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________________________________________________________________________
Rue Belliard 35, B-1040 Brussels, tel: (+32)(0)2 286 18 11, fax: (+32)(0)2 286 18 00, www.eftasurv.int
Final report
EFTA Surveillance Authority mission to
NORWAY
19 to 29 May 2008
regarding the application of EEA legislation related to
identification and registration of bovine animals, labelling of beef and beef products,
identification and registration of ovine and caprine animals, and related to
veterinary and zootechnical checks applicable in intra-Community trade in certain
live animals and products
Comments to the draft report are referred to in the report in underlined italic. The
Comments to the draft report and information on the corrective actions already taken and
planned by the Norwegian competent authority are also included in Annex 5 (except for
the enclosures referred to in the comments).
Brussels, 22 October 2008
Case No: 63916
Event No: 491040
Page 2
Table of contents
1 INTRODUCTION ................................................................................................................................. 4
2 SCOPE AND OBJECTIVE OF THE MISSION ................................................................................ 5
3 LEGAL BASIS FOR THE MISSION ................................................................................................. 6
4 MAIN FINDINGS ................................................................................................................................. 6
4.1 NATIONAL LEGISLATION ................................................................................................................ 6 4.2 COMPETENT AUTHORITIES .............................................................................................................. 7
4.2.1 General information ............................................................................................................. 7 4.2.2 Training of staff ................................................................................................................... 8 4.2.3 Harmonisation of official control ......................................................................................... 8 4.2.4 Enforcement of legislation ................................................................................................... 9
4.3 IDENTIFICATION AND REGISTRATION OF BOVINE ANIMALS ........................................................... 10 4.4 IDENTIFICATION AND REGISTRATION OF OVINE AND CAPRINE ANIMALS ....................................... 11 4.5 NATIONAL COMPUTERISED DATABASES ....................................................................................... 12 4.6 LABELLING OF BEEF AND BEEF PRODUCTS .................................................................................... 13 4.7 OFFICIAL CONTROL RELATED TO IDENTIFICATION OF BOVINE, OVINE AND CAPRINE ANIMALS ..... 13 4.8 OFFICIAL CONTROL RELATED TO LABELLING OF BEEF AND BEEF PRODUCTS ................................ 16 4.9 OFFICIAL CONTROL RELATED TO TRADE IN LIVE ANIMALS ........................................................... 17 4.10 PRODUCER OF EARTAGS VISITED .................................................................................................. 18 4.11 FARMS VISITED ............................................................................................................................. 18 4.12 AUCTION MARKETS VISITED ......................................................................................................... 20 4.13 SLAUGHTERHOUSES AND CUTTING PLANTS VISITED ..................................................................... 20 4.14 DAIRY INDUSTRY’S CONSULTANCY SERVICES VISITED ................................................................. 21 4.15 RETAILERS VISITED ...................................................................................................................... 21
5 FINAL MEETING .............................................................................................................................. 22
6 CONCLUSIONS ................................................................................................................................. 22
6.1 LEGISLATION ................................................................................................................................ 22 6.1.1 Commission Regulation EC (No) 509/1999 ...................................................................... 22 6.1.2 Commission Decision 2001/672/EC .................................................................................. 23 6.1.3 Commission Regulation (EC) No 2006/968 ...................................................................... 23
6.2 APPLICATION OF LEGISLATION RELATED TO IDENTIFICATION AND REGISTRATION OF BOVINE
ANIMALS AND LABELLING OF BEEF AND BEEF PRODUCTS ............................................................. 23 6.2.1 Eartags................................................................................................................................ 23 6.2.2 Holding registers ................................................................................................................ 23 6.2.3 Holding registers ................................................................................................................ 23 6.2.4 Controls of holdings ........................................................................................................... 23 6.2.5 Controls on holdings .......................................................................................................... 23 6.2.6 Passports ............................................................................................................................ 24 6.2.7 Passports ............................................................................................................................ 24 6.2.8 Labelling of beef products ................................................................................................. 24 6.2.9 Sanctions ............................................................................................................................ 24
