COMMISSION STAFF WORKING DOCUMENT Accompanying the document 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  SWD(2022) 73 final  COMMISSION STAFF WORKING DOCUMENT      Accompanying the document 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 {COM(2022) 129 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.

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Contents 

Introduction 

Food 

Genetically modified organisms 

Feed 

Animal health 

Animal by-products 

Animal welfare 

Plant health 

Plant protection products 

Organic production and labelling of organic products 

Protected designation of origin, protected geographical indications and 
traditional specialities guaranteed 

Fraudulent and deceptive practices 

National official controls programmes 

Coordinated control programmes 

Operations coordinated by Europol 

General legend 

1 

3 

14 

15 

20 

24 

28 

34 

37 

42 

45 

49 

53 

49 

50 

51 

i 

 
 
 
      
 
 
 
 
Introduction 

The Commission publishes an annual report on the operation of official controls in EU 
countries in the areas of food and feed safety, animal and plant health, animal welfare, 
pesticides, organic farming and quality schemes1. This report is based on:  

● 

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

● 

the results of Commission controls carried out in EU countries. 

The Commission’s report covers the years 2019 and 2020. It provides a compilation of 
comparable data into EU-wide statistics for 2020. These data will, over time, allow trends 
in controls and non-compliance issues to be identified.  

This staff working document accompanies the Commission’s report and provides more 
details of the controls and audits carried out by national authorities and by the 
Commission in specific areas of the food chain, as follows: 

  Food 

  Genetically modified organisms 

  Feed 

  Animal health 

  Animal by-products 

  Animal welfare 

  Plant health 

  Plant protection products/Sustainable use of pesticides 

  Organic production 

  Geographical indications 

  Fraudulent and deceptive practices 

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

1 

 
 
 
                                                           
The graphics relating to national official controls are based on the 2020 data from 26 of 
the 27 EU countries, as Malta did not submit its 2020 annual report in time to be included. 
These data are presented at EU level. Because the reporting requirements were different 
for 2019, similar comparable data are not available for that year. The text in this staff 
working document is based on information submitted for both 2019 and 2020.  

As the reporting requirements changed from 2020 onwards, not all EU countries were able 
to provide all of their data in the detail required. This limits the extent of full comparability 
in the graphics provided, as data might have been grouped by some EU countries, rather 
than split into the sub-categories.  

For the Commission controls carried out in EU countries, for each topic, a table lists the EU 
countries audited, the number of audits carried out, the number of recommendations 
raised and the distribution of these over the different topics. A description of some issues 
of particular interest is provided after the tables. 

2 

 
 
 
Food 
Official controls carried out by EU countries 

In this part of their annual reports, the EU countries have to report on the official controls 
carried out in the areas of food and food safety, integrity and wholesomeness at any stage 
of production, processing and distribution of food. This includes the rules aimed at ensuring 
fair practices in trade and protecting consumer interests and information, and the 
manufacture and use of materials and articles intended to come into contact with food. 
Therefore, data relate to the whole food chain, from farming, fishing and hunting to food 
production, distribution, wholesale, retail sale and food services. 

The EU countries’ annual reports do not contain a lot of information on how the level of 
compliance is followed up. While some reported that, in general, compliance was sufficient 
and/or in line with previous years, no data on performance indicators were given. 

Most EU countries reported that a reduced number of official controls were carried out in 
2020 due to the COVID-19 pandemic. This makes it more difficult for them to compare the 
2020 results with those from previous years. 

Some of the annual reports contained information on the type of non-compliance issues 
found with food businesses. Problems were identified in the maintenance of premises and 
equipment, personal hygiene and training, food storage, procedures based on HACCP2 
principles, food handling and the respect of best before/use by dates. National authorities 
indicate that reasons for non-compliance include ignorance of legislation on the part of the 
business operators and, in some cases, intentional misconduct. 

Table 1 provides a heat map of the numbers of businesses, official controls carried out, 
non-compliance issues identified and administrative sanctions applied across the different 
parts of the food chain, in 2020. 

The highest numbers in each column have the darkest shade of colour.  

2 Hazard analysis and critical control points – Article 5 of Regulation (EC) No 852/2004 of the European 

Parliament and of the Council 

3 

 
 
 
 
                                                           
Table 1 – official controls – food sectors - 2020 

Businesses 

Controls 

Animal production 

Aquaculture 

Growing of crops 

Mixed farming 

Hunting 

Fishing 

Meat of domestic ungulates 

Meat from poultry and lagomorphs 

Meat of farmed game 

Wild game meat 
Minced meat, meat preparations and mechanically separated 
meat (MSM) 
Meat products 

Treated stomach, bladders and intestines 

Rendered animal fats and greaves 

Gelatine 

Collagen 
Highly refined chondroitin sulphate, hyaluronic acid, other 
hydrolysed cartilage products, chitosan, glucosamine, rennet, 
isinglass and amino acids 
Colostrum, raw milk, colostrum-based and dairy products 

Egg and egg products 

Fishery products 

Live bivalve molluscs 

Frogs' legs and snails 

Honey 

Sprouts 

Processing and preserving of fruit and vegetables 
Manufacture of grain mill products, starches and starch 
products 
Manufacture of bakery and farinaceous products 

Manufacture of vegetable oils and fats 

Manufacturers of beverages 

Manufacture of other food products 

Establishments producing food contact materials 
General activity establishments (cold stores, re-wrapping and 
re-packing establishments, wholesale markets, reefer vessels) 
Transport and storage 

Wholesale 

Retail 

Food and beverage service activities 

Others 

1 536 971 

14 810 

1 795 645 

185 838 

238 112 

43 210 

17 250 

4 349 

1 094 

1 441 

7 240 

24 012 

817 

906 

146 

81 

12 

30 380 

8 006 

12 600 

4 050 

257 

9 381 

171 

51 160 

5 427 

746 857 

16 768 

79 371 

181 601 

33 015 

16 712 

190 943 

193 600 

152 936 

17 002 

Non-
compliance 
issues 
14 017 

248 

3 102 

3 067 

579 

302 

9 800 

1 235 

1 037 

7 007 

10 309 

611 

400 

40 

25 

320 

9 343 

1 486 

5 637 

913 

82 

2 

64 

6 195 

758 

Sanctions 

6 032 

87 

2 474 

6 082 

344 

272 

12 930 

6 450 

311 

561 

3 441 

4 918 

408 

209 

27 

17 

147 

4 097 

787 

2 027 

665 

43 

2 

43 

4 324 

520 

25 979 

13 433 

1 142 

4 007 

8 758 

1 168 

7 057 

4 901 

8 349 

776 

2 605 

6 197 

322 

2 215 

2 620 

5 312 

64 789 

3 912 

24 610 

13 515 

4 012 

4 860 

52 747 

10 152 

9 170 

41 390 

76 322 

6 608 

7 984 

539 

456 

20 

75 757 

13 446 

25 856 

3 869 

266 

3 357 

199 

29 767 

5 223 

90 940 

7 136 

31 333 

53 286 

4 776 

57 992 

49 770 

55 739 

3 737 304 

2 444 358 

204 027 

763 841 

802 830 

81 002 

151 777 

201 183 

23 614 

104 902 

103 000 

6 346 

4 

 
 
