2011-01

Dairy Industry Notice 2011—01

Issued February 2011

Key items in Dairy Industry Notice 2011—01 are:

1. Changes to Importing Country requirements:
1.1 Certificates for European Union
1.2 Product testing requirements for Sri Lanka
1.3 New Certificate for Taiwan
1.4 New requirements exporting non–prescribed goods to China
2. Importing Country Reviews
2.1 Russia
2.1 Indonesia
2.2 European Union
2.3 El Salvador
3 Changes to EXDOC (Submitting RFPs)
3.1 Mandatory Batch numbers required on all RFPs and manual export permits
4. Clarification of EU requirements relating to receival and use of milk and milk products (action item from DEICC)
5. Amendments to the AQIS Dairy Website including Dairy Export Program Operations Manual (DEPOM) and Known Importing Country Requirements
6. Public Holiday Arrangements and Contact Details

1. Changes to Importing Country requirements:

Items included in this section are mandatory items that will be enforced by AQIS. Items included in the Dairy Industry Advice are provided for information only.

1.1 Certificates for European Union

As advised in Dairy Industry Notice 2010—04, The Commission Regulation (EU) No 605/2010 required the issue of new certification for milk and milk products exported to the European Union from 30 November 2010. These certificates have now been developed and are available in EXDOC. The new certificates remove references to EC Directive 92/46 and now reference EC Regulations 178/2002, 852/2004, 853/2004 and 854/2004 and reduce the number of certificates available from 3 to 1.

1.2 Product testing requirements for Sri Lanka

Sri Lanka revised its standard for milk powders and the revised standard took effect from 2 February 2009. The standards includes compositional requirements, including ‘Polenske value’ that indicates whether milk fat in milk powder has been substituted with vegetable fat.  

Australian milk powders have never been associated with fraudulent practices such as substituting milk fat with vegetable fat. The testing methodology for Polenske value and the range nominated in the revised standard may cause problems for certain milk powders. In 2009, Sri Lanka advised that they were considering modifying relevant provisions of the revised standard, however, the revised standard is not yet available (December 2010). AQIS can provide a copy of the standard on request.

Butter, milk powder and margarine may require NATA test results in order to enter Sri Lanka. Testing for Salmonella may be required for milk powder, where Salmonella should be absent in 500g. These test results are not required to be endorsed by AQIS. It is in the exporter's interest to find out from the Sri Lankan importing authorities whether NATA test results are needed.

1.3 New Certificate for Taiwan

The default certificate for Taiwan has been amended to the ZD035T (instead of the ZD035). The change was put in place to ensure that the certificates printed with BVSc beside the signature block.

1.4 New requirements exporting non–prescribed goods to China

Recently, a number of exporters have attempted to export colostrum products, goat and sheep cheese products and other dairy products made from non–bovine milk to China. The Chinese authorities have confirmed with AQIS the import requirements for non–bovine dairy products and colostrum products are the same as for bovine dairy products, ie they are required to be manufactured in an AQIS registered establishment and will need to obtain full export certification to ensure entry into China

The certificate requirements for non–bovine dairy products are as below:

For products such as non–bovine (goat, sheep) cheeses, powders etc

Use AQIS health certificate template ZDCN02 (Chinese health certificate for products other than infant formula). Products will have to come from an AQIS export registered establishments with the relevant Approved Arrangement in place and certification must be obtained through the EXDOC system.

For infant formula containing non bovine dairy components

Use AQIS Health Certificate for Infant Formula version ZDCN01 (Chinese health certificate for infant formula). As for infant formula with bovine dairy components, this product will have to be tested for Enterobacter sakazakii at a NATA lab and results presented to AQIS before a certificate can be issued.

 

Further details on the approved arrangement and registration requirements can be obtained by contacting the Dairy Export Program

2. Importing Country Reviews

2.1 Russia

Following the inspection by Russian inspectors between 18 and 22 October 2010, 3 dairy establishments (and 3 meat establishments) were temporarily suspended from exporting to Russia. The temporary suspension was effective from the 20th December 2010. AQIS’ ER/EXDOC has been modified to ensure that no export certificates for Russia are issued to these establishments after 20 December

The Russian authorities have advised that they want AQIS to:

• ensure that the 3 affected establishments have addressed non– compliances identified by Russian auditors
• audit all dairy establishments (currently listed by Russian authorities for export of dairy products to Russia) against the current Russian requirements; and
• based on those audit findings, by 1 March 2011, provide guarantees that all the listed establishments meet all relevant Russian requirements.

