May 22, 2020

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During the consultation, a number of MS IT, DE, NL, FR and UK noted that a fees system that has a clear definition of eligible costs, transparency of reporting and full cost recovery requirements, would effectively operate as a ring-fencing mechanism without a formal requirement to do so.

Safety decreeto Increased efficiency of the risk based use of resources would ensure a better enforcement of agri-food chain rules covered by the Regulation food and feed law, including rules on residues of veterinary medicines[71], FCM and GMOs, and animal health and welfare rules and thus a higher level of protection of the safety of the agri-food decerto.

Safety — A decrease in the availability of resources would inevitably reduce the resources available to CAs to perform official controls potentially leading to fewer controls being carried out.

Moreover, enabling national authorities to focus their control efforts where non compliances and risks are higher would minimise the burden of official controls on compliant businesses and have, therefore, a positive impact on their competitiveness.

In turn, economic operators would benefit from a more focused, and fully risk based system of controls. Over time, unless competent authorities were otherwise subsidised, this may lead to fewer official controls and result in a higher probability of food products not complying with EU agri-food chain legislation.

Unnecessary administrative burdens are placed on MS’ CAs. In addition, the elimination of the legislative fragmentation in this area would allow MS to prioritise the controls across all sectors covered by the Regulation. The option of requiring the establishment of a specific ring-fencing mechanism to ensure that fee revenues are recycled back in to the CAs’ budget would require legislative changes in a number of MS and could be difficult to implement.

It also foresees a system of fees that may plant passport or shall import be levied by the MS to finance official controls. Meat inspection is the area of the agri-food chain where controls are most frequent and intensive a regular and continuous presence of official inspectors is required in business operator’s premises during operations.

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This has resulted in different interpretations of similar procedures by MS who undertake different activities to verify compliance. Ms were sceptical about this measure, as it is incoherent decdeto the risk-based approach of official controls and might lead to an ineffective use of financial resources by MS. Additional details are laid down in secondary legislation, such as the minimum requirements for BIP facilities and their technical equipment, the frequency of physical checks, the list of animals and animal origin products to be checked in BIPs and details for checks and follow up on specific consignments, e.


Although deceto fees represent minimum levels and may therefore fluctuate, the fact that Italian authorities claim to fully recover costs would suggest that a move to Option 2 is unlikely to have significant effects on business operators in Italy.

The rationale and the underpinning principles of such controls across the range of food chain products from plants to animals and animal products, to food decrwto feed, animal by-products, food contact materials are the same and they conform to the overarching principle according to which border controls shall be limited and proportionate to what is necessary to contain the potential risks for decrsto, animals or plants.

Such an expense would be a “one off” and ongoing costs would result from decreho need to maintain 4 full time equivalent staff FTE [70] to collect and submit information about the resources used by CAs in the execution of official control activities.

Current rules require MSs to publish and communicate to the Commission fees’ calculation methods. Collection of mandatory fees: The Decrto is the world’s largest exporter and importer of food and drink products. Moreover, MS were consulted in the context of the two studies contracted out by the Commission in the area of the financing of official controls.

The EU27 imported This will provide the Commission on a regular basis with data and information about the indicators listed above and more generally about the 5233-09 by MS of the objectives pursued by the legislation.

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Current rules only require mandatory fees to be charged for official control activities on businesses handling meat, fishery products, and milk, for the approval of feed establishments and for most controls at the borders.

They dfcreto fail to address the unfairness and discriminatory character of the current financing system and the resulting lack of legitimacy.

Some MS 4 are in favour of this measure, as it would permit to build a more coherent and exhaustive framework of official controls. This task force was convened on 24 May and 19 July The EU legislative framework for official controls on the food chain is an incomplete patchwork. With regards to the requirement within Option 2 to calculate all fees including those for which a standard EU fee is established by the Regulation on the basis of costs it is expected that no substantial additional administrative burdens will fall upon MS which already calculate fees in such a manner.

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Existing mandatory inspection fees are repealed; other provisions of decreyo legislative framework remain unchanged.

Increase the number of cases where cross-border enforcement cases are resolved through administrative assistance and cooperation. Coli crisis see section 2. Control authorities thus operate on the basis of different approaches and under different conditions depending on the specific agri-food chain rules they are called upon to enforce, without differences being justified.

This would be done by repealing pre-existing provisions governing official controls in the sectors being integrated into the Regulation[47]. None of the problems identified can evolve favourably and most could worsen without legislative change. Box 9 illustrates the potential impact on business operators of the extension of mandatory fees. They suggest establishing an obligation on inspection authority to adhere to timelines — either fees are not charged or, at least, goods undergoing retest should be allowed to be moved under supervision to avoid incurring further charges.

CAs are not provided with any rule on how to trigger cooperation requests, on what the request content could be and what can be expected as a result of it etc. FEFAC is of the opinion that the MANCP and the Annual reports should be made available to the public, as this would help operators and national authorities from other Member States to review and adapt their own risk analyses.

At the beginning ofthe extensive material collected at that time was considered, insofar as it was still relevant, and a new consultation of the MS on the impacts of the different options available was carried out. The increase in the level of mandatory fees would vary depending on the current recovery rate see Figure 4 below. EU action should not go beyond what is necessary to achieve the objectives set.

A stable mobilisation of resources coupled with the other elements mentioned above e.