 
 
 
Official controls in the food chain need to cover a broad range of food categories and a 
number of specific topics: 

1. Dairy products 

2. Dairy alternatives 

3. Fats and oils, and fat 
and oil emulsions 

4. Edible ices 

5. Fruit and vegetables 

6. Confectionery 

7. Cereals and cereal 
products 

8. Bakery wares 

9. Fresh meat 

10. Minced meat, meat 
preparations and MSM 

11. Meat products 

12. Fish and fisheries 
products 

13. Eggs and egg 
products 

14. Sugar, syrups, honey 
and table-top sweeteners 

15. Salts, spices, soups, 
sauces, salads and 
protein products 

16. Foods intended for 
particular nutritional uses 
as defined by Regulation 
(EU) No 609/2013 of the 
European Parliament and 
of the Council 

17. Beverages 

18. Ready-to-eat 
savouries and snacks 

19. Desserts excluding 
products covered in 
categories 1, 3 and 4 

20. Food supplements as 
defined in point (a) of 
Article 2 of Directive 
2002/46/EC of the 
European Parliament and 
of the Council excluding 
food supplements for 
infants and young 
children 

21. Processed foods not 
covered by categories 1 
to 17, excluding foods for 
infants and young 
children 

22. Others – foods not 
covered by categories 1 
to 21 

23. Food contact 
materials 

Table 2 provides an overview of the official controls carried out in the EU countries3 during 
2020 on the above food categories and specific topics, in relation to EU rules in 10 cross-
cutting areas. 

Table 3 gives an overview of the number of non-compliance issues detected and the 
number of administrative sanctions applied by the national authorities in the different 
sectors. 

Both tables list the top five food categories for the specific topics. 

3 Malta did not report in time for this report; Belgium, Ireland, Latvia and Sweden provided incomplete data. 

5 

 
 
 
 
 
                                                           
Table 2 – official controls – topics – top 5 - 2020 

Microbiological criteria 

Pesticides in food 

Contaminants in food 

Residues of veterinary medicinal products in food 

Labelling, nutritional and health claims 

Genetically modified organisms (GMOs) in food 

Improvement agents (additives, enzymes, 
flavourings, processing aids) 

Irradiation of food 

Contamination by/migration of food contact 
materials 

Other 

7 

 
 
 
 
 
 
 
 
 
 
 
 
Table 3 – non-compliance issues & sanctions – topics – top 5 - 2020 

Microbiological criteria 

Pesticides in food 

Contaminants in food 

Residues of veterinary medicinal products in food 

Labelling, nutritional and health claims 

Improvement agents (additives, enzymes, flavourings, 
processing aids) 

Other topics 

Administrative sanctions 

8 

 
 
 
 
 
 
 
 
 
 
 
 
 
The EU countries need to report in more detail on a number of specific topics: 

Number of non-
compliance issues 
identified 

Number of administrative 
sanctions applied 

The labelling of 
genetically modified 
organisms (GMO) used 
in food products 

The use of unauthorised 
GMO’s in food products 

Irradiation of food 

15 

1 

9 

Food contact materials 

1740 

Novel food4 

208 

11 

1 

5 

534 

146 

4 ‘Novel food’ is food that humans in the EU did not consume to a significant degree before 15 May 1997. 

9 

 
 
 
 
 
 
 
 
                                                           
Commission controls of EU countries 

EU countries audited: 

Number of audits carried out: 

39 

Poland: 6 – Belgium: 3 - Malta: 3 – 
Germany: 2 -  Spain: 2 - France: 2 –Italy: 
2 - Cyprus: 2 - Romania: 2 – Slovenia: 2 

Total number of recommendations raised: 

164 

Recommendations per audit area: 

The following controls in these areas are highlighted: 

Ready-to-eat food 

In 2019, we concluded a series of audits and fact-finding missions to assess the 
arrangements put in place by the competent authorities in the EU countries to verify 
businesses’ compliance with food hygiene requirements that apply to ready-to-eat food.  

10 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The audits/missions focused on how national authorities implemented official controls in 
establishments that produce ready-to-eat food mainly of animal origin, which is considered 
to potentially pose a higher microbiological risk to consumers.  

The series found that the official controls were, in general, effective in identifying hygiene 
non-compliance issues.  

However, on-the-spot visits identified instances where national controls had either not 
detected certain non-compliance issues or, more often, had detected them, but had not 
consistently or effectively followed up to verify that businesses had rectified the problems 
in a timely fashion. These issues related mainly to:  

● 

● 

businesses' procedures to prevent cross-contamination; and  

businesses’ procedures based on HACCP principles, including sampling and testing 
requirements.  

In some cases, these non-compliance issues led to food safety alerts and outbreaks of 
food-borne illnesses.  

These ineffective elements in the controls stem from different but sometimes shared 
challenges, for instance: 

● 

● 

addressing training/support needs for staff carrying out controls in this sector (where a 
substantial range of requirements need to be checked); or  

implementing more systematic reviews of businesses aimed at identifying the 
underlying causes of contamination incidents in order to have them address these 
effectively and to prevent the issues from reoccurring.  

The audits also found that EU countries have put in place different measures to address 
some of the challenges for official controls identified in this area, as well as facilitating 
business operator compliance and consumer awareness. 

11 

 
 
 
 
Horsemeat 

Official controls carried out by EU countries unveiled the ‘horsemeat scandal’ in 2013, 
identifying the presence of horsemeat in meat labelled as beef. The discovery led to the 
recall of beef products in supermarkets across Europe and further investigations, leading to 
prosecutions in several EU countries. 

Against this background, we carried out four audits in 2019 to assess the performance of 
the official control systems, and to identify improvements (if any) made following the 2013 
scandal. 

The audits identified that the competent authorities had strengthened their official control 
systems and the applicable national legislation, with the aim of improving compliance with 
and enforcement of the relevant EU requirements, and ensuring that only horses with the 
correct identification and clearance for slaughter enter the food chain.  

Nevertheless, the audits identified a number of deficiencies and challenges faced by 
competent authorities in controlling this sector. The main challenges include:  

● 

● 

● 

● 

● 

verification of the horse passports’ reliability and veracity, as these are issued by 
multiple bodies across the EU; 

swift corroboration of the horses’ status in other EU countries’ national databases; 

accuracy of the information available in these databases; 

controls on the mandatory recording of non-permitted treatments; and  

issues regarding the return of horse passports which are no longer valid to the 
respective passport issuing bodies. 

12 

 
 
 
 
Food of non-animal origin 

In 2018 we began a second series of audits to evaluate the effectiveness of official 
controls to verify – and where necessary enforce - the implementation of food hygiene 
requirements by businesses, in particular those requirements which aim to prevent 
microbiological contamination of food of non-animal origin.  