Currently, 16 establishments are listed by Russian authorities to export dairy products to Russia (1 x Tasmania, 1 x NSW, 1 x QLD and 13 x  Victoria). AQIS was aware that only some of those 16 establishments exported to Russia in the last 12 months and as such sought confirmation from all 16 establishments that they wish to maintain their listing. All establishments have indicated that they wish to continue with their Russian listing.

2.1 Indonesia

The audit of Australia’s export dairy system by Indonesian authorities (Directorate General Livestock Services — DGLS) was conducted in October 2010 and included visits to processing establishments and a farm in New South Wales and Victoria, and a meeting with Dairy Food Safety Victoria. At the exit meeting, DGLS auditors indicated that they were generally satisfied with the Australian Dairy System, however they did identify a range of system issues and hygiene and processing non–compliances at processing establishments.

The Indonesian Directorate General of Animal Husbandry and Animal Health Services (previously Directorate General of Livestock Services) has advised the Australian Government that, following a recent audit of the Australian dairy food safety system, all Australian factories currently exporting dairy products to Indonesia are approved as eligible to export to Indonesia and will be put on their approved list. This means that the requirements for factory inspection and provision of information in a questionnaire required under Law 18 will not be necessary for existing Australian dairy export establishments. Factories not currently exporting to Indonesia requiring registration should contact AQIS to arrange registration prior to export.

If you are experiencing difficulties with customs clearance or require further information on the agreement, please contact Phill Goode at Dairy Australia (telephone: 03 9694 3817) or contact AQIS (telephone: 02 6272 3933).

2.2 European Union

The European Commission’s Food and Veterinary Office (FVO) audited Australia’s export dairy system in September 2010. FVO provided a draft report on 27 October 2010. AQIS, SRAs and industry worked on developing Australia’s response comprising of comments on the draft report and actions proposed to address FVO’s recommendations.

Australia’s response was submitted to FVO on 1 December. FVO assessed the response and advised that 4 out of 5 proposed actions were unsatisfactory. AQIS will work with industry and State Regulatory Authorities on developing a response and providing it to FVO by mid February 2011.

2.3 El Salvador

Indications are that El Salvador is likely to be the next importing country review of Australia, possibly in February/March 2011. El Salvador will conduct a listing review as opposed to a systems review.

All costs for the El Salvador visit will have to be borne by the participating establishments. Eight establishments that are currently interested in being inspected and listed by El Salvador. With that number of establishments and a contribution by Dairy Australia, at this stage AQIS anticipates that the cost will be approximately $3000 to $4000 per establishment. AQIS sought confirmation and agreement from participating companies/establishments that:

a) the costs, per establishment as outlined above, are agreed to and will be paid by the company in full; and

b) a finalised list with full details of the establishments to be inspected (including establishment addresses) can be provided to El Salvador.

If any of the eight establishments interested in the listing establishments have not confirmed the above, they should contact AQIS .

3. Changes to EXDOC (Submitting RFPs)

3.1 Mandatory Batch numbers required on all RFPs and manual export permits

The Export Control (Milk and Milk Product) Orders 2005 set out the requirements for Dairy Products to be traceable. Schedule 8 of the Orders sets out the requirements for Milk and Milk products to be traceable back to the supplier of the Milk and Milk products and ingredients.

Why are traceability systems required?

• Meet the requirements of Australian legislation, specifically the Export Control (Milk and Milk Products) Orders 2005 (subclause 1.1 of Schedule 8);
• Allow registered establishments to meet importing country requirements; and
• Provide assurances that the milk and milk products have been handled appropriately to maintain food safety and traceability in order to be eligible for export.

What is traceability?

Traceability can be defined as the ability to identify the origin of food inputs, through all stages of production, processing and distribution. The basic characteristics of traceability systems are:

• Identification of units/batches of all inputs (Product traceability information)
• Lot identification of processed product (Production records and lot or batch labelling)
• Information on when and where they are moved and/or transformed (Documentation e.g. Transfer Certificate and Declarations of Compliance)
• A system linking this data (Approved Arrangement which reconciles product to documentation)

Who is required to have traceability systems in place?