6.3 APPLICATION OF LEGISLATION RELATED TO IDENTIFICATION AND REGISTRATION OF OVINE AND
CAPRINE ANIMALS ........................................................................................................................ 24 6.3.1 Registration of movements of ovine and caprine animals .................................................. 24 6.3.2 Holding registers ................................................................................................................ 24 6.3.3 Holding registers ................................................................................................................ 24 6.3.4 Checks of holdings ............................................................................................................. 24
6.4 APPLICATION OF LEGISLATION RELATED TO VETERINARY CHECKS RELATED TO TRADE IN LIVE
ANIMALS ...................................................................................................................................... 25 6.4.1 Quarantine and isolation .................................................................................................... 25
7 RECOMMENDATIONS TO THE NORWEGIAN COMPETENT AUTHORITY ..................... 25
Page 3
ANNEX 1 LIST OF ABBREVIATIONS AND TERMS USED IN THE REPORT ........................... 26
ANNEX 2 RELEVANT LEGISLATION ............................................................................................... 27
1 ACTS RELATED TO IDENTIFICATION AND REGISTRATION OF
BOVINE ANIMALS AND REGARDING THE LABELLING OF BEEF AND
BEEF PRODUCTS: .................................................................................................... 27
2 ACTS RELATED TO IDENTIFICATION AND REGISTRATION OF
OVINE AND CAPRINE ANIMALS:........................................................................ 28
3 ACTS RELATED TO VETERINARY AND ZOOTECHNICAL CHECKS
APPLICABLE IN INTRA-COMMUNITY TRADE IN CERTAIN LIVE
ANIMALS AND PRODUCTS: .................................................................................. 29
ANNEX 3 INFORMATION ON PRODUCTION AND TRADE ........................................................ 31
ANNEX 4 OFFICIAL CONTROL RELATED TO IDENTIFICATION OF BOVINE, OVINE
AND CAPRINE ANIMALS .................................................................................................. 33
ANNEX 5 COMMENTS TO THE DRAFT REPORT AND INFORMATION ON THE
CORRECTIVE ACTIONS ALREADY TAKEN AND PLANNED BY THE
NORWEGIAN COMPETENT AUTHORITY .................................................................... 35
Page 4
1 Introduction
The mission took place in Norway from 19 to 30 May 2008. The mission team comprised
two inspectors from the EFTA Surveillance Authority (the Authority).
The opening meeting was held with representatives of the Ministry of Agriculture and
Food, the Ministry of Health and Care Services and the Norwegian Food Safety Authority
(NFSA) on 19 May. At the meeting, the Norwegian competent authorities added
information to their reply to the Authority’s pre-mission questionnaire. This was the third
mission to Norway where identification of cattle and labelling of animal products were
part of the scope of the mission. However, this was the first mission only focusing on
identification and labelling, and the first mission on identification of ovine and caprine
animals and related veterinary checks applicable in intra-Community trade in live animals.
In agreement with the NFSA, and following information received and observations made
during the first days of the mission, some changes were made to the mission programme.
One additional grocery store was visited during the first week. During the second week
two other farms were visited than those proposed in the programme. In addition, an
additional meeting was held with representatives of one district office in order to have a
demonstration of registrations made in the central database and one meeting was also
organised with the dairy industry’s consultancy services. Consequently, a visit to an eartag
producer had to be cancelled.
Throughout the mission, representatives of the head office of the NFSA accompanied the
mission team. In addition, representatives of the relevant regional offices and district
offices of the NFSA participated during meetings at the district offices and the visits to the
different farms and establishments.
A final meeting was held at the NFSA’s head office in Oslo on 29 May 2008, at which,
the mission team presented its main findings and some preliminary conclusions from the
mission.
The abbreviations used in the report are listed in Annex 1. The meetings with the
competent authorities and the visits to farms, auction markets, and slaughterhouses,
cutting plants and other undertakings during the mission are listed in Figure 1. Due to the
information received during the first week of the mission it was agreed with the NFSA to
amend parts of the programme for the second week in order to check some farms with
high amount of incorrect or missing registrations in the central database, and to get more
information and demonstrations of registrations of events in the database.
Page 5
Figure 1: Competent authority, farms, establishments and other undertakings visited
during the mission
Number Comments
Competent authority 7 In addition to the opening and final meeting, meetings
were held with representatives of three different
regional offices and six different district offices.
Central database 1 Meeting with the company running the different
databases.
