in poultry populations, the audits showed that, in general, EU 
countries implemented programmes that complied with the requirements and 
which were effective in meeting the EU targets in Salmonella prevalence. 
Nevertheless, in most cases the detection rate in samples taken by businesses 
(that provide a much more continuous coverage of the flock status than official 
samples)  is significantly lower than in the official samples. This may make the 

30 

 
 
 
businesses’ sampling an ineffective contribution to the programmes, and 
suggests that it is likely that low-level flock infections remain undetected. 

● 

for rabies, the audits showed good implementation of vaccination programmes, 
which led to a decrease in the number of cases in animals. 

Most EU countries have difficulties in demonstrating their level of or trends in 
compliance regarding animal welfare, due to the absence of specific objectives and/or 
a lack of defined indicators to monitor. 

A three-year project to reduce the routine tail docking of piglets was completed. It 
included audits and visits to several EU countries by a team of experts with hands-on 
experience in rearing pigs with intact tails. Its results included action plans from all 
non-compliant EU countries, which will help deliver the further progress necessary to 
stop the routine practice of tail docking. 

We continued to carry out audits on the transport of animals by sea and to work with 
the European Maritime Safety Agency to set up a system to improve official controls 
on livestock vessels and thus improve animal welfare during sea transport. 

The use of visualisation tools in a web portal supports prompt decision making, 
leading to increased plant health protection. Audits on the control measures taken by 
EU countries where there are infections by plant pests help to improve controls and 
support work to eradicate these. 

While EU countries have made progress in implementing the Directive on the 
sustainable use of pesticides, controls on the implementation of integrated pest 
management by farmers and growers remain an area of concern. 

In most EU countries, private control bodies certify organic production and the use 
and labelling of these products. The supervision of these control bodies by the 
competent authorities needs further improvement. 

Official controls in relation to products certified under the geographical origin 
schemes (PDO/PGI/TSG) do not always verify that these products comply with the 
rules in the product specifications. 

EU countries have some arrangements in place to deal with fraud threats in the agri-
food chain, but official controls focusing on fraudulent and deceptive practices are 
not yet systematically in place across all control areas. 

The staff working document accompanying this report provides a more detailed 
description of some of the main areas where the Commission carried out audits. 

31 

 
 
5 
Other Commission control 
activities 

32 

 
 
5.1 
Entry of animals and goods into the EU 

EU countries are required to carry out official controls of animals, goods of animal 
origin and some goods of non-animal origin entering the EU. They carry out the 
majority of these controls in border control posts designated for that purpose. The 
purpose of the controls is to ascertain that animals, food and feed meet the same 
high standards as those in place for animals and goods produced within the EU. EU 
countries can only designate border control posts for these controls after the 
Commission has determined that the structure and layout of the proposed border 
control posts and the arrangements in place meet the applicable EU requirements30. 
In 2020 we received and assessed 67 notifications from EU countries of new (or 
amendments to existing) border control posts, including their inspection centres.   

Our oversight of EU countries' official controls on entry of animals and goods 
continued in 2019 and 2020, with 11 audits being carried out. The results of these 
confirm that EU countries continue to improve their systems and the implementation 
of controls. These audits will continue in future years. In addition, we carried out desk-
based evaluations on the implementation of controls on entry of animals and goods 
through those border control posts located in the outermost regions of the EU, again, 
with satisfactory results.   

30  Regulation (EU) 2017/625 and associated legislation such as Regulation (EU) 2019/1014, 

Regulation (EU) 2019/1012 and Regulation (EU) 2019/1081. 

33 

 
 
 
                                                      
5.2 
Residues of veterinary medicinal products and 
environmental contaminants in animals and products of 
animal origin 

Veterinary medicinal products are widely used in animal production to either prevent 
or cure diseases. Very low concentrations – residues – of the pharmacologically active 
substances present in the veterinary medicines may be present in the meat, offal and 
milk products from treated animals and also in milk, eggs and honey. Safe 
concentrations in food – ‘maximum residue limits’ – are set at EU level. Food 
containing residues at and below this limit is deemed safe and may be placed on the 
market, demonstrating that the principles of good agricultural and good veterinary 
practice have been adhered to in animal production (medicines used in accordance 
with their label instructions). EU countries implement annual residue monitoring 
programmes to verify that veterinary medicinal products are used in accordance with 
the applicable EU rules, and to detect the potential misuse or illegal use of 
pharmacologically active substances. These programmes also include monitoring 
animals and animal products for the presence of environmental contaminants and 
pesticides.  