All registered establishments involved in the preparation of Milk and Milk products must have a system for tracing, identifying and, if necessary, recalling product at the Establishment (subclause 1.1 of Schedule 8).

The entire traceability system is intended to cover export the chain from where product is sourced from through to when it is exported from Australia.

Changes to EXDOC business rules and traceability information

The requirement for traceability systems also extends to those that are responsible for raising export documentation. Registered establishments, exporters and those responsible for raising export documentation (Approved Export Permit Issuers) should be aware of their roles and responsibilities in implementing and managing effective traceability systems.

AQIS have undertaken a review of the current information in EXDOC and are seeking to strengthen traceability through our export certification systems in line with legislative and importing country requirements. This will enhance the ability of businesses to trace goods from the finished product back to the origin therefore supporting the capacity to conduct a recall if necessary.

In order to achieve this, the business rules in EXDOC will be changed to include the requirement to enter a batch code for traceability purposes. Establishments will be responsible for ensuring that staff that are involved in the export documentation process are aware of the new requirements for batch code information, this will include but is not limited to RFP validators (Approved Export Permit Issuers), agents, exporters and other staff involved in issuing export documentation such as transfer certificates.

4. Clarification of EU requirements relating to receival and use of milk and milk products (action item from DEICC)

The European Union operational requirements are detailed in Annex III, Section IX of Regulation (EC) No 853/2004. Guidelines for Australian establishments are provided in the Dairy Export Program Operations Manual including information sheets I5.2.1 Understanding European Union (EU) Import Requirements for Management of Somatic Cell Counts and I14.1 Understanding Requirements for Sourcing of Raw Milk. General requirements accepted by European Union are provided in the Export Control (Milk and Milk Products) Orders 2005 in Schedule 5 Parts 1 & 2 and supported by requirements of the Food Standards Code, Standard 4.2.4, the Primary Production and Processing Standard for Dairy.

All edible milk and milk products must be made using raw milk compliant with European Union somatic cell requirements, total plate count, temperature controls and use of antibiotics.

The following summarises the mandatory requirements to demonstrate compliance with EU requirements.

• Raw milk for the production of heat–treated milk and milk products must have:
• • somatic cell counts ≤400,000/mL as determined by rolling geometric average over a period of 3 months with at least one sample per month per farm; and
  • Plate count at 30°C ≤100,000/mL, as determined by rolling geometric average over a period of 2 months with at least 2 samples per month.
  • Each farm supplying milk to the establishment is required to meet the above requirements. See Dairy Export Program Operations Manual I5.2.1 Understanding Requirements for Sourcing of Raw Milk and the Countdown Downunder website for further details.

• In relation to temperature controls, immediately after milking, milk must be cooled to not more than 8°C in the case of daily collection, or not more than 6°C if collection is not daily. During transport, the cold chain must be maintained and, on arrival at the establishment of destination, the temperature of the milk must not be more than 10°C. When raw milk fails to comply, the food business operator must inform the competent authority (State Regulatory Authority) and take measures to correct the situation.
• • Note: compliance with the Milk Cooling Project principles are accepted by the EC for the purpose of these requirements.

• In relation to antibiotics in milk, establishments must have procedures to ensure that:
• • (a) raw milk does not contain antibiotic residues in a quantity that, in respect of any one of the substances referred to in Annexes I and III to Regulation (EEC) No 2377/90, or
  • (b) exceeds the levels authorised under that Regulation; or
  • (c) the combined total of residues of antibiotic substances does not exceed any maximum permitted value.
  • When raw milk fails to comply with the above, the establishment must inform the competent authority (SRA) and take measures to correct the situation.

• If a company is sourcing milk or milk products to be used in processing products for shipment to the European Union, then the milk and milk products must be sourced from an establishment that is EU registered and can demonstrate compliance with the above EU requirements.
• • Generally an annual statement from the supplier company, attesting to compliance with the individual EU elements (EU listed, AQIS registration number, Somatic Cells, Standard Plate Count, Antibiotics, temperature controls and product testing) will satisfy compliance.
  • As part of their Approved Supplier Program, companies may choose different means of verifying this information (compliance audits, independent testing etc)
  • Whatever the method of verification, companies must be in a position to substantiate the declaration that the goods being exported meet the full requirements of the Milk and Milk product Orders 2005 and are eligible for export to the European Union (including the above parameters)

5. Amendments to the AQIS Dairy Website including Dairy Export Program Operations Manual (DEPOM) and Known Importing Country Requirements

The AQIS Dairy Website has been amended to include a link to requirements for return of Australian dairy product to Australia.

