Milk labeling news: the Ministry of industry and trade proposes to approve the terms before the end of the pilot experiment
IMPORTANT
Recently, the Ministry of industry and trade published on the portal of normative legal acts a draft document on ‘rules for labeling dairy products by means of identification and features of implementing the state information system for monitoring the circulation of goods subject to mandatory labeling by means of identification’.
According to the document, dairy enterprises do the registration in the state information monitoring system within 7 calendar days from the date when it becomes necessary for a participant in the circulation of dairy products to carry out activities related to the introduction into circulation, and (or) retail sale of labeled dairy products.
In addition, within 30 calendar days from the date of registration in the monitoring information system, market participants ensure that their own software and hardware are ready for information interaction with the monitoring information system and send an application to the operator of the monitoring information system to pass information interaction testing.
After registration in the monitoring information system, enterprises send an application to the system operator for remote access to the emission registration device located in the infrastructure of the monitoring information system in electronic form.
The draft document requires enterprises to test the information interaction between its own hardware and software and information monitoring system in accordance with the procedure published on the official website of the operator of information monitoring system in information and telecommunications network "Internet", in relation to the operations related to the marking of dairy products, the introduction of dairy products into circulation, circulation and withdrawal from the circulation necessary for the participant of circulation of dairy products, in accordance with the approved rules, no later than 60 calendar days from the date of readiness of own hardware and software for information interaction with the monitoring information system.
WHAT WE LABEL AND WHEN
For milk and cream, non-condensed and without adding sugar or other sweetening substances (code for the unified Commodity nomenclature of foreign economic activity of the Eurasian economic Union 0401, OKVED codes 10.51.11, 10.51.12), with a shelf life of 28 days, as well as ice cream and other types of food ice that do not contain or contain cocoa (commodity nomenclature code 2105 00, code for the classifier 10.52.10): participants in the circulation of dairy products that enter into the circulation of specified dairy products, apply identification means to dairy products and submit information to the “Honest mark " system on the application of identification means and introduction into circulation of the specified dairy products in accordance with the Rules approved by this resolution, since January 20, 2021, submit information to the information monitoring system on the circulation and withdrawal from circulation of the specified dairy products
since October 1, 2021;
the participants of circulation of dairy products, engaged in wholesale in the specified dairy products, and participants of circulation of dairy products, engaged in the retail sale of specified dairy products, submit information on the circulation and the withdrawal from circulation of the specified milk products in the information system monitoring since October 1, 20.
For milk and cream, non-condensed and without the addition of sugar or other sweetening substances (commodity nomenclature code 0401, classification codes 10.51.11, 10.51.12, 10.51.21, 10.51.22), with a shelf life of up to 28 days, milk and cream, condensed or non-condensed with the addition of sugar or other sweetening substances (commodity nomenclature code 0402, classification code 10.51.51), whey, condensed or non-condensed, with the addition of or without adding sugar or other sweeteners, products made from natural milk components, with or without the addition of sugar or other sweetening substances, not elsewhere named or included (commodity nomenclature code 0404, classifier codes 10.51.55, 10.51.56), butter and other fats and oils made from milk, dairy pastes (commodity nomenclature code 0405, classifier code 10.51.30), cheeses and cottage cheese (commodity nomenclature code 0406, classifier code 10.51.40), soft drinks, containing fat obtained from products of commodity items 0401-0404 (commodity nomenclature codes 2202 99 910 0, 2202 99 950 0, 2202 99 990 0, code for the classifier 10.51.56):
the participants of circulation of the dairy products apply identification means on specified dairy products and submit information on application of identification means and entry of specified dairy products into circulation into information monitoring system since July 1, 2021, submit information on the circulation and the withdrawal from circulation of the specified dairy products into the information monitoring system since October 1, 2021.
In addition, the participants of the circulation of dairy products, engaged in wholesale in the specified dairy products, and participants of the circulation of dairy products, engaged in the retail sale of specified dairy products, submit information on the circulation and the withdrawal from circulation of the specified milk products in the information monitoring system since October 1, 2021.
For buttermilk, curdled milk and cream, yogurt, kefir and other fermented or curdled milk and cream, condensed or non-condensed, with or without the addition of sugar or other sweetening substances, with or without flavoring additives, with or without the addition of fruit, nuts or cocoa (commodity nomenclature code 0403, classifier code 10.51.52): enterprises apply identification means to the specified dairy products and submit information on the application of identification means, entry into circulation, circulation and withdrawal from circulation of the specified dairy products into the information monitoring system, since October 1, 2021.
In addition, for peasant farm holdings that independently carry out retail sales of their own dairy products, there is a delay until October 1, 2022.
The complete rules can be found here.
OPINIONS
According to Ivan Gorlenko, Director of LLC Spectr, the introduction of labeling of finished dairy products will worsen the drop in demand for it - the costs will lead to an increase in prices on the shelves, which in turn will adversely affect demand.
- The problems with labeling of dairy products are obvious, it is by and large not necessary for anyone, except those who will benefit from it. I think that the question of demand is relevant here - this will not warm up consumption, but will only worsen the drop in demand. It is clear that there will be costs, there will be an increase in the price on the shelf. The price increase is a decrease in demand, - said Ivan Gorlenko.
The expert advises to treat the introduction itself "like a change in the weather" - there is nothing you can do about it, and all participants in the industry will have to work in the same conditions.
Meanwhile, the National Union of milk producers (Soyuzmoloko) considers it premature to set a time frame for the introduction of mandatory labeling of dairy products before the end of the experiment, scheduled for the end of 2020.
- According to the draft government decree published for public discussion, some products should start being labeled in four months, which will not allow to ensure the readiness of not only manufacturers, but also suppliers of equipment and packaging, as well as retailers and importers of products. In total, the industry has more than 2.5 thousand medium-sized and large enterprises for the production of dairy products and several thousand small organizations that cannot be included in the system in less than six months, - said Artem Belov, General Director of Soyuzmoloko.
The expert reminded that at the moment the pilot project on labeling of finished dairy products has been extended until December 31, 2020, and it is in an active phase of implementation. By September 1, participants plan to sum up the first results of testing, the second stage of the interim summing up is scheduled for October 31, 2020. The overall results with a real estimate of the time and cost of implementation will be summed up only on January 10, 2021.
- The proposed timing of the introduction of labeling without analyzing the results of the experiment in general seems optimistic. The current draft with new implementation dates have not been discussed with the participants and Soyuzmoloko yet, and in our opinion, needs to be refined according to the results of experiment and actual tests, - said Artyom Belov.
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