Each year, we, together with the relevant European Union reference laboratories, 
review the EU countries' residue monitoring plans, and provide comments and 
recommendations on their suitability. We also audit EU countries’ implementation of 
their residue monitoring plans, focusing on elements such as laboratory performance 
and the effectiveness of follow-up investigations of non-compliant results. In 2019 
and 2020, we carried out eight audits in EU countries with largely satisfactory results.  
These audits will continue in future years. 

34 

 
 
 
 
6 
Systematic follow-up of audit 
recommendations 

35 

 
 
6.1 
General follow-up audits 
Through general follow-up audits, we systematically follow up the actions that 
competent authorities committed to implement to address the recommendations 
made in audit reports. These audits cover all of the ‘open’ recommendations across 
all sectors.  

These audits can be: 

● 

● 

● 

carried out at the offices of the competent authorities, or by remote means; 

carried out as a desk-based exercise from our offices (administrative follow-up); 
or 

focused on a specific topic: in a small number of cases, when the outcome of the 
audit is particularly problematic, sector-specific follow-up audits are arranged, to 
follow up on actions which must be urgently implemented by the EU countries. 

Table 5 – Follow-up audits in EU countries in 2019-2020 

General follow-up 
audits: 

Desk-based follow-up: 

Specific topic: 

This process continued to be effective in dealing with the vast majority of issues 
identified. The results of general follow-up audit actions are published in country 
profiles (see 6.2, below). 

At the end of December 2020, EU countries had taken corrective action, or provided 
satisfactory commitments to address shortcomings within acceptable timelines. 
Based on a three-year rolling indicator, corrective actions had been taken on 92% of 
recommendations resulting from audits carried out in the three year period 2016- 
2018.  

36 

 
 
 
 
 
 
6.2 
Country profiles 
Country-specific knowledge is important when preparing audits and in informing 
policy-making. Therefore, we maintain and publish country profiles.  

These country profiles are publicly available and give an overview for each EU 
country, including: 

● 

● 

● 

● 

the five most recently published audit reports; 

the assessment of the actions taken by the country in response to audit 
recommendations; 

the organisation of official controls in the country; 

links to relevant websites in the country. 

The publication of these country profiles helps ensure the full audit cycle is 
transparent to the public. 

37 

 
 
 
6.3 
Enforcement 

When an EU country breaches EU law, the Commission determines 

appropriate actions on a case-by-case basis, in line with the approach laid down in its 
Communication ‘EU law: Better results through better application’31. These actions 
may range from contact with the EU countries' authorities at appropriate levels to 
ensure the correct application of EU law, up to launching EU Pilot exchanges and/or 
infringement proceedings as a last resort, where all other avenues to encourage 
compliance have been exhausted. Enforcement tools other than infringements for 
food safety also include protective or safeguarding measures. These can range from 
taking precautionary measures on the trade in and movements of animals, plants or 
food and feed products to adopting safeguarding measures in accordance with the 
relevant legislation. 

If contact with EU countries or EU Pilot exchanges do not result in the breach of law 
being corrected, the process may enter the pre-litigation and litigation phases of the 
infringement procedure32.  

In 2019, the Commission opened an infringement case against Czechia on its 
systematic official controls of certain foodstuffs coming from other EU countries 
every time these foodstuffs entered the country, in breach of EU rules on official 
controls ensuring compliance with feed and food law, animal health and animal 
welfare rules33.  

The Commission closed two longstanding infringement cases in 2019: 

—  Greece: relating to a shortage of staff assigned to the services responsible for 

veterinary controls; and 

—  Portugal: relating to measures to prevent the spread within the EU of the pine 

wood nematode. 