An initial audit series, carried out between 2013 and 2016, identified a number of 
shortcomings, most notably that: 

● 

● 

● 

official controls on primary producers of food of non-animal origin intended to be 
eaten raw were not or not sufficiently focused on the risk of microbiological 
contaminants; 

official samples to verify microbiological contamination were rarely taken; 

as regards sprout production, controls were not sufficiently effective in verifying and 
enforcing the requirement that seeds used for sprouting are specifically produced for 
this purpose, or that they are fit for sprouting. 

During the course of the initial series, we observed notable improvements in EU countries’ 
official control systems, with more focus being placed on microbiological risks. EU countries 
responded positively to the recommendations made in those audit reports. 

This second series extended the scope of the audits to include frozen fruits and vegetables. 
These products are an increasingly important food source in the EU, but are also associated 
with food-borne outbreaks.  

The first six of these follow-up audits demonstrated progress on implementing official 
controls at the stage of primary production, though there is still significant scope for 
improvement in controls on frozen soft fruits and vegetables. 

The audits also established that third-party certification schemes and (associated) 
inspections implemented by major retailers, discounters and supermarkets play an 
important role in reducing microbiological risks associated with food of non-animal origin. 
These efforts are consistent with the General Food Law5, which gives food business 
operators primary responsibility for the production of safe food. 

5  Regulation (EC) No 178/2002. 

13 

 
 
 
                                                           
Genetically modified 
organisms 

Official controls carried out by EU countries 

EU countries must carry out official controls to monitor the deliberate release into the 
environment of genetically modified organisms (GMOs) for the purpose of food and feed 
production. In most EU countries, there are no deliberate release activities.  

Table 4 provides an overview of the number of official controls carried out, non-compliance 
issues identified and administrative sanctions applied in 2020, in relation to the commercial 
cultivation, experimental release and seeds and vegetative propagating materials for use in 
food and feed6. 

Table 4 – official controls – GMOs - 2020 

Commission controls  of EU countries 
The 2019 and 2020 work programmes did not include any audits relating to the deliberate 
release of GMOs into the environment. 

6 The use and labelling of GMO in food and feed is reported in the food and feed sections. 

14 

 
 
 
 
 
 
                                                           
Feed 
Official controls carried out by EU countries 

Businesses active in the feed sector can be classified as follows: 

- 
registered establishments; 
-  approved establishments7;  
-  businesses manufacturing and/or trading medicated feeding stuffs; 
- 

farmers using feed. 

Table 5 gives an overview of the numbers of establishments, official controls carried out, 
non-compliance issues identified and administrative sanctions applied at EU level8, in 2020. 

Table 5 – official controls – feed - 2020 

7 These businesses carry out operations involving more sensitive substances, such as certain feed additives, 
premixtures and compound feedingstuffs, requiring prior approval (all establishments need to at least be 
registered with the authorities). 

8 Data for 25 EU countries: Malta did not submit its report in time to be included in this report; Luxembourg 

provided incomplete data. 

15 

 
 
 
 
 
                                                           
Official controls in the feed sector cover issues such as feed labelling, traceability, 
additives, undesirable substances, medicated feed, pesticides and GMOs. 

Non-compliance issues and sanctions were attributed to businesses’ shortcomings in one or 
more of the following: labelling/traceability, feed safety, additives, undesirable substances, 
prohibited materials, medicated feed, pesticides, the use of unauthorised GMOs and the 
labelling of GMOs. 

The graphics in Table 6 give an overview and breakdown of the numbers of official controls 
carried out, non-compliance issues identified and administrative sanctions applied over 
these different aspects9, in 2020. 

While pesticide residues in feed is the biggest focus of official controls, most non-
compliance issues and administrative sanctions related to feed labelling and traceability. 

Specific non-compliance issues mentioned in the EU countries’ annual reports included:  

- 
the maintenance of premises and equipment, hygiene rules and cleanliness; 
-  self-monitoring plans not addressing all risks, the formalisation and updating of 

documents (tests, traceability, etc.), maintenance of permanent written procedures 
based on the HACCP principles (deficient HACCP or HACCP not being adapted or 
updated), lack of record-keeping or inadequate documentation; 
feed labelling; 
the status of the registration/approval: operating without registration; validity of 
registration/approval; non-registration of all activities;  
incorrect use of feed additives; 
the presence of undesirable substances in feed. 

- 
- 

- 
- 

In its report, Estonia mentioned that it had prepared guidelines for online sales of feed. 

9 Some EU countries indicated that they are not yet able to provide these data in the format required. 

16 

 
 
 
 
                                                           
Table 6 – official controls – feed - 2020 
Official controls, non-compliance issues and administrative sanctions across 11 different topics, 
ranked by absolute figures 

Official 
controls 
carried out 

Non-
compliance 
issues raised 

Sanctions 
applied 

A: Labelling of feed 
B: Traceability of 
feed 
C: Safety of feed 
D: Additives in feed 
E: Medicated 
feeding stuffs 
F: GMOs in feed  
G: Labelling of 
GMO 
H: Unauthorised 
GMO in feed 
I: Pesticides in feed 
J: Undesirable 
substances in feed 
K: Prohibited 
materials in feed 

17 

 
 
 
 
 
 
Commission controls of EU countries 

EU countries audited: 

Number of audits carried out: 

Total number of recommendations raised: 

Recommendations per audit area: 

10 

France: 2 

32 

In this area the following controls are highlighted: 

General feed hygiene 

In 2020, a series of audits built on the findings of previous audits on feed additives and 
processed animal proteins, which had identified some systemic weaknesses in EU countries’ 
official controls, justifying a deeper and broader look at the overall feed sector in the EU.  

The audits covered EU countries’ official controls on feed hygiene, the approval and 
registration of feed establishments, feed labelling and EU countries’ assessment of the 
suitability of feed business businesses’ HACCP-based procedures.  

18 

 
 
  
 
 
 
 
 
 
 
 
 
 
 
We carried out three audits in 2020; three are planned in 2021, with a further three to 
follow in 2022. 

Feed additives, their ingredients and traceability 

Feed additives and their mixtures (premixtures) are used in producing feed for animals. EU 
countries must verify that feed manufacturers only place safe feed additives and safe feed 
on the market.  

We examined the implementation of official controls on feed additives, their ingredients 
and traceability in a series of audits carried out in eight EU countries in 2018 and 2019. 
This series resulted in an overview report in 202010.  

The overall results of the audits were positive, showing that EU countries’ inspections of 
feed additive (and feed) manufacturers and the testing of feed additives was working well. 
Nevertheless, several areas for improvement were noted, with common problems relating 
to the competent authorities’ assessment of feed labelling, businesses’ HACCP-based 
procedures and the implementation of appropriate sampling protocols. The relevant EU 
countries implemented corrective actions accordingly.  

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

19 

 
 
 
                                                           
Animal health 
Official controls carried out by EU countries 

Official controls  carried out in relation to the identification and registration of 
cattle, sheep and goats 

During 2020, 7% of all cattle (5% of all holdings) were the subject of an official control. 
2% of all holdings were non-compliant. For 30 171 animals (0.04%) on 1 752 holdings, the 
authorities ordered movement restrictions, for 604 holdings (23 168 animals) this affected 
all animals present. For 49 237 animals (0.06%) on 83 holdings (0.004%), destruction was 
ordered. 