Farms 8 Two sheep farms, two beef farms and four dairy or
combined beef/dairy farms.
Slaughterhouses and cutting
plants
- cattle
- sheep and goats
- cutting plants
3
1
1
Including one cutting plant.
Livestock market 2
Dairy industry’s consultancy
services
1
Eartags production company 1
Retailers
- supermarkets
- other groceries
2
1
2 Scope and objective of the mission
The scope of the mission was the following main EEA Acts and related EEA legislation:
a) Regulation (EC) 820/97 on identification and registration of bovine animals
and on labelling of beef and beef products and Regulation (EC) No 1760/2000
on identification and registration of bovine animals and on labelling of beef
and beef products1;
b) Council Regulation (EC) No 21/2004 on identification and registration of
ovine and caprine animals;
c) Council Directive 90/425/EEC on veterinary and zootechnical checks
applicable in intra-Community trade in certain live animals and products.
The objective of the mission was to assess the Norwegian competent authorities’
application of the relevant EEA legislation referred to in Chapter 3 and Annex 2 to this
report. A particular focus was put on the systems for eartagging of animals, registrations
and reporting, labelling of beef and beef products, and on the competent authorities
official controls and follow-up of non-conformities.
1 Regulation (EC) No 1760/2000 of 17 July 2000 on identification and registration of bovine animals and on
labelling of beef and beef products and relevant application texts are in the process of being incorporated
into the EEA Agreement. However, in agreement with the NFSA this regulation has been taken into account
during the mission and when drafting the report. Furthermore, and also in agreement with the NFSA, where
relevant under Chapter 7 on Conclusions, references are made to these acts.
Page 6
3 Legal basis for the mission
The legal basis for the mission was:
a) Point 4 of the Introductory Part of Chapter I of Annex I to the EEA Agreement;
b) Article 1(e) of Protocol 1 to the Agreement between the EFTA States on the
Establishment of a Surveillance Authority and a Court of Justice (Surveillance
and Court Agreement);
c) Council Regulation (EC) No 21/2004 of 17 December 2003 establishing a
system for the identification and registration of ovine and caprine animals and
amending Regulation (EC) No 1782/2003 and Directives 92/102/EEC and
64/432/EEC;
d) Commission Decision 98/139/EC of 4 February 1998 laying down certain
detailed rules concerning on-the-spot checks carried out in the veterinary field
by Commission experts in the Member States.
Legislation relevant for the mission is listed in Annex 2.
4 Main findings
4.1 National legislation
The main Norwegian Act creating the general framework for the functioning of the NFSA
is Act No 124 of 19 December 2003 relating to food safety and plant and animal health
(the Food Act). The Food Act also provides the legal basis for regulations in the relevant
fields adopted by the Ministry of Agriculture and Food, the Ministry of Health and Care
Services and the Ministry of Fisheries and Coastal Affairs.
According to the Norwegian regulation on eartagging, registration and reporting of
animals (FOR 2002-09-03 No 970: Forskrift om merking, registrering og rapportering av
dyr) all holdings keeping cattle pigs, lama and farmed deer must be registered in the
central database (Husdyrregisteret). This Norwegian regulation incorporates Regulation
(EC) No 820/97 and Directive 92/102/EEC.
Requirements for labelling of beef are included in the Norwegian regulation No 315 of 28
March 2001 on marking of origin of beef etc. (FOR 2001-03-28 nr 315: Forskrift om
opprinnelsesmerking av ferskt storfekjøtt mv.) which implements Regulation (EC) No
1760/2000.
Council Regulation (EC) No 21/2004 has been applicable to Norway since March 2005.
All farmers keeping animals permanently shall be registered in the central database. The
legal basis for this obligation can be found in the Norwegian Regulation on eartagging,
registration and reporting of small ruminants (FOR 2005-11-30 No 1356: Forskrift om
merking, registrering og rapportering av småfe) which implements Regulation (EC) No
21/2004.
