Is EVC really scary?
At the end of June this year, the Ministry of justice registered the orders 249 No. 51475, 250 No. 51476 and 251 No. 51477 of 28.06.2018 of the Ministry of agriculture of the Russian Federation, excluding ready dairy products from the action of EVC. However, at the end of July by the decree of the President of the Russian Federation the term of obligatory registration of veterinary accompanying documents in electronic form for controlled goods, for which veterinary accompanying documents were not issued until July 1, 2018, was postponed to July 1, 2019. Thus, there was a certain dissonance that has not been resolved to this day.
The orders of the Ministry of agriculture are about dairy products made from pasteurized, UHT, high-temperature processed milk in consumer packaging.
In addition, so-called composite products are derived from the veterinary certification system. This applies to processed products containing less than 50% of animal products, under the condition that such products have been thermally processed entirely until the natural properties of the raw product have been completely changed, products containing less than 50% (by weight) of pasteurized whole milk, skim milk, other raw milk and not containing other animal products, as well as products containing less than 50% of fish or crustaceans, shellfish or other aquatic invertebrates dried, salted, in brine and smoked.
The Rosselkhoznadzor assured that dairy products, despite the fact that they are excluded from the list of obligatory EVC, can be registered in the “Mercury” system. To date, mandatory veterinary certificates in electronic form are issued only for raw milk.
In general, enterprises and experts note that the system has not been finalized. But if finalized, it might be of interest to ensure market transparency. There are no results and the issue of improving the regulatory framework of the system. As reported in one of the latest materials of the Rosselkhoznadzor: "nothing happened in this area in September (the processes are going on, but there is still no result – interdepartmental coordination of 4 Orders of the Ministry of agriculture continues -changes in the rules of certification and changes in the three lists – for "state veterinary", authorized and certified). The situation is similar in the regulatory framework for the identification and registration of animals: the process is underway, but there is no result yet".
OPINIONS
Marina Petrova, Deputy Chairman of the Committee of Moscow Chamber of Commerce and industry on entrepreneurship development in agriculture and General Director of “Petrova 5 Consulting”
- The system "Mercury" today works in terms of accounting of raw milk, but after the postponement of the introduction testing on the chain “Farm-Processor-Network operator” stopped. The dairy industry today needs to clarify the position of the state in relation to the introduction of traceability system of finished products "from field to counter". A clear state position will help to understand the reality and the planned timing of the introduction of EVC for finished products and will encourage enterprises, which have ceased to take seriously the statements of regulatory authorities due to the recent transfers, to the real action.
Arkady Ponomarev, member of the Agrarian Committee of the State Duma
- The idea of increasing the transparency of the market is correct and vital. But its implementation can be wrong.
If the certification system is not technically developed, it brings confusion and becomes a brake. Therefore, first it is necessary to try it in the market of raw materials, clean up all the mistakes and inconsistencies. And only then use it on the market of finished products.
The representative of the major dairy enterprise of the Central Federal district
– In terms of readiness for the introduction of EVC for finished dairy products, we have done a lot of work, so we do not expect big changes in this aspect. There are, of course, some difficulties, but the last two or three years we went in the appropriate direction, so the question "to work or not to work" in the EVC system doesn’t arise. Business clearly needs transparency. Market participants should organize traceability, but under the supervision of the structure, which now oversees this process, on the enterprises have to meet increased requirements, unrealistic conditions are set for execution, there are a number of factors that are not quite convenient for the manufacturer. Therefore, it would be possible to simplify the issues of transparency and create conditions that are equally beneficial for the state and the manufacturer.
Dmitry Pinchukov, Chairman of the group of companies "Galaktika"
- By now the dairy market has come closer to the introduction of electronic certification for finished dairy products. At that time, it was clear that the implementation of the project is costly to market participants: it is necessary to attract additional staff, buy equipment. It is no longer possible to shift additional costs on the shoulders of consumers; the purchasing power is not growing. In addition, at the time of the previous launch, it was clear that the system was not fully ready, there were problems with the software and many retail outlets were not ready. Is there any confidence that all these problems have been solved now? In addition, was an alternative system of traceability using QR codes announced? What is its future? The manufacturers will surely not survive two systems. As for the fight against falsification, the EVC system for finished dairy products will not be an effective tool to combat falsification. A lot of time and effort will be spent, but still there are ways and those willing to get around it. Current versions of inspections by Rospotrebnadzor, Roskoshestvo and other organizations of finished products on the shelves are not worse, but easier and cheaper.
Irina Napora, Deputy General Director of the dairy plant LLC "Novator" (Republic of Crimea)
- There are a lot of questions to the system, we wrote questions to the creators of EVC, but didn’t receive any answers. I'm afraid that no one has understood yet how EVC will work in the case of finished dairy products.
If you work with your farms - it's easy, but working with households of population is difficult and we take this burden for ourselves, as our company is interested in raw milk.
Milk is a product that is transformed in the production process. On the market there is a large amount of butter and cheese, which are not really butter and cheese. If the system works, it will be clear that it is impossible to make from a certain amount of milk a certain amount of cheese. The idea of EVC is good, but it is implemented with huge technical difficulties. We ship our products 24 hours a day and since July 1 we have introduced a system of night operators, in addition we do not have enough veterinarians who could work seven days a week.
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