For sheep and goats, 6% of the animals (4% of the holdings) were subject to an official 
control, with 2% of all holdings found to be non-compliant. 

Belgium notes that most sheep and goats in the country are kept as a hobby, with keepers 
being less aware of the need for identification and registration. Czechia notes that there is 
a high incidence of the loss of one or both ear tags for grazing animals. 

Estonia created guides and instructions for animal keepers and food business operators. 

Other official controls 

In addition to animal farming, there is a broad range of activities where controls relating to 
animal health are vital to control outbreaks and the spread of animal diseases. 

Table 7 provides an overview of the number of operators involved in these activities and 
the number of official controls carried out, non-compliance issues identified and 
administrative sanctions applied11, in 2020. 

11 Sweden noted that due to outbreaks of animal diseases, it had limited resources to produce the data in the 

field of animal health. 

20 

 
 
 
                                                           
Table 7 – official controls – animal health - 2020 

21 

 
 
 
 
 
Commission controls of EU countries 

EU countries audited: 

Number of audits carried out: 

21 

Bulgaria: 5 – Czechia: 2 – Greece: 2 – Hungary 2 

Total number of recommendations raised: 

80 

Recommendations per audit area: 

In this area, the following controls are highlighted: 

African swine fever 

During 2019-2020, we carried out controls of affected EU countries and completed a series 
of fact-finding visits in some disease-free EU countries. These visits focused on their 
preparedness and response capacity for the disease if this affects wild boar.  

22 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The evidence gathered indicated that all EU countries were taking measures to prevent and 
prepare for a possible Spread of the disease into their territories. They were monitoring 
border areas properly in order to detect the disease promptly, but passive surveillance was 
weak in other parts of their territory. This constituted a weak point in case of geographical 
jump of the disease.  

The Commission identified good practices, which supported the update of the EU’s strategic 
paper on African swine fever. 

Highly pathogenic avian influenza 

We focused the controls on the EU countries most affected by the epidemics in 2016-17 
and in 2020, and issued recommendations to improve their preparedness and response 
capacity.  

The main shortcomings noted related to poor risk assessments for the entry of the disease, 
insufficient application of disease prevention and containment measures, and suboptimal 
epidemiological analysis to inform the rapid selection of the most suitable control 
measures.  

The detailed knowledge obtained from some of the audited EU countries helped the 
Commission to manage the application of the regionalisation policy during the 2021 
epidemic of the disease. 

Zoonoses 

The audits on Salmonella in poultry populations showed that the majority of EU countries 
are achieving their targets. The main shortcomings noted related to the low rate of 
detection of Salmonella in samples taken by farmers versus official sampling. This renders 
the farmers’ sampling contribution to the Salmonella national control plans practically 
ineffective. 

The evidence indicated that generally, vaccination programmes for eradicating rabies are 
properly implemented and the number of cases in animals have decreased.  

23 

 
 
 
 
Animal by-products 
Official controls carried out by EU countries 

Animal by-products (ABPs) are materials of animal origin that people do not consume. ABPs 
can spread animal diseases (e.g. Bovine Spongiform Encephalopathy - BSE) or chemical 
contaminants (e.g. dioxins) and can be dangerous to animal and human health if not 
properly disposed of. EU rules regulate the movement, processing and disposal of these. 

Table 8 provides an overview of the numbers of establishments, official controls carried 
out, non-compliance issues identified and administrative sanctions applied, in 2020, 
comparing the numbers between approved12 and registered establishments.  

Table 9 compares the numbers of non-compliance issues and administrative sanctions 
between two types of product non-compliance issue: 

labelling and traceability of ABPs and derived products; 

- 
-  safety of ABPs and derived products. 

Table 8 – official controls – ABPs - 2020 

12 These establishments process, handle or store ABPs and/or derived products (all establishments need to be 

at least registered with the authorities). 

24 

 
 
 
 
 
                                                           
Table 9 – product non-compliance – ABPs - 2020 

Non-compliance issues noted in the EU countries’ annual reports include:  

- 

the incorrect removal of ABPs, non-removal of ABPs and/or failure to hand over ABP 
to authorised persons; 
transport of ABPs which were not clearly identified; 

- 
-  poor hygiene in storage premises, failure to prevent entry of animals and vermin, 

state of cleanliness of containers, inappropriate storage of ABPs;  

-  unsubstantiated documents, incomplete completion of documents, missing 

- 

documents; 
the unauthorised placing on the market of ABPs, carrying out of unauthorised 
activities. 

Estonia plans to organise information days on topics such as procedures based on the 
HACCP principles, cross-contamination, traceability and labelling requirements, as the 
competent national authorities consider that Estonian start-ups do not have a good 
overview of the requirements of the ABP Regulation. 

25 

 
 
 
 
 
 
Commission audits of EU countries 

EU countries audited: 

Number of audits carried out: 

Total number of recommendations raised: 

Recommendations per audit area: 

8 

33 

In this area the following controls are highlighted: 

Hygiene, traceability and trade requirements of processed animal proteins.  

Audits on ABPs and derived products of mammalian origin cover EU countries’ controls 
on meat-producing establishments dealing with ruminants and pigs and ABP processing 
plants, where the risk of cross-contamination or misuse of ABPs derived from different 
species and the risk of fraudulent practices is the highest. In 2020, three audits were 
carried out; five audits are planned for 2021 and a further six in 2022. 

Processed animal proteins are authorised for use in certain types of animal feed, mainly 
for manufacturing compound feed for pets and farmed fish, and producing organic 
fertilisers or soil improvers. EU countries need to verify that products placed on the market 

26 

 
 
  
 
 
 
 
 
 
 
 
 
 
are safe and traceable, thus preventing the possible unauthorised use of materials 
containing processed animal protein in certain types of animal feed (‘feed ban’).  

In 2020, an overview report on how EU countries implemented official controls  on 
processed animal proteins13 collated the main findings of audits in eight EU countries, 
carried out in 2018 and 2019. The audits focused on processed animal proteins produced 
and traded between EU countries and imported into the EU, and the traceability and trade 
of organic fertilisers and soil improvers. We also considered the practical implementation of 
the requirements relating to channelling consignments of ruminant processed animal 
protein intended for export, following a relaxation of the feed ban rules in July 2017.  

The audits found that EU countries’ inspections of businesses and testing of processed 
animal proteins was working well overall, but that controls on cross-border traceability 
needed to improve. The main deficiencies identified included:  

  poor or limited implementation of official controls on channelling of consignments 

 

of ruminant processed animal proteins intended for export; and  
the failure of the competent authorities and businesses to systematically record 
information on the movements of processed animal proteins traded within the EU, 
thus undermining the EU-wide traceability of these consignments.  

Recommendations were made accordingly and the relevant EU countries took corrective action. 