Page 7
In the reply to the Authority’s pre-mission questionnaire the NFSA informed the
Authority that the following EEA acts have not been implemented into Norwegian law:
a) Commission Regulation EC (No) 509/1999 of 8 March 1999 concerning an
extension of the maximum period laid down for the application of ear-tags to
bison (Bison bison spp.)2;
b) Commission Decision 2001/672/EC of 20 August 2001 laying down special
rules applicable to movements of bovine animals when put out to summer
grazing in mountain areas3; and
c) Commission Decision 2006/968/EC of 15 December 2006 implementing
Council Regulation (EC) No 21/2004 as regards guidelines and procedures for
the electronic identification of ovine and caprine animals4.
4.2 Competent authorities
4.2.1 General information
It follows from a Royal Decree of 19 December 2003 that the competence to instruct the
competent authority, the NFSA, is split between the Ministry of Agriculture and Food, the
Ministry of Fisheries and Coastal Affairs and the Ministry of Health and Care Services.
The Ministry of Agriculture and Food is responsible for primary production on land, the
Ministry of Health Care Services is responsible for processed food and drinking water,
while the Ministry of Fisheries and Coastal Affairs is responsible for the primary
production in the water. In addition, the Ministry of Agriculture and Food is
administratively responsible for the NFSA, including budgetary allocations, and for the
co-ordination of the Ministries’ activities towards the NFSA. The head office of the NFSA
reports to the three ministries, depending on the fields.
The NFSA comprises a head office located in Oslo, eight regional offices and 61 district
offices. The head office personnel are distributed on six different geographical locations
in Norway; Oslo is one of them. The head office is responsible for co-ordinating the
organisation's activities including, inter alia, preparation of new legislation, eradication of
animal diseases and the continuous monitoring of the food chain in general, including
animal welfare issues, inspections of farms, establishments and undertakings.
Within the NFSA, administrative decisions are adopted by the district offices. Any appeals
following these decisions are considered by the regional offices. In addition, the regional
offices coordinate the activities of their district offices.
Based on the NFSA’s budget, decided by the Ministry of Agriculture and Food, the head
office of the NFSA determines the specific budgets for the head office and the regional
offices. This is followed by a budgetary process at the regional offices in co-operation
with their respective district offices. Within the framework agreed with the regional office,
the district offices can allocate their budgets as most suits the districts.
2 See comment from the NFSA on page 35 of the report. 3 See comment from the NFSA on page 36 of the report. 4 See comment from the NFSA on page 35 of the report.
Page 8
Reports on budget and activities are sent from the district offices to the regional offices
and from the regional offices to the head office. Special reports are made on the budget,
and other reports are sent every four months in addition to an annual report. The head
office is reporting back to the three responsible Ministries.
4.2.2 Training of staff
Related to the scope of this mission, the NFSA organised training courses for its staff both
in 2006 and 2007. In 2006 two two-day courses were organised for a total of 35 staff. The
first course, in March, was for the NFSA staff appointed with special duties with regard to
the databases. Information on, and familiarisation with, the different databases within the
central database, inspections and sanctions were topics addressed in addition to
obligations and procedures for this staff. Late 2006 another course was organised for this
staff and those in the regional offices appointed coordinators within the different regions.
On the agenda were issues such as detailed registrations in the registers for cattle and for
sheep and goats. Furthermore, presentations of new guidelines and procedures for
registration and reporting of data related to cattle and information about new legislation
for identification of sheep and goats, approval of eartags and inspections related to the
new legislation for identification of sheep and goats were also given at this course.
In the spring 2007 a two-day course for all relevant staff of the NFSA was arranged
focusing on how to carry out official inspections and when to use sanctions.
Late summer 2007 a course on traceability was arranged at three different places in
Norway for a total of 93 staff of the NFSA. The main issues on the agenda were reporting
and registration of information in the national cattle database and inspections on farms and
in slaughterhouses.
During the mission, NFSA representatives informed the mission team that training of staff
related to identification of animals had not been scheduled by the head office for 2008.
Furthermore, the head office now considers further training to be the responsibility of the
regional offices. Representatives from all the three regional offices met during the mission
informed the mission team that training in the mentioned topics had not been considered
as necessary in 2008.
4.2.3 Harmonisation of official control
In order to ensure a harmonised official control throughout Norway related to the scope of
this mission, the NFSA has issued a set of guidelines for different types of inspections,
identification of animals and a manual for the use of the database of ovine and caprine
animals.
