From food regulation to chemicals registration

Christopher Booker (with, no doubt, the help of RAE North) tells us all about the EU food inspection system.

What Mr Paterson recognised from the start, unlike any other politician in Britain, was that the root of the problem lay in what had followed when, a decade ago, the EU took over all “competence” to make food law from national governments. It promptly introduced a new set of rules across Europe, to replace the old dependence on regular inspection and testing of foodstuffs with a radical new system. The EU’s version of what is known as HACCP (Hazard Analysis and Critical Control Points) is based on a trail of paper, whereby any food product, as it passes along the chain from one firm to another, must be acccompanied by a piece of paper certifying its nature and contents.

This system, set up under EU regulation 178/2002, was to be administered by a new European Food Safety Authority, represented in each country by “independent” national food safety agencies, such as that created in Britain in 2002. But the regulation also laid down that ultimate responsibility for the reliability of food sold to the public was placed on the “food operators” at every step along the chain, culminating in those retailers who sell food to the public,

Mr Paterson became aware years ago, when he was on the relevant Commons committee, that this new system was wide open to fraud. Everyone along the chain was expected under the rules to trust the paperwork passed on to them. But it only needed one firm to insert false information into the paper trail and the reliability of the system would collapse (as we have seen when horse meat correctly labelled on leaving a Romanian slaughterhouse was mis-labelled as beef after being exported to western Europe).

Entirely typical for bureaucrats of course. If the paper work\’s right then so is the real world, isn\’t it?

And they\’ve built the same system for chemicals regulation as well. REACH works on exactly the same system. As the producer/consumer of any specific \”chemical\” (which ranges from iron, good old plain Fe, all the way through to the most exotic creation of the pharmaceuticals industry) you should be REACH registered. This costs, depepnding on the size of the firm being registered, from thousands to tens of thousands of euros. But note, not for each company. For each \”chemical\”. And it really is quite, quite absurd.

I shall have to register for iron for example. Something I might produce in quantities of 20, 30 tonnes a year. Entirely as a by-product of producing something else. It\’s a waste. A waste worth perhaps $200 a tonne. A waste which obviously I send off to the scrap merchant (hell, it\’s iron, it\’s scrap metal). But this entirely trivial disposal of a by-product needs to be registered with a bureaucracy in Helsinki.

Do note that the registration fee, those thousands or tens of thousands, isn\’t actually to prove the safety of anything. No, no, that\’s an entirely different process, over and above this one. The fee is just to get the bureaucrats to read the documents stating that you\’ve registered.

Now, you don\’t actually have to register: neither as a producer nor a consumer. But one of the two must be registered. Any transaction taking place must have one participant registered. I have a little shell company registered on a number of products (but not Fe, not as yet) specifically to do this.

But here\’s the thing. Having set up this vastly expensive (recall, every producer/consumer, or at least one of the two, has to do this for every chemical. It isn\’t that Fe has been registered once and that\’s it. Every producer/consumer of Fe must register at that same fee, subject only to one of the two being registered for any transaction. There will thus be hundreds of thousands of registrations for each chemical) then that\’s it. We\’ve a paperwork chain. But that\’s all we\’ve got, a paperwork chain.

What we\’ve not actually got is a system of checking that what\’s on the paperwok is what\’s actually on the back of the lorry. Say, Fe with less than the permissible amount of lead in it. This will still have to be checked by the scrappie or consumer. Just as it already is and was before the invention of the paperwork chain.

That is, we\’ve a paperwork chain and nothing else: just what the EU\’s \”sole competence\” on food safety managed to achieve.

They\’re fuckwits aren\’t they?

5 thoughts on “From food regulation to chemicals registration”

  1. It depends what you think the EU is trying to achieve. If you think that they are genuinely trying to make things safer for consumers then, yes, they’re fuckwits.

    If, on the other hand, you think that the EU is trying to guarantee itself a direct income through taxing trade, then they’re actually doing pretty well.


  2. Something about your Fe problem’s not immediately apararent. Your scrappy, who’s taking your Fe stream is both a consumer of ‘chemicals’ & a producer. That’s what a scrap dealer does, isn’t it? Accumulated material from diverse sources & sells bulk to consumers. As Fe’s about the biggest line he handles & a high proportion of his sources would have no reason to be registered – I’m not going to register as a ‘chemical supplier’ to dump a car at the breakers- why isn’t the scrappy registered? If he is, what makes you different from me scrapping a banger? Why can’t you ride on his registration, if only one party needs to be?

  3. That is an accurate picture if what passes for public administration now in the UK, and probably most of the West. What matters is the piece of paper, not reality. Reality will not prevent you from punishment if the paperwork is incorrect. For example in my line of business operators of various machine need tickets that ‘prove’ they are competent to operate them. If they have an accident and they have a ticket I am fine. Insurance pays up etc. If on the other hand they don’t have a ticket and never have an accident, but someone finds out, I’m for the high jump. Competence is no defence for lack of a piece of paper.

    The whole system is f*cked and its no wonder we are in the economic hole we are.

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