13   Overview report on official controls on hygiene, traceability and trade requirements of processed animal 

proteins. 

27 

 
 
 
 
                                                           
 
Animal welfare 
Official controls carried out by EU countries 

Animal welfare on farm 

Table 10 provides an overview of the numbers of production sites, official controls carried 
out, sites with non-compliance issues and sanctions applied, in 2020, across the animal 
species listed. 

Table 10 – official controls – animal welfare on farms - 2020 

The EU countries generally did not provide a thorough analysis of the welfare of animals on 
farms. While some gave an indication of the main issues identified, there were generally no 
descriptions of action plans to improve the situation, although these are required by the EU 
rules14. 

Animal welfare during transport 

Table 11 provides an overview of the number of official controls carried out and 
administrative sanctions applied across the different animal species, in 2020. 

14 Articles 151, 152, 156, 157 and 158 of Regulation (EU) 2017/625 require an analysis of the most serious 

findings of non–compliance and a national action plan to prevent or decrease their occurrence. 

28 

 
 
 
 
                                                           
Table 11 – official controls – animal welfare during transport – 2020 

These official controls led to a number of administrative sanctions being applied. The 
graphs in Table 12 show the number of sanctions applied for the different species. The 
main issues were: 

 
 
 

for cattle and pigs, the fitness of animals; 
for poultry, transport practices;  
for the other species, problems with transport documentation. 

Belgium noted that foreign transporters are responsible for a significant proportion of the 
infringements identified, posing difficulties for enforcement. These infringements are sent 
to the national contact point of the relevant EU country.  

There are also no clear descriptions of action plans to address major deficiencies, despite 
the requirement for these15. 

15 Article 154 of Regulation (EU) 2017/625 requires an analysis of the major deficiencies detected and an 

action plan to address them. 

29 

 
 
 
                                                           
Table 12 – official controls – animal welfare during transport - 2020 
Administrative sanctions for different species relating to six areas 

Cattle 

Pigs 

Sheep & 
goats 

A: fitness of 
animals 
B: transport 
practices 
C: Means of 
transport 
D: water, feed, 
journey times 
E: documents 
F: other 

30 

 
 
 
 
 
Horses 
and 
donkeys 

Poultry 

Other 

A: fitness of 
animals 
B: transport 
practices 
C: Means of 
transport 
D: water, feed, 
journey times 
E: documents 
F: other 

Animal welfare at the time of killing 

The reports contain some information regarding animal welfare in slaughterhouses and 
during culling of animals for animal health reasons. 

Germany stated that, in its opinion, reporting on official controls on animal welfare at 
slaughter is optional and therefore unnecessary. Ireland also did not provide any 
information in this section. Greece noted that, due to resource problems, some regional 
services are lagging behind on animal welfare controls. Hungary indicated that it would 
submit the statistical data in another way, in accordance with regulations. 

31 

 
 
 
 
 
 
EU countries did not yet make full use of the ability to report these data through the new 
annual reporting of official controls (AROC) platform. 

Commission controls of EU countries 

EU countries audited: 

Number of audits carried out: 

Total number of recommendations raised: 

Recommendations per audit area: 

13 

France: 2 

57 

In this area the following controls are highlighted: 

Animal welfare on farm - pigs 

We completed a three-year project aimed at reducing the routine tail docking of piglets. As 
part of this project, we audited four EU countries and led visits to several EU countries by a 
team of experts with hands-on experience in rearing pigs with intact tails. The experts met 

32 

 
 
 
 
 
 
authorities and farmers and gave advice and recommendations for making progress in this 
area. We also assessed EU countries’ action plans to reduce tail docking. 

Animal welfare on farm - indicators  

Through our audits and analysis, we looked at the methodologies (including the use of 
indicators) in EU countries to demonstrate compliance with legal requirements and to 
assess the state of well-being of farm animals. With a few exceptions, official services do 
not use animal welfare indicators and the related methodologies are still being developed. 
Therefore, most EU countries cannot demonstrate the necessary level of compliance in their 
territories regarding animal welfare, due to the absence of specific objectives and/or the 
lack of suitable methodologies to monitor these. 

33 

 
 
 
Plant health 
Official controls carried out by EU countries 

The EU countries have to report on the official controls carried out on businesses 
authorised to issue plant passports16 and businesses authorised to apply the ISPM 15 
mark17 to wood packaging materials. 

Table 13 provides an overview of the number of businesses involved, official controls 
carried out, non-compliance issues identified and administrative sanctions applied, in 2020. 

Table 13 – official controls – plant health - 2020 

Germany noted that the introduction of the new EU regulations required a significant 
commitment in terms of human resources to re-register, update and educate 
establishments. The Netherlands and Poland reported fewer controls or less coverage, 
because this is a new area of controls. France stated these new regulations were the 
reason for the high number of non-compliance issues identified during official controls. 
Slovakia used the time that the COVID-19 pandemic restrictions were in place to develop 
materials and manuals for professional operators and inspectors. 

16 Plant passports are harmonised labels that must accompany all plants for planting during all business-to-

business movements within the EU, to ensure the absence of quarantine pests, compliance with regulated 
non-quarantine restrictions and traceability. 

17 A mark on wood packaging materials shows they have undergone treatment to remove or kill pests. 

34 

 
 
 
 
 
 
                                                           
Commission controls of EU countries 

EU countries audited: 

Number of audits performed: 

10 

Spain: 5 – Italy: 2 

Total number of recommendations raised: 

41 

Recommendations per audit area: 

In this area the following controls are highlighted: 

Controls on harmful pests and diseases  

Plant health is important for sustainable agriculture and horticultural production, food 
security and protection of the natural environment. We continued to conduct a wide range 
of audit and analysis activities in the field of plant health, in EU countries (and non-EU 
countries that export plants to the EU), to verify compliance with EU rules. 

35 

 
 
  
 
 
 
 
 
 
 
EUROPHYT-Outbreaks 

Rapid reporting by EU countries on new outbreaks of pests and diseases, and on their 
spread in the EU, is fundamental for assessing risk factors and better targeting EU 
countries’ control activities. We further developed the web-based module for outbreak 
notifications under the EUROPHYT system, with the adoption of a common protocol for 
notifications. This facilitates rapid reporting and supports the harmonisation of practices 
between EU countries. The introduction of mapping tools in the EUROPHYT-Outbreaks 
system now allows the extent and localisation of outbreaks to be visualised. This supports 
rapid decision making, providing increased protection against phytosanitary risks. 

Audits on outbreaks of pests in the EU 

The EU priority pest Xylella fastidiosa is a bacterial pathogen that has done serious damage 
to olive trees. We have regularly audited control measures in all EU countries that have had 
outbreaks of these bacteria since its first detection in Italy in 2013. The audit results and 
follow-up to these have contributed significantly to improving controls in these EU 
countries. We continued audit and follow-up activity in Italy and other EU countries to 
address this particular plant health risk. 