According to the reply to the Authority’s pre-mission questionnaire the NFSA established,
in the beginning of 2008, a national network group consisting of more than 100 staff from
different district and regional offices. In addition to being a forum for discussions,
information is distributed regularly through this network, usually every month.
Furthermore, the regional offices have each appointed regional coordinators who are
responsible for distribution of information to the district offices within their regions.
Finally, the NFSA also publish continuously relevant information on its homepage on the
Internet.
Page 9
A representative of a regional office met during the mission informed the mission team
that one staff member at the regional office was the contact person for all issues related to
identification of animals. To some extent the regional office had followed-up the periodic
reports from the district offices.
A representative of another regional office met during the mission informed the mission
team that the regional office had not given priority to issues related to identification of
cattle, sheep and goats. Furthermore, the regional office had not appointed any contact
person related to identification of these animals.
In all three regions visited, the mission team noted that the regional offices had not been
involved in how the risk analyses were carried out at the different district offices in order
to ensure a harmonised control within the regions. The regional offices visited had also,
only to a minor extent, followed-up the district offices and how they carried out these
official checks. The follow-up of the district offices carried out had mainly been related to
the use of the central database.
4.2.4 Enforcement of legislation
According to the reply to the Authority’s pre-mission questionnaire, the district offices of
the NFSA are responsible for carrying out all inspections related to application of
legislation on identification of live animals and labelling of beef products. Such
inspections are carried out based on risk analyses.
In cases of breaches of legislation related to identification of animals the district offices
can restrict movements of animals, issue a fine or destruct affected animals. Reports on the
activities carried out by the district offices are done by the respective regional offices in
accordance with established routines. As for other decisions adopted by the district offices,
the respective regional offices act as the instance appeal.
The NFSA has issued general guidelines for the enforcement of national legislation. These
guidelines make reference to Articles 54 and 55 of Regulation (EC) No 882/2004 on
verification of official controls5. The options to restrict movements of individual animals
or all animals on a holding, issue a fine or destruct affected animals are not referred to in
these guidelines.
However, Point 4 of the Norwegian guidelines on official control of eartagging,
registration and reporting of cattle contains detailed descriptions on action to be taken in
case of non-compliances. Representatives of the NFSA informed the mission team that no
other criteria as indicated in Article 2(4)(g) of Regulation (EC) No 1082/2003 have been
defined by Norway. For official control of tagging, registration and reporting of sheep and
goats similar guidelines have been prepared.
Some statistical information related to sanctions is included in Figure 7 of Annex 4 to this
report.
5 Regulation (EC) No 882/2004 of the European Parliament and of the Council of 29 April 2004 on official
controls performed to ensure the verification of compliance with feed and food law, animal health and
animal welfare rules has been incorporated into the EEA Agreement. However, due to constitutional
requirements the compliance date for this regulation in Norway is still pending.
Page 10
In one of the regions visited NFSA representatives informed the mission team that
harmonisation of controls had been discussed in a regional meeting. However, a
representative of the regional office informed the mission team that the office had not
initiated any specific measures for ensuring harmonisation of the enforcement of the
legislation on identification of animals.
4.3 Identification and registration of bovine animals
Council Regulation (EC) No 820/97 on identification and registration of bovine animals
and regarding the labelling of beef and beef products has been applicable to Norway since
it was incorporated into the EEA Agreement in June 1999. After Norway had provided
detailed information about the procedures in place and following a visit to Norway, the
Authority adopted, in February 2003, Decision 17/03/COL by which the Norwegian
database for bovine animals was recognised as fully operational.
According to the reply to the Authority’s pre-mission questionnaire Norway considered
that the central database was complying with the requirements of Regulation (EC) No
820/97 from the date when the Authority adopted its Decision 17/03/COL.
The cattle database is available to all staff of the NFSA. In addition to the staff at the
district offices of the NFSA, the staff of the company running the databases, the producers
of eartags, the animal keepers, the slaughterhouse organisations and the dairy industry’s
consultancy services have access to the database and can register and update information
depending on the access rights given. Farmers not member of any of the farmers’
associations and not registering information in the central register themselves through the
internet, can send information on specific sheets to their respective district offices of the
NFSA, which then enter the information in the register. In some regions a special district
office has been appointed as responsible for entering the data received from farmers from
the whole region while in other regions the registrations are done by the relevant district
offices.