The following amendments have been made to DEPOM:

To reflect current practices and minor errors

• DEPOM Introduction
• A2.1 Dairy Export Program Website
• A2.1.1 WI Webpage Approval
• A2.1.2 WI Notification of Website Updates
• A4.3 Suspension or Revocation of Approved Arrangements
• A8.2 Verification of SRA activities
• A8.2.1 WI Verification of of SRAs
• A11.2 Sanctions
• A13.1 Document Control
• A13.2 Records Management
• B1 AQIS SRA Dairy Schedule
• B2.3 Management of Animal Food
• B2.3.1 WI Auditing Management of Animal Food
• B8 Independent Official Sampling Program

To amend DEPOM to reflect changes to responsibilities within AQIS

• A6.5 Expanded Application of the Milk Orders
• A8.3 Establishment and Consignment Verification
• A8.3.2 WI Loadout Inspection
• A11.3 Prohibited Goods List
• A11.3.1 WI Prohibited Goods List
• D4.3 WI Prohibited Goods List

To provide new procedures, information sheets and forms to address identified gaps in DEPOM

• A2.1.3 WI Website Queries
• A5 Alternative Regulatory Arrangements
• A6.1.1 WI Adding new DC codes
• A7 Export from Unregistered Establishments
• A10.1 WI Returned Australian Goods
• I1.2 Communication with AQIS
• I4 Information Sheet — Export from an Unregistered Establishment
• I7.1 Information Sheet — Exemptions
• I17.1 Information Sheet — Requirements for Pest Control

DEP007 Form — Applications to export from an unregistered establishment register

DEP209 Form — Product to be Entered onto the Prohibited Goods Table (completed by auditors)

DEP210 Form — Entry Into Prohibited Goods Table Dairy Program

DEP211 Form — Product included in the Prohibited Goods List in EXDOC — (advice to establishments)

6. Public Holiday Arrangements and Contact Details

AQIS has made some structural changes to consolidate service delivery arrangements. The following reflects the new communication arrangements.

Contacting AQIS regarding new or changes to export registered establishments

All form EX26s are to be sent to the Registration Coordinator in the AQIS regional office in your state. The addresses are:

Victoria	PO Box 1006, Tullamarine, VIC 3043
NSW	PO Box 657, Mascot NSW 1460
Queensland	PO Box 222, Hamilton QLD 4007
Far North Queensland	Attention Brad McCullough PO Box 96 Cairns International Airport QLD 4870
Tasmania	PO Box 1006, TullamarineVIC 3043
South Australia	PO Box 63 Export Park SA 5960
Western Australia	PO Box 606, Welshpool WA 6105
Northern Territory	Attention Michael Greenhalgh PO Box 37846 Winnellie NT 0821

Contacting AQIS regarding dairy export documentation

Fax 03 8308 5005
Email

Contacting AQIS regarding dairy program issues — Food Export Branch — Commodity Management — Dairy:

Fax 03 8308 5055
Email Queries

In addition to issues regarding milk and milk products, the Dairy Export Program is to be contacted when determining certification requirements for:

• milk products of non bovine origin (eg goat or sheep milk cheeses) where an export certificate is required;
• milk products which are not generally covered by the Export Control (Milk and Milk Products) Orders 2005 (eg ice cream): and
• milk products of a minor component dairy (eg powder blends with a minor component of milk powder).
• Milk products exported to New Zealand where an export certificate is required
• Milk products in a small consignment (10L/10kg or less) where an export certificate is required.
• milk products not listed in clause 13(b) of the Export Control (Milk and Milk Products) Orders 2005 where an export certificate is required
• colostrum where an export certificate is required

Audit reports for dairy export registered establishments and sample forms & results for the Independent Product Sampling Survey are to be provided to dairy@aqis.gov.au.

Public Holidays

AQIS Offices will be closed on the following dates:

14th March Labour Day
22nd and 25th April (Easter)
26th April ANZAC Day

Please ensure that all milk and milk products to be exported during the above public holidays are covered by export permits issued during office hours prior to the date of departure and, where health certificates must be issued, on or prior to the date of departure and that these are also obtained during office hours on or prior to the date of departure.