After the first EU outbreak of the tomato brown rugose fruit virus in Germany in 2018, nine 
further EU countries reported outbreaks of this virus in subsequent years. Its damaging 
effects could be of significant concern for plant health in the EU. The virus was mainly 
detected in tomato crops and greenhouses, but was also found in field crops and peppers. 
We audited the control measures taken in a number of the affected countries, to support 
eradication work across the EU. 

36 

 
 
 
 
Plant protection products 
Official controls carried out by EU countries 

Plant protection products (PPP) are subject to official controls at market level and during 
use. 

Marketing of PPP 

A range of businesses are active in the PPP distribution chain. Table 14 provides an 
overview of the number of operators, official controls carried out, non-compliance issues 
identified and administrative sanctions applied across the types of operators, in 2020. 

Table 14 – official controls – marketing of PPP - 2020 

A specific non-compliance issue at this stage is the storage of PPP that are no longer 
authorised to be used. 

37 

 
 
 
 
 
Use of PPP and sustainable use of pesticides 

Table 15 provides an overview of the number of operators, official controls carried out, 
non-compliance issues identified and administrative sanctions applied, in 2020, across the 
types of operators in relation to official controls carried out on the use of PPP and the 
sustainable use of pesticides. Other professional uses include use in forestry, around 
railways and roads, non-agricultural areas such as golf courses and other public areas, 
seed treatment operators and spray contractors and/or service providers.  

Table 15 – official controls – use of PPP - 2020 

Non-compliance issues identified related to use exceeding the authorised dosage of PPPs, 
the use of PPPs for purposes for which they have not been authorised or the use of 
unauthorised PPPs, the use of PPPs in breach of the conditions for protecting groundwater 
and not respecting the requirement for prior notification when using rodenticides. 

38 

Agricultural usersOther professional usersOtherAgricultural usersOther professional usersOtherOperators5 182 3991 909 6836 064Official controls64 45635 569625Non-compliances9 9837 157161Administrative sanctions7 4484 422159 
 
 
 
 
Commission controls of EU countries 

EU countries audited: 

Number of audits performed: 

Total number of recommendations raised: 

Recommendations per audit area: 

9 

49 

In this area the following controls are highlighted: 

The sustainable use of pesticides 

The broad range of measures set out in the Directive18 on the sustainable use of pesticides 
(SUD) provides the basis for reducing the risks and impacts of pesticide use on human 
health and the environment, in particular by promoting the use of integrated pest 
management (IPM) and alternatives to pesticides. 

SUD report 

We submitted the second report to the European Parliament and the Council on the 
experience gained by EU countries in implementing national targets set out in their national 
action plans (NAP) and on progress in implementing the sustainable use of pesticides19. The 

18 Directive 2009/128/EC. 

19  Report from the Commission to the European parliament and Council on the experience gained by Member 

States on the implementation of national targets established in their National Action Plans and on 
progress in the implementation of Directive 2009/128/EC on the sustainable use of pesticides 

39 

 
 
  
 
 
 
 
 
 
 
 
 
 
 
                                                           
report concluded that, despite widespread delays in revising NAPs, and the absence of high-
level, outcome-based targets in most of the revised NAPs, EU countries have made 
progress in implementing the SUD. The control of the implementation of IPM by farmers 
and growers continues to be the most widespread weakness in the application of the SUD 
in EU countries. This report was published alongside the Farm to Fork and Biodiversity 
strategies20 to underline the SUD’s political importance in achieving the pesticide reduction 
targets set out in these strategies. To this end, the Commission will propose a revision of 
the SUD, to reinforce the provisions on IPM, and promote the greater use of alternative 
ways to protect harvests from pests and diseases. 

Evaluation of the SUD  

We started an evaluation of the SUD and launched an impact assessment of its possible 
future revision, to be done in line with the Commission’s guidance on Better Regulation21. 

In May 2020, we published a combined evaluation roadmap and inception impact 
assessment for this initiative22. This document aims to inform people living in the EU and 
groups affected by this policy about this initiative and allow them to provide feedback and 
participate actively in future consultation activities. 

We organised a Better Training for Safer Food remote workshop with EU countries’ 
competent authorities on the topic: ‘Sustainable Use of Pesticides Directive (SUD) 
2009/128/EC - experiences on its current implementation and possible future policy 
options’. The workshop ran from 17-19 November 2020. Additional details concerning the 
event are available via the event website23. 

SUD implementation 

In 2019, we carried out seven audits to evaluate the implementation of measures to 
achieve the sustainable use of pesticides. The 2020 work plan contained six audits; we 
postponed five of these due to the COVID-19 pandemic. We carried out one audit remotely. 

We organised two series of Better Training for Safer Food courses. The first series focused 
on implementing IPM. These 14 courses started in 2018 and we extended the period over 
which these courses ran, to compensate for delays due to the COVID-19 pandemic. The 
second series, on pesticide application equipment, started in the third quarter of 2019. 
These six courses focus on inspection and calibration techniques. 

20 European Commission – Farm-to-fork Strategy and European Commission – Biodiversity Strategy 

21 European Commission - Better regulation: guidelines and toolbox 

22 Roadmap and results of this public consultation  

23 BTSF Workshop details 

40 

 
 
                                                           
Harmonised risk indicators 

In August 2020, we published updated EU harmonised risk indicators for pesticides for the 
2011-2018 period for the EU countries (which, at that stage, included the United Kingdom). 
These indicators are important because they show the trends in the risks associated with 
the use of pesticides.  

We also recently set ambitious targets to reduce the use and risk of chemical pesticides 
(based on Harmonised Risk Indicator 1), and the use of more hazardous pesticides by 50% 
by 2030, under the Commission’s farm to fork strategy.  

Harmonised Risk Indicator 1 (HRI 1), which measures the use and risk of pesticides, shows a 
decrease of 17% since the baseline period in 2011-2013, but no change compared to 
2017. Harmonised Risk Indicator 2 (HRI 2), based on the number of emergency 
authorisations, shows an increase of 56% since the baseline period in 2011-2013, and an 
8% increase compared to 2017. These results show that there is no room for complacency 
if the EU is to reduce the risks associated with pesticides. 

41 

 
 
 
 
Organic production and labelling 
of organic products 
Official controls carried out by EU countries 

For the 2019 reporting year, the Commission sent follow-up letters to 21 EU countries and 
2 European Free Trade Association (EFTA) countries, because their annual reports for that 
year lacked quality or accuracy on organic data or official organic control topics24.   

This allowed clarification on issues related to:  

● 

● 

● 

● 

a lack of compliance with the legal control requirements (number of annual 
inspections, additional risk-based and unannounced inspections carried out);  

a lack of information on the number and type of non-conformities detected and 
information on the relevant measures applied;  

a lack of information on the supervisory activities by the competent authority in 
relation to the organic control bodies (audits, number of files examined, witness/review 
audits, major findings and follow-up given to irregularities);  

a lack of information on actions taken by the competent authority to ensure 
compliance by the organic businesses and/or the effective operation of their official 
control services.  

The Commission’s assessment of the annual reports submitted for the 2020 reporting year 
is ongoing.  