It follows from the Norwegian regulation FOR 2002-09-03 No 970: Forskrift om merking,
registrering og rapportering av dyr that the animal keepers are responsible for keeping a
register of all animals and movements of animals on the holding. According to this
regulation, the register should be approved by the NFSA. However, in the reply to the pre-
mission questionnaire, the NFSA informed the Authority that the format of the holding
registers has not been approved.
With regard to approval of eartags, the legal competence has been delegated from the head
office to the regional office of Rogaland and Agder. Appeals of decisions adopted by the
regional office related to approval of eartags are handled by the head office of the NFSA.
In Norway it is possible to use eartags with different colours. Detailed requirements are
laid down in the Norwegian regulation FOR 2002-09-03 No 970: Forskrift om merking,
registrering og rapportering av dyr. It follows from this regulation that bovine animals
born in Norway shall be tagged with one yellow eartag in each ear. However, although
rarely followed-up in practice, it is possible to use other colours than yellow on the
original eartags, if necessary for the actual production on the holding,. When changing
holding, an additional white eartag is applied corresponding to the holding where the
animal is kept. Animals imported from other EEA countries keep the original eartags and
Page 11
should be tagged with an additional salmon-red eartag in one ear within seven days of
arrival at the holding of destination. When imported from third countries the original
eartags are replaced by two salmon red eartags within seven days of import.
According to the reply to the pre-mission questionnaire, it is a legal requirement that
eartags must be replaced if they get lost or become unreadable. It is required that the
animals must get a new eartag of the same colour and the letter E printed along with the
identification number to show that it is a replaced eartag. An eartag bearing the letter R
and the original identification number written with a permanent marking pen can be used
until the correct replacement eartag can be applied.
In the Norwegian reply to the pre-mission questionnaire, the NFSA informed the
Authority that animal passports are not required for movements of native born animals
within Norway. However, all animals traded to Norway from other EEA countries or
imported from third countries must be accompanied by a passport issued by the NFSA.
Passports issued by competent authorities in other EEA countries are returned to the
issuing authority with additional information about the first holding of destination in
Norway when replaced by the Norwegian passport. Animals for export are accompanied
by a passport issued by the NFSA.
According to statistical information provided by the NFSA during the mission, on
average, 61.5 percent of the relevant events were reported to the national database within
seven days of the event occurring. According to representatives of the NFSA and of some
of the slaughterhouses visited, delays in registering events in the database could most
probably be due to delayed reporting from the farmers to the farmers’ organisations or to
the NFSA. In one of the districts visited NFSA representatives informed the mission team
that they considered to have seven days to register the information in the cattle database
after it had been received at the office. The representative of the dairy industry’s
consultancy services visited informed the mission team that the information received from
the farmers was usually registered in their database the same day as it arrived and
automatically transferred to the cattle database the following night.
During the mission, representatives of the NFSA informed the mission team that the date
when the event was actually registered in the cattle database was the data used for the
statistical information, which did not take account of when the event was received by the
institution registering the event in the database.
4.4 Identification and registration of ovine and caprine animals
For ovine and caprine animals, the same principles apply as for tagging of bovine animals.
According to information provided by the NFSA, it is more common, in order to facilitate
separation of animals from different holdings on summer grazing, to use different colours
or different combinations of colours on the tags/parts of the tags in order to indicate the
holding of origin and/or the age groups. Tattoos are not approved for identification of
cattle, sheep and goats in Norway. Representatives of the NFSA also informed the mission
team that detailed requirements related to the different colours that can be used are in the
process of being established.
At the opening meeting, representatives of the NFSA informed the mission team that
electronic identification of sheep started on a voluntary basis in 2008. During this season
approximately 75% of the lambs born were tagged with an electronic eartag.
Page 12
4.5 National computerised databases
In Norway the responsibility for operating the official databases have been outsourced to a
private company. This company is running different registers for cattle, for sheep and
goats, for pigs and for poultry. All these registers constitute the central database
(Husdyrregisteret). The central database (Husdyrregisteret) consists of a number of
different databases; the eartag database (Merkeregisteret), the cattle database
(Storferegisteret), the sheep and goat database (Småferegisteret), the pigs database
(Svineregisteret), the poultry database (Fjørferegisteret), the database of owners of
ornamental birds (Hobbyfjørferegisteret) and the database for supervisions
(Tilsynsregisteret). The latter is an internal database for the internal use by the NFSA. The
different animal databases keep information about holdings with animals. In addition, the
cattle database contains all the information required in Regulation (EC) No 1760/2000.
