Food Law News - EU - 2002

FSA Letter, 2 May 2002

BSE - Collagen Imports

Draft Commission decision laying down conditions for intra-community trade and imports from third countries of collagen and raw materials intended for the production of collagen

The European Commission has recently issued a draft Decision to lay down conditions for intra-Community trade (i.e. between Member States) and imports from third countries of collagen and raw materials intended for the production of collagen for human consumption and for use in cosmetics, pharmaceuticals and medical devices.

This will be discussed at the next public health meeting of the Standing Veterinary Committee (SVC) scheduled for late May 2002. The purpose of this consultation is to canvas interested parties for initial views on the proposals set out in this draft.

Background

Commission Decision 1999/724/EC setting out the conditions for intra-Community trade and imports from third countries of raw materials and gelatine for human consumption was adopted on 28 October 1999 and came into force on 1 June 2000. It followed the opinion of the EU Scientific Steering Committee on the safety of gelatine as regards BSE infectivity and associated geographical risk.

In May 2001 the EU Scientific Steering Committee published a report and opinion on the safety with respect to TSE risks of collagen produced from ruminant hides. This was followed by the current draft Decision setting out the conditions for intra-Community trade and imports from third countries of collagen and raw materials intended for the production of collagen for human consumption and use in cosmetics, pharmaceuticals and medical devices. This proposal is very similar to the gelatine Decision and frequently cross-refers to it. The proposal was discussed, in its current form, at the SVC working group on BSE on 11 April 2002.

The UK made a number of initial points to the Commission at the SVC working group on BSE. These included:

• the Decision should not cover medical devices or pharmaceuticals, these were not covered by the similar gelatine proposal;
• the heating of collagen is inappropriate as it is thermally unstable;
• a moisture content of 15% is not achievable, 18% would be more realistic; and
• potassium sorbate should be added to the list of approved preservatives, in line with the provisions of Directive 95/2 (Miscellaneous Additives).

The Commission undertook to give further consideration to the issues raised at the meeting.

Request for information

The Agency would like views from interested parties on the requirements set out in the current proposal and the effect it will have on the collagen industry in the UK and on consumers. In particular, we would like to know:

• the effect of the proposal on collagen manufacturers;
• the effect of the proposal on collection centres and tanneries;
• the effect on importers/ other suppliers of raw materials;
• if collagen has food uses other than the production of sausage casings and what these other uses are; and
• if the proposal provides enhanced protection for consumers.