EU countries may delegate to control bodies certain official control tasks and other official 
activities25. In most EU countries, private control bodies are active in certification and 
official controls of organic businesses. The competent authorities are required to supervise 
these bodies26.  

Under the rules on organic production, EU countries’ competent authorities for organic 
farming supervise the control bodies to whom they delegate official control tasks and 
report the results of this supervision activity to the Commission. The supervision audits 
include office assessments of the control procedures, witnessed audits, where the 

24 Annex XIIIc and XIIIb of Regulation (EC) 889/2008. 

25 Article 28 of Regulation (EU) 2017/625.   

26 Article 33(a) of Regulation (EU) 2017/625.   

42 

 
 
 
                                                           
competent authority observes the inspection carried out by inspectors from the control 
body, review audits, where the competent authority directly inspects organic businesses to 
verify compliance with the organic rules. The competent authorities impose measures 
where necessary, including the withdrawal of these bodies’ delegations. 

Commission controls of EU countries 

EU countries audited: 

Number of audits performed: 

Total number of recommendations raised: 

Recommendations per audit area: 

5 

54 

The recommendations in this area are not split into further topics. 

In its Farm to Fork strategy, the Commission set a target for organic farming at 25% of the 
EU’s agricultural area by 2030. In the last 10 years, there has been an increase of 63%, to 
currently 8.5% of the total utilised agricultural area27.  

Imports of organic agri-food products are also significant, reaching 3.2 million tonnes in 
201928.  

We continue to carry out an annual programme of audits of the control systems for organic 
products produced or imported into the EU.  

Private control bodies certify imports from most non-EU countries and audits of these 
bodies are an important part of the Commission audit programme in the organics sector, 
accounting for 12 of the 17 audits carried out in 2019-2020. The remaining five audits 
were in EU countries.  

A main difference between the two cases is that control bodies in non-EU countries may 
apply group certification if the group has an internal control system. This approach 
facilitates exports from small farmers in developing countries that cannot afford individual 
certification. Many of the non-compliance issues found in non-EU countries relate to issues 
with the implementation of this system.  

27  Organic farming statistics provided by Eurostat. 

28  EU Agricultural Markets Briefs No 13, March 2019: "Organic farming in the EU. A fast growing sector". 

43 

 
 
 
  
 
 
 
 
 
 
                                                           
The most frequent adverse findings identified in the audits in EU countries related to the 
supervision of control bodies, compliance with minimum control requirements from the 
control bodies, the notification to the competent authorities of non-compliance issues by 
businesses from the control bodies and the lack of enforcement of measures in cases of 
non-compliance issues. 

44 

 
 
 
Protected designation of origin, 
protected geographical indications 
and traditional specialities 
guaranteed 
Official controls carried out by EU countries 

EU geographical indications (GI) legally protect 3 231 registered names of products in order 
to promote their unique characteristics and protect the traditional expertise of their 
producers. More than 1 700 non-EU GIs names are protected in international agreements. 
Each GI has a specific standard on how the product is made, while also serving as a 
guarantee for the quality and authenticity of the product. 

In terms of economic performance, the estimated value of sales in the EU of GI products in 
2017 was EUR 74.76 billion, including the United Kingdom (EU28), accounting for 6.8% of 
the total food and drink sales (EUR 1 101 billion for the EU28). Wines make up 51% of this 
value, 35% is provided by agricultural products and foodstuffs, and drinks account for 
13%29. 

The average value premium rate for GI products in the EU28 was estimated in 2017 at 
2.07, indicating that the sales value of GI products was on average (weighted) 2.07 times 
higher than the sales value for comparable standard products without a GI label30. 

EU countries carry out official controls on businesses’ compliance with product 
specifications and the labelling of the products, at production and marketing level. 

In 2020, 26 EU countries submitted specific information on official controls and 
enforcement of GIs as part of their annual reports. In comparison to previous years, this is 
an increase in the number of reports received, while submission via the digital AROC 
platform considerably improved the transparency of the submitted information and data 
extraction.  

29  Study on economic value of EU quality schemes, geographical indications (GIs) and traditional specialities 

guaranteed (TSGs) 

30  Study on economic value of EU quality schemes, geographical indications (GIs) and traditional specialities 

guaranteed (TSGs) 

45 

 
 
 
                                                           
The national authorities identified various objectives for the official controls of GIs. Hungary 
noted that maintaining trust and protecting the interests of consumers was one of its 
objectives, and Czechia noted that ensuring the rights of the GI producers were guaranteed 
and respected was within their remit. 

Due to the COVID-19 pandemic, some EU countries reported difficulties in carrying out the 
planned number of official controls (e.g. France and Belgium). By contrast, the Italian 
central inspectorate for the protection of quality and fraud prevention of agri-food products 
(ICQRF) reported that it had carried out 215.9% of its planned control activities due to an 
intensification of controls in e-commerce, where a particularly high number of operations 
took place as a direct consequence of the epidemiological situation.  

National authorities applying the temporary measures31 in order to maintain the smooth 
functioning of the internal EU market and to ensure the free circulation of goods during the 
COVID-19 restrictions, had to closely monitor changes in the difficulties in carrying out 
official controls. Moreover, they were still required to apply a risk-based approach in 
carrying out their official controls. In this way, while relaxing certain obligations relating to 
official controls, the EU countries were able to ensure that producers relying on GIs did not 
need to de-certify their production during the pandemic.  

Based on the information submitted, the following observations have been made: 

●  Official controls on GI included pre-market checks and checks in the marketplace. In 
some countries (e.g. France) 90% of the checks were pre-market, whereas in , for 
example, Slovakia there were 67 pre-market checks in comparison to 1 122 checks in 
the conventional marketplace. 

●  Official controls in the market place are split into checks in the physical marketplace 
and checks on the internet. In addition to checks on individual businesses, some 
national authorities also addressed GI infringements on internet platforms. 

● 

Some countries (e.g. Estonia and Finland) indicated that e-commerce had not been 
separately audited or separately recorded in the control system. Some (e.g. Estonia) 
carried out combined checks - both in the physical marketplace and on the internet - 
on the same businesses. 

●  With the growing size and frequency of e-commerce operations, checks on internet 

sales play an increasingly important role in establishing GI infringements. The trend to 
increase the proportion of checks in e-commerce can be considered as positive. 

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

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

46 

 
 
                                                           
● 

● 

● 

● 

● 

● 

Some countries indicated a particularly high level of compliance (e.g. Greece 97.3 % 
and Belgium), while in others a higher non-compliance rate was detected (e.g. in 
France 10 % or Austria 31.4 % of non-compliance, found in 10.6 % of the businesses). 

The types of infringement included: non-compliance with the product specification, 
presence of substances not allowed or not declared, labelling not in accordance with 
the rules; and cases where non-GI products were labelled as GI. 

Some countries reported information on infringements per product or product category 
(e.g. Italy or Austria), while others reported per entire GI sector (e.g. Hungary - on 
wines). 

