Not milk
Tomorrow, the EEC Council will discuss the initiative of the Ministry of Finance to introduce into the technical regulation "On the safety of food products" (TR CU 021/2011) definitions that define milk-containing products and products with milk fat substitution by vegetable fat at 50 percent or more. The initiative is positive, but it does not solve the key problem, say market participants. Some participants evaluate it negatively.
As it follows from the appeal of the Ministry of Finance to the Chairman of the EEC Board Tigran Sarkisyan, the Ministry has prepared a draft EEC order approving the identification of a group of products of mixed composition produced with the use of milk and milk fat substitutes, the mass fraction of which in the fat part is 50% or more. According to the authorities, this “will ensure that the consumer is not misled when buying dairy products”.
"In this regard, I believe it necessary to consider the development and adoption of these changes in the framework of the reduced procedure without public discussion, without the preparation of the conclusion on Regulatory impact assessment and outside the plan for the development of technical regulations of Eurasian economic community", says the letter signed by the Head of the Ministry of Finance.
It should be noted that currently the technical regulations of the CU "On the safety of milk and dairy products" and "On the safety of food products" do not set requirements for products containing more than 50% of milk fat substitutes in the fat proportion in the composition. All these circumstances, according to the Ministry of Finance require a soon rapid response.
Among the definitions proposed by the draft order of the EEC there are the heat-treated fermented milk substitute, cheese substitute, sour cream substitute, condensed milk substitute, etc.
As the Director of the Russian Dairy Research Center Mikhail Mishchenko emphasized in his comment to The DairyNews, the initiative of the Ministry of Finance is correct, but does not solve the basic problem.
"I would not like to assess the procedural aspects in making this decision: the format of the adoption of these changes without public hearings. In fact, I can say the following: the desire of the government to clarify the definition of dairy products and what is called a dairy product, but it is not in fact, is commendable. And the fact that products containing more than 50% of vegetable fat will be called substitutes is correct", stressed the expert.
"We are talking about the threshold values of the use of milk fat substitutes. They require much more complex research and control. It is very difficult to divide products into milk-containing and milk substitutes with current thresholds. It turns out that if you have a product with 49% of milk fat substitutes, it is a milk-containing product, and if it contains 50% it is a substitute. In my opinion, products with any percentage of milk fat replacement are a substitute. Leave dairy and dairy compound ingredients in the technical regulations. It has been done all over the world. In order to be honest and correct, changes must be made to the foundation - all products with the replacement with vegetable fat must be transferred to the technical regulation "On the safety of food products". If the state takes the second step, as I mentioned, it will be a very serious breakthrough for the market!"- summed up Mikhail Mishchenko.
The question of the conceptual apparatus of technical regulations arises not for the first time. Today, many market participants call the terminology of technical regulation 033/2013"On the safety of milk and dairy products" to be complicated. So the changes in TR 033 that entered into force on 16 July this year, on the one hand, solve the problem of identification of dairy compound and milk-containing products, believe market experts: a quantitative criterion for assessing the content of non-milk components has been set: a product in which the mass fraction of milk solids in the finished product is not less than 20 % should be called a milk-containing product. But on the other hand, now the names will become much more inconvinient. And less clear to the consumer ("milk-containing product with a substitute for milk fat produced by the technology of cottage cheese/sour cream/cheese"), said a number of analysts.
According to one of the market participants interviewed by The DairyNews, in terms of awareness of the buyer, the changes in technical regulations are out of line: on a small piece of packaging we are trying to fit so much information even based on the requirements of existing documents that it becomes impossible to read it. It would be better not to change the rules in technical regulations but increase the responsibility of the manufacturer for any errors and discrepancies in the information on the label to inner content, - said the representative of the city dairy plant "Magadanskiy" Arkady Konovalov in an interview with the Agency.
It is not necessary to exclude milk-containing products from the technical regulations: products with vegetable fats in the composition have also the right to exist. The opinion about the dangers of palm oil is nothing but a delusion and fiction, believes the expert.
He calls a significant increase of fines for manufacturers of falsification and for violators of technical regulations of the CU an effective measure.
Chairman of the Board of Directors of the dairy plant "Uzlovsky" Vasily Velichkovsky supports the idea of a complete withdrawal of products with analogues and substitutes for milk fat from the dairy technical regulations, with a proviso: Only in this case it is necessary to decide what kind of VAT will be imposed on the product. Products with milk fat substitutes are bought by consumers with a low income, for those changes in price are important, said Velichkovsky.
Meanwhile, Rosstat notes the growth of real disposable income of the population - a little more than 1% within the seven months of 2018. Milk consumption depends significantly on the level of income of buyers, say milk producers. The world experience shows that the regulatory document for the industry should include only dairy products; this will be most easily perceived by the buyer.
It is worth reminding that the initiative of the Ministry of economic development for the separation of milk and products from milk fat substitutes this year is also being discussed in terms of the separation of shelves for these products on store shelves. It is assumed that the proposal can be implemented in 2019.
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