However, the mission team observed that, for instance, pre-designed quick searches for
the staff in the NFSA did not take into account all the factors to be used in carrying out the
risk analysis for deciding on the holdings to be inspected.
At the time of the visit, 20.416 cattle holdings were registered in the cattle database. The
NFSA and the Norwegian Agricultural Authority are in the process of linking the central
database to that for state subsidies. Although not completed it was possible to compare the
holdings in the database with those applying for subsidies. In total, 18.725 cattle holdings
applied for subsidies in 2008, 18.367 of which could be linked to the national cattle
database. For different reasons 358 of those cattle holdings that have applied for subsidies
could not be linked to the cattle database.
According to statistical information provided by representatives of the NFSA, restrictions
on movements of animals were, at the time of the mission, placed on 23 holdings because
of incorrect identification and/or registration.
During the visit to the operator running the databases, the mission team also received
information about the corrective action taken related to the points included in the
Authority’s decision 17/03/COL of 3 February 2003 on the recognition of the Norwegian
cattle database being fully operational. The mission team observed that measures had been
taken concerning all the points included in the Authority’s Decision.
With regard to point 2 of the Decision, related to entering events into the database, the
possibilities to report events into the database had been improved. A web interface had,
inter alia, been established, enabling immediate verification of the registered information
by those who had registered it. This reduced the amount of incorrect registrations. A
national campaign was organised in 2005 focusing only on identification of cattle and
registration into the database for bovine animals.
Training courses have not been arranged, but a representative of the operator running the
databases informed the mission team that they had looked in detail into the incorrect
registrations and worked together with the relevant organisations to improve them.
It is possible to check in the national database whether animals and holdings are under
restrictions on movements. This information is available to the slaughterhouses. However,
it was not clear to what extent this feature was actively used by the slaughterhouses. The
Page 13
operator of the databases informs the relevant district office by e-mail if animals under
restrictions are moved from the holding, one for each animal moved. At the time of the
mission, 265 e-mails had been sent in 2008 for moving animals out of farms with
restrictions and 17 e-mails had been sent for moving animals with restrictions.
Finally, it was not possible to register movements in the current database for sheep and
goats. However, representatives of the NFSA and of the operator of the databases
indicated to the mission team that it would be possible to have a database for registration
of movements of sheep and goats operational as of autumn 2008.
4.6 Labelling of beef and beef products
The NFSA is responsible for approving labelling systems for beef and beef products. No
voluntary beef labelling system has been approved in Norway and guidelines for approval
of such systems have not been established. However, the Norwegian Quality System for
Agriculture (Kvalitetssystemer i Landbruket (KSL)) is working on a project related to
voluntary labelling of beef and beef products.
4.7 Official control related to identification of bovine, ovine and caprine animals
According to the guidelines on official control of eartagging, registration and reporting of
cattle, the NFSA shall inspect at least 5% of all holdings in each district every year. When
a control is carried out it shall comprise all cattle on the holding.
It follows from these guidelines that the holdings to be inspected are to be selected based
on a risk analysis where the following criteria shall be taken into account:
a) holdings with more than 10% divergence between the number of animals in the
central database and the number of animals covered by the application for
subsidy;
b) the number of cattle on the holding;
c) conditions that can affect animal and human health;
d) substantial changes on the holding compared to previous years;
e) results of previous controls, in particular related to the updating of the holding
register; and
f) the reporting of the information to the cattle database.
The NFSA had not defined in more detail what should be considered as substantial
changes on the holding.
Representatives of one of the district offices met during the mission informed the mission
team that according to calculations made based on a method established by the head office
of the NFSA, the district office had only 60% of the resources necessary to carry out all
the duties assigned to it.
These representatives also informed the mission team that, in addition to the points
included in the guidelines mentioned above, other criteria such as sampling related to
monitoring programmes for animal diseases and residues of veterinary medicinal products
and notifications related to possible breaches of animal welfare requirements, also had a
direct impact on the decision-making process related to the farms to be visited.
