How to produce goods “made in Ukraine” the European way, and why is it needed?

In the past, many Ukrainian companies did not care much about organization of production processes ensuring that the end product is safe. Now, they have to change very thoroughly, because today, consumers want to buy safe products only.

Today, running a business in Ukraine the same way as yesterday is simply impossible — that’s how transformations occurring after Ukraine took the course toward integration with the European Union may be described. Exporters were the first to start implementing new safety and quality requirements, for they were first to chart the course toward Europe.

“The Europeans are prepared to consume only safe products, which only few Ukrainian companies could offer. Therefore, Ukrainian businesses exporting their goods had to revamp their production processes for compliance with European standards long before they became mandatory in Ukraine”, Vladyslav Faleiev, an expert in international trade and the founder of PBDS consulting company says.

After signing the Association Agreement, Ukraine began changing its requirements to producers working for the domestic market and the system of controlling compliance with these requirements. New requirements were designed to make Ukrainian products safer and of better quality.

Obligatory HACCP for food producers

Legislative changes passed in Ukraine back in 2014 obliged all food producers (except primary producers) to implement a modern HACCP system.

The purpose of this system is to identify and continuously control all factors that could affect the quality of end products.

The State Service for Food Safety and Consumer Protection, established in 2014 as a new agency responsible for controlling compliance with food safety legislation, maintains that food control existed in Ukraine even before that, but it wasn’t risk-oriented and did not envisage HACCP control. There were only sanitary and hygienic requirements to food production.

In the past, there were more specific requirements to organization of production process, the State Service for Food Safety and Consumer Protection explains. For example, walls had to be tiled. The today’s requirement is quite different: walls must be easily washable. In other words, the company is given a choice of how the safety of production process must be ensured.

The Zero Hour will strike in September 2019, when all food producing companies, including small businesses but excluding primary producers, would have to be compliant with international standards (medium-sized and large companies are already required to implement HACCP). After that, all companies will be subjected to systematic checks. If a company fails to implement HACCP by the required deadline or doesn’t want to do it, it would be fined for 111 thousand hryvnias (30 times the minimum salary amount).

Is it difficult to make production safe as required by international standards?

There are two orders of the Ministry of Agricultural Policy that Ukrainian food producers should take note of in view of the new rules. The first one is an instruction of sorts, telling how to implement a HACCP system. The second order is a list of 70 questions an inspector of the State Service for Food Safety and Consumer Protection may ask an entrepreneur when checking his company’s HACCP system.

Many questions are formulated in general terms. For example, an inspector may ask whether your premises are properly ventilated, or whether your business has procedures of controlling materials during food processing. But also, there are more specific questions, for example, whether your windows have anti-insect screens.

At first glance, it all seems rocket science. But Ukrainian entrepreneurs who have already implemented HACCP in their production say that all requirements are adequate.

Still, reorganization of production processes might take at least several months.

A lot depends on the current organization of production. “Some companies would have almost no changes and outlays when implementing HACCP, while others would incur huge costs”, Vladyslav Faleiev says.

The expert explains the new approach using tomato juice as an example. Safety control begins with checking tomatoes brought by a supplier. Say, a supplier must bring raw food in right containers. The receptacle in which tomatoes are dumped cannot be in the open air, for tomatoes may be exposed to rain. If the reception facility is outdoors, it would have to be roofed.

“Then, we’ll take a look at the water used to wash tomatoes before they reach the conveyor belt. A producer must make analysis of this water. Water must be compliant with requirements to drinking water, and reverse osmosis filters must be in place”, Vladyslav Faleiev continues.

Safety requirements also include: personnel must have clean hands and wear special clothes and caps, the procedure of leaving the workplace must be regulated, personnel cannot work overtime, and lamps in production facilities must have closed encasing.

As part of HACCP implementation process, a company must prepare numerous instructions for personnel on what to do in particular situations, the State Service for Food Safety and Consumer Protection explains. For example, when production line stops, in the event of a power outage, or when an items falls off the conveyor belt. The instructions must clearly describe how an employee should act in these situations.

Some companies would have to change production technology.

For instance, farmers growing fruits and vegetables would have to use the right varieties and hybrids. A product must have “sellable” appearance, and it must stay on the shelf for as long as necessary. Only the plant protection products filed in a special register can be used.

The State Service for Food Safety and Consumer Protection recommends producers themselves contact the agency and request an audit of their safety system. This way, the Service would be able to help companies find deficiencies in production safety and advise how to fix them. Voluntarily audited companies would not be fined. Fines would be charged for deficiencies discovered during scheduled inspections (111 thousand hryvnias, or 30 times the minimum salary amount).

New technical regulations, new standards and new control for manufacturers of non-food products

In Ukraine, there is a list of products (and in the past, it included almost all items) requiring a government-issued certificate to manufacture. There is also a list of several tens of thousands of state standards (GOSTs).

“The GOSTs clearly described the entire manufacturing process for every product. They even included requirements to the product’s manufacturing equipment”, Taras Tarasevych, Head of Commercial Department at Remos (Yaka and Claire de Nature trademarks), a company exporting cosmetic products to Poland, says. “The government had clear guidelines as to what ingredients a particular product must contain and in what quantities. A finished product would then go for examination and certification. And every six months, a product would have to be taken for analysis again”.

The European system is different from Ukrainian, Taras Tarasevych continues. The EU does not regulate the product’s content, but at the same time, a number of ingredients are prohibited.

There is no obligatory product certification. The important thing is for a product to be compliant with technical regulations that set out safety requirements. Then goes consumer control.

What is changing in Ukraine? The list of products requiring obligatory certification is gradually shrinking, and it must be abolished altogether by the end of 2018. At the same time, companies would have to be compliant with technical regulations that are gradually being harmonized with European regulations.

The procedure of controlling the product’s conformity with these requirements is also changing and, in fact, becoming simpler. Manufacturers would no longer have to receive a pile of papers from public authorities, but they will bear responsibility for conformity with technical regulations. And the random government control takes place when a product hits the store shelves.

“There still will be many requirements to manufacturers”, Vladyslav Faleiev says. “But they’d have to change, for business with developed countries cannot be done any other way. The most important thing is for entrepreneurs to want and be ready to do it”.

By Iryna Gudz

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