Enforcement actions administered included administrative and judicial actions. The 
relatively low rate of judicial actions (in comparison to the number of administrative 
actions) might indicate a relatively less serious level of infringements identified. 
Administrative actions included temporary closure of the businesses (e.g. in Hungary). 

Some EU countries with particularly high awareness of GI issues have reported a very 
high number of official controls for all types of checks (e.g. France carried out over 
43 000checks, and Italy carried out 132 251 checks). 

Very limited or almost no information was provided on the checks of GI that originated 
from non-EU countries but is protected in the EU either via direct application or on the 
basis of international agreements. 

Table 16 provides an overview of the number of businesses subject to official controls, the 
number of those with non-compliance issues, the number of official controls carried out, 
non-compliance issues raised and administrative sanctions applied, in 2020. 

47 

 
 
Table 16 – official controls – PDO/PGI/TSG/GI - 2020 

Commission controls of EU countries 

EU countries audited: 

Number of audits carried out: 

Total number of recommendations raised: 

Recommendations per audit area: 

5 

14 

The recommendations in this area are not split into further topics.  

In 2019-2020, we audited five EU countries on their control systems in this area. 

The audit teams found overall well-structured systems of official controls with designated 
competent authorities and well-trained staff in place. 

The main negative findings related to weak market controls of products from other EU 
countries and non-EU countries and the fact that these controls were not always based on 
an appropriate risk assessment. For their own products, the EU countries often failed to 
cover all of the elements of the product specifications when carrying out controls on 
producers. 

48 

 
 
 
  
 
 
 
 
 
 
 
Fraudulent and deceptive practices 
Official controls carried out by EU countries 

Fraudulent and deceptive practices are characterised by their intentional nature, aimed at 
achieving an economic gain, in violation of legal rules and at the expense of the immediate 
customer or the final consumer. 

There are different types of fraud in the agri-food chain: dilution, substitution, concealment, 
unapproved enhancement, counterfeit products, mislabelling and forgery. 

National official controls programmes 

Competent authorities are required to carry out official controls to identify possible 
intentional violations of the rules32, through fraudulent or deceptive practices, and taking 
into account information regarding such violations shared through the mechanisms of 
administrative assistance and any other information pointing to the possibility of such 
violations. 

EU countries reported on such official controls. Examples included official controls on: 

  honey; 
  olive oil;  
 
  e-commerce of food supplements; 
 

illicit wine production (obtained from water and sugar solutions);  

the sector of self-storage facilities, to ensure these are registered/approved for the 
activities offered; 

the falsification of veterinary certificates regarding animal health status;  

  an illegal slaughterhouse;  
 
  equine identification; and  
 
the trade of animals. 

Coordinated control programmes 

EU countries contributed to EU control programmes coordinated by the Commission. 

32 Regulation (EU) 2017/625 introduced new rules on fighting fraud in the entire agri-food chain. Article 9(2) 
requires EU countries to carry out official controls regularly, with appropriate frequencies determined on a 
risk basis, to identify possible intentional violations of the rules through fraudulent or deceptive practices. 

49 

 
 
 
                                                           
An initial programme called upon national authorities to increase their vigilance and adapt 
their control activities on online offers and advertising of food in relation to COVID-19, 
following the rise in sales of products claiming to prevent and/or cure the disease33.  

The programme asked the EU countries to: 

 

 

trace and identify websites, sellers and businesses with illegal practices in 
marketing food and food supplements linked with COVID-19 sold online in the EU; 
follow-up on non-compliances and suspicions of fraudulent practices that were 
identified; 

  strengthen the cooperation and administrative assistance between Member State 

 

authorities on the control of internet sales; 
inform consumers that products bearing COVID-19 infection-related health claims 
were illegal and might even be injurious to their health. 

A second coordinated control programme aimed to estimate the prevalence of some non-
compliances including fraudulent practices in the herbs and spices sector34. 21 EU countries, 
Switzerland and Norway actively participated. The goal was to protect consumers from 
misleading and potentially unsafe products. Samples of six different herbs and spices were 
analysed. Oregano was identified as the most vulnerable, with 48% of the samples at risk 
of adulteration. The Commission called on the businesses to take the necessary actions to 
enhance prevention against fraudulent practices and on the national authorities to increase 
their official controls in the sector and sanction those businesses committing fraud. 

Operations coordinated by Europol 

The EU countries participate in yearly operations coordinated by Europol: 

-  Operation Silver Axe V35, targeting the counterfeit and illicit trade of pesticides, led 

to the seizure of 1 346 tonnes of illegal pesticides. This quantity could be enough to 
spray 207 000 km2, or more than all the farmland in Germany which accounts for 
nearly half the country, almost 75 % of farmland in France or more than 150 % of 
the farmland of Romania36; 

-  Operation OPSON 202037, targeting the trafficking of counterfeit and substandard 

food and beverages, led to the dismantling of 19 organised crime groups involved in 
food fraud and the arrests of 406 suspects. The operation included more than 

33  More information on this coordinated control plan. 

34  More information on this coordinated control plan, including a question and answer section. 

35 Europol press release on Operation Silver Axe V.  

36 Estimation of the possible use rate of the found products, Surface of farmlands, Eurostat, 2016. 

37 Europol press release on OPSON 2020. 

50 

 
 
 
                                                           
26 000 checks. As a result, about 12 000 tonnes of illegal and potentially harmful 
products worth about €28 million were seized. With more than 5 000 tonnes seized, 
animal food was the most seized product, followed by alcoholic beverages (more 
than 2 000 tonnes), cereals, grains and derived products, coffee and tea and 
condiments. Large amounts of saffron were seized: 90 kg in Spain and 7 kg in 
Belgium with an estimated value of more than €306 000. 

Commission controls of EU countries 

Our work programme did not contain audits on official controls on fraudulent and deceptive 
practices in 2019 and 2020.  

In order to support and monitor the implementation by the EU countries of the new 
provisions in the Official Controls Regulation on controls on fraudulent and deceptive 
practices, we launched a project in 2019 including a desk study and two pilot fact-finding 
studies of two EU countries. In 2020, we carried out fact-finding studies on four additional 
EU countries, with two more planned for 2022. The information collected in 2019 and 2020 
shows that the EU countries already have some arrangements in place to deal with threats 
of fraud in the agri-food chain, but that official controls targeting fraud are not yet 
systematically in place across all control areas.  

We will produce a guidance document in 2022 based on the information collected in this 
project on challenges and examples of good practice. This will facilitate the consistent and 
effective application, by the national authorities, of the new provisions on fighting 
fraudulent and deceptive practices in the agri-food chain. 

51 

 
 
 
 
 
General legend 

EU countries (EU27) 

Belgium 

Greece 

Lithuania 

Portugal 

Bulgaria 

Spain 

Luxembourg 

Romania 

Czechia 

France 

Hungary 

Slovenia 

Denmark 

Croatia 

Malta 

Slovakia 

Germany 

Italy 

Netherlands 

Finland 

Estonia 

Cyprus 

Austria 

Sweden 

Ireland 

Latvia 

Poland 

52