31 2017/C 18/02: Communication from the Commission: EU law: Better results through better 

application 

32 Article 258 of the Treaty of the Functioning of the EU. 

33 A letter of formal notice was sent in January 2019 and a reasoned opinion in July 2019. . In July 

2020 an additional letter of formal notice was sent. 

38 

 
 
                                                      
In 2019, the Court of Justice of the European Union ruled that Italy 

failed to adequately prevent the further spread of the quarantined harmful organism 
Xylella fastidiosa in Apulia34. 

In 2019-2020, the Commission did not refer any cases to the court in the areas 
subject to official controls covered by this report. 

34 Judgment in case Commission v Italy, C-443/18 

39 

 
 
 
 
 
                                                      
7 
Support for EU countries 

40 

 
 
7.1 
Networks 

The Directorate for Health and Food Audits and Analysis hosts a 
number of networks and working groups comprised of officials from competent 
authorities of the EU countries and Iceland, Liechtenstein and Norway to discuss and 
promote the implementation of certain aspects of EU law.  

Since 2008, two networks have met regularly to exchange experiences on the 
preparation, implementation and reporting of MANCPs and on the implementation of 
national audit systems (NAS) on official controls. During 2019 and 2020, the MANCP 
network met six times, twice remotely. The meetings were mostly focused on the 
development, and finalisation, of the two guidance documents on preparing the 
MANCP and EU countries' annual reports. The challenges and opportunities that EU 
countries faced during 2020 because of the COVID-19 pandemic in implementing 
official controls were also discussed.  

The MANCP network also helped test the electronic version of the standard model 
form for the annual reports, the ‘annual reporting on official controls – AROC’ tool, to 
help EU countries get ready to submit this for the first time in 2021. 

The NAS network met three times during 2019 and 2020, once remotely. The 
meetings facilitated the development and finalisation of the guidance document on 
conducting audits under Article 6 of the Official Controls Regulation. The NAS 
representatives and the Commission exchanged their experiences in implementing 
their audit programmes during the COVID-19 pandemic, focusing on good practices 
identified. 

In 2019 and 2020, the network of EU countries’ national contact points for the 
protection of animals during transport met three times to discuss animal welfare 
indicators for transport controls, the transport of unweaned calves, resting points in 
non-EU countries, transport in extreme temperatures and the transport of animals 
using livestock vessels. In 2020, the national contact points finalised the update to 
the network document on livestock vessels. 

During the first wave of the COVID-19 pandemic, the network played an important 
role coordinating the exchange of information to avoid livestock trucks being held at 
national border crossings due to restrictions on movement. 

41 

 
 
In order to help EU countries address weaknesses in the system, the Commission 
created two working groups, dealing with formulation analysis and enforcement in 
relation to plant protection products (PPP). Representatives of more than 20 EU 
countries attended the meeting of the working group for PPP formulation analysis 
and the three meetings of the PPP enforcement working group organised by the 
Commission in 2019. Due to the higher priority given to evaluating the Sustainable 
Use of Pesticides Directive (SUD), the working group on authorisation and formulation 
analysis was transferred to the Commission policy unit on pesticide authorisation and 
the working group for enforcement was discontinued.    

The Commission organised a joint meeting of the SUD and the PPP Enforcement 
working groups in May 2019 to address issues of mutual concern, in conjunction with 
a workshop on integrated pest management (IPM). The workshop's objective was to 
help EU countries to assess the implementation of IPM at farm level, building on the 
experience gained during the Better Training for Safer Food courses on IPM. In 
November 2019, the SUD working group held a joint meeting with the working group 
on agro-environmental statistics, which addressed issues of mutual concern, in 
particular relating to the development of more useful harmonised risk indicators. In 
2020, one SUD working group meeting was organised in November, focusing on 
technical aspects of the evaluation and revision of the SUD, which began in late 
2019. 

In December 2020, EU countries' competent authorities were invited, through the SUD 
working group, to provide their feedback on possible future policy options. In 
December 2020, a contract was signed for an external study supporting the 
evaluation of the Directive and an impact assessment of its possible revision. 
Preparatory work was also undertaken for a remote Commission stakeholder event to 
take place in January 2021 and an online public consultation/(have your say) for this 
initiative to be launched in January 2021. Further details are available on the 
Commission’s Better Regulation Portal website35. 

