Complying with Information Sheet 64

Quite a taks

The QA manager: “After acquiring 2 companies, we not only had an enormously large and much bigger range, but also niche products that the Dutch market is barely familiar with. This made it complicated to set up a proper monitoring plan and GIRA (hazard analysis). On top of that came the Information Sheet 64 legislation, which meant the NVWA were extra strict in their checks. We knew we needed help to manage all of this properly.” 

The products the organisation imports come mainly from Asia, where different laws and regulations apply than in the Netherlands. This called for a specialist approach — something Eurofins Food Safety Solutions, with its worldwide network of laboratories, was perfectly suited for. Moreover, the company had already had a positive experience with Eurofins in earlier collaborations. 

The start: defining unique product groups 

Imke Otten-Leenders, Food Quality Consultant at Eurofins Food Safety Solutions: “We started by setting up a complete monitoring plan that complied with the latest laws and regulations. This was no easy task given the enormous range and the unique product groups. But by working together and communicating well, we still managed to map out all the product groups properly.” 

Categorising 3,600 products 

A complex next step: categorising the 3,600 products into the right categories. “Many of our products don't fit into the usual Western product groups,” explains the QA manager. “Think for example of fermented jellyfish, fermented duck eggs, or dried plants such as dried lily bulbs. Or, for instance, banana leaves that were used to steam products, so not intended for consumption. How do you categorise those products, what do you test for, and which limit applies then? To comply with Information Sheet 64, we had to translate these niche products into which mainstream products they would correspond to. It was crucial to make the right risk assessment and use the right tests. Fortunately, Imke has a lot of knowledge and expertise in this area.” 

Tea and seeds, or dye? 

Otten-Leenders: “We wanted to test ‘tea’ in the lab, for example. But when we looked at the product specifications, the ‘tea’ turned out to consist of dried vegetable leaves and almonds. No legal limit applies to that, and in the Netherlands we wouldn't call that tea. ‘Seeds’ that we wanted to analyse also turned out not to be intended for consumption as seeds, but used as a dye. Consumers therefore don't eat them. How do you then handle an exceedance? Those were interesting cases.” 

An ongoing process

“Every aspect of the process was taken over by Eurofins Food Safety Solutions: from setting up the monitoring plan, to sampling, transport to the laboratory, and interpretation of the results,” says the QESH/QHS employee at the importer. “The lab results are also checked directly against the legislation. That way we quickly know whether we meet all requirements. The monitoring plan also helps us determine which products need extra attention and what we need to watch out for. It's an ongoing process that has to be continuously updated, for example when new products are added or legislation changes.” 

Lessons Learned

The project also delivered a lot for the organisation. “It was an intensive process, especially given the time pressure of the NVWA inspection. We had to move quickly, it was also a learning experience to take a critical look at our supplier base and streamline the range. Sometimes we bought the same product from multiple suppliers. That could be handled more efficiently. That way we also optimised our processes and the risk analysis.” 

Cultural differences and different consumption habits 

In addition, monitoring products from Asia proved to be a challenge, partly due to cultural differences and different consumption habits. “We discovered it's crucial to work closely with experts who know the laws and regulations of both the importing and exporting countries,” says the QESH/QHS employee. “It wasn't just about complying with Dutch legislation, but also about understanding the differences in product use and the associated risks. It really makes a difference whether dried leaves are eaten or used for steaming, for example. We researched carefully for which purposes our products are used in Asian cuisine.” 

6 tips from the QA-experts:

1. Bring in help in good time.

 “If you're dealing with a complex product range or a lot of changes in legislation, consider external help. That can save you a lot of time and gives you an extra safety net for questions about changing legislation. Eurofins has taken a huge amount off our hands.”

2. Be critical of your range. 

 “Regularly look at your product groups and suppliers. Sometimes processes can be organised more efficiently by grouping products or rationalising suppliers.”

3. Look at the main ingredient and the risk of a composite product. 

“This has helped us save costs. You can't test every ingredient of a composite product.”

4. Stay flexible. 

Legislation is constantly changing. Make sure your monitoring plan is a living document that moves along with those changes.

5. Knowledge of importing countries.

“Products from other cultures often require a different approach. It's essential to have good knowledge of the product, the way it is consumed, and both the Dutch and foreign regulations.”

6. Reporting to the NVWA adds value. 

“We've had to report exceedances on our products fairly regularly. It turned out the NVWA actually appreciated that. They saw it as a sign that we're careful and on the right track.”

“During the NVWA's most recent visit, they indicated they're very positive about the steps we've taken. Our proactive way of reporting exceedances and the way our monitoring plan is structured were assessed favourably. That makes us feel reassured!”