35 Roadmap and results of the public consultation. 

42 

 
 
 
                                                      
7.2 
Better training for safer food 

 Better Training for Safer Food (BTSF) is a Commission training 
initiative to improve the implementation of EU rules covering food, feed, animal 
health and welfare, plant health and plant protection products, organic farming and 
geographical origin schemes (PDO/PGI/TSG). It plays a key role in improving the 
effectiveness and reliability of official controls and spreading knowledge of EU 
legislation. The Commission’s controls help identify training needs.  

The 2019-2020 BTSF programme contained an extensive range of technical topics 
and a number of sessions of particular relevance for official control systems. These 
included:  

● 

● 

● 

● 

● 

audit systems and internal auditing;  

EU sanitary and phytosanitary law enforcement;  

food fraud and food e-commerce;  

the Official Control Regulation;  

outbreak preparedness and management; support for EU audits (for national 
experts); and  

● 

EU overview reports.  

In 2020, a workshop on following up recommendations was organised. 

200 training courses took place in EU countries during 2019 and up until March 2020, 
when all face-to-face training courses had to be suspended due to the developing 
COVID-19 pandemic. In 2020, those contracts were modified to provide virtual 
training, where possible, and all new contracts now incorporate a virtual learning 
component. 

BTSF has gradually implemented online training throughout 2020, using virtual 
classrooms and e-learning modules available through the BTSF Academy. BTSF is 
expanding its e-learning offer and translating the existing modules into most official 
languages to ensure that the maximum audience will have access to training 
material, no matter what happens in the future. The academy also provides a 

43 

 
 
repository of existing training resources that officials from both EU and non-EU 
countries can use. 

  See the BTSF 2019 annual report for more information. 

44 

 
 
 
Conclusions 

The EU has comprehensive legislation to minimise safety hazards and non-
compliance issues, from farm to fork. The EU countries’ annual reports on official 
controls demonstrate that national authorities continue to fulfil their role monitoring 
and verifying that businesses along the food chain comply with relevant EU 
requirements and take enforcement measures when this is not the case. 

The introduction of a standard model form for the annual reports facilitated the 
collection of comparable information and data on the EU countries’ official controls 
across the agri-food chain. 

This report and the accompanying staff working document provide a compilation of 
these comparable data into EU-wide statistics for the year 2020. These data will, over 
time, enable trends to be identified in controls and non-compliance issues. For 2020, 
the statistics for 26 countries show that there were 16.8 million entities that came 
within the scope of official controls and that national authorities carried out more 
than 4 million official controls on these entities. Based on these controls, some 
655 000 non-compliance issues were identified, leading to the application of 388 000 
administrative sanctions and almost 13 000 judicial actions. 

As the standard model form was used for the first time, not all EU countries were 
able to submit all of the data in the format required. Following the Commission’s 
guidance note for completing the annual report, would further improve the 
comparability of information provided in the open text boxes. 

The staff working document accompanying this report provides details of the official 
controls carried out by EU countries and of Commission controls carried out in relation 
to EU requirements for food and feed law, animal health and welfare, plant health 
and plant protection products. The results of these show that EU countries have the 
necessary control systems in place and, overall, they provide levels of compliance 
compatible with food and feed safety and a healthy internal EU market. Commission 
controls identified weaknesses in some EU countries’ control systems and highlight 
room for improvement in national control systems. 

The Commission’s systematic follow-up of audit recommendations shows that, in 
general, national authorities take appropriate corrective measures to address 
shortcomings identified. 

Working in partnership with the national authorities, the Commission continues to 
support EU countries to continuously improve their official control systems through 
the networks and the BTSF initiative. 

45 

 
 
During 2020, the restrictions imposed due to the COVID-19 pandemic posed a 
challenge for national authorities and the Commission in completing their control 
plans. Staffing levels and resource constraints were also cited as reasons for national 
authorities not completely implementing their planned programmes. The restrictions 
also led to more use of remote means for carrying out controls. These technologies 
have demonstrated value and could be further explored. 

46