Furthermore, the content of the annual budgetary disposition letter from the head office of
the NFSA often influenced the decisions on farms to be visited. Consequently, checks on
identification of live animals, registration and reporting of such events and of movements
Page 14
of live animals were therefore often not the primary reason for carrying out on-the-spot
checks on farms.
At another district office visited the NFSA representatives informed the mission team that,
due to the amount of resources available, only approximately 60% of the duties assigned
to the district office could be carried out. However, the office had categorised the different
duties into two groups; obligatory and not obligatory. The office had resources to carry out
approximately 95% of the obligatory duties. Checking identification on holdings was not
considered to be an obligatory duty.
At this district office the risk analyses expected to be carried out, in order to decide on the
farms where identification of animals should be checked, were normally not done for
small ruminants. Checks on the identification of animals were done in farms where the
inspectors already had a visit for other purposes such as taking samples for disease
monitoring programmes, residues control programmes and animal welfare visits.
A representative from a third district office visited informed the mission team that when
obligatory duties such as border control and meat control had been covered, the office had
only available 55% of the total resources needed. For the region approximately 70-73% of
the total resources needed were available.
A representative from another district informed the mission team that risk analysis created
the basis for deciding on which farms to be visited. He also informed that the farmers were
invited to sign the reports on-the-spot.
A local inspector at one of the other district offices visited informed the mission team that
approximately 40 to 50% of the cattle farms visited for checking identification of animals
were chosen following a risk analysis carried out in accordance with the guidelines
established by the head office of the NFSA.
In one of the district offices visited NFSA representatives informed the mission team that
the office, in 2007, carried out inspections in 114 out of 1.728 cattle farms and 319 out of
1.492 sheep farms. It was not possible to indicate the number of farms visited based on a
risk analysis taking into account the criteria laid down in Regulation (EC) No 1760/2000
and Regulation (EC) No 21/2004. However, it was indicated to the mission team that the
majority of the inspections were carried out based on other criteria than those laid down in
Regulation (EC) No 1760/2000 and Regulation (EC) No 21/2004.
The local NFSA representative informed the mission team at one of the farms visited that
inspections were normally notified maximum 48 hours before the visit. Usually, the
inspectors tried to notify only 24 hours in advance. The purpose of the visits was only
given to the farmers upon arrival at the farms.
According to information provided by representatives of four district offices visited, two
main options were relevant for reporting to the farmer the results of inspections carried
out. Based on a printout from the national database, the NFSA inspectors added
information on findings made on-the-spot. The report could be signed by the farmer or his
representatives and a copy was sent back to the farmer from the NFSA. This option was
harmonised on a national level, although not consistently applied. The other option was to
Page 15
send a report to the farmer issued by the inspectors after the inspection. In this situation
the farmer were not given any possibility to comment or to sign the report.
With regard to inspections of slaughterhouses it was not clear, in at least two of the
regions visited, whether these were inspected in the same manner as other holdings. The
regional office had not distributed any information to the district offices related to such
inspections.
In another slaughterhouse visited (only slaughtering sheep) the representatives of the
NFSA could not confirm whether the slaughterhouse was registered in the central
database6. Furthermore, the NFSA representatives informed the mission team that it is not
yet a requirement in Norway to submit information about movements of sheep and goats
to the sheep and goat database. The ante-mortem control in the slaughterhouse consisted
of checks of the means of transport, the animals and the identification of the animals. The
district office of the NFSA responsible for the official control at this slaughterhouse
initiated in 2005 a local campaign to ensure that only animals identified in accordance
with the national requirements were slaughtered. Consequently, in 2005 approximately 30
animals were incinerated because of absence of identification. In 2006 this number had
increased to almost 90 animals while it in 2007 had dropped back again to approximately
20 animals. In these years between 120.000 and 130.000 animals had been slaughtered
annually.
Representatives of one of the regional offices visited informed the mission team that
slaughterhouses sometimes accepted that animals with restrictions on movements were
accepted for slaughter. However, it is possible that the district office can grant derogations
from these restrictions. As these derogations are not linked to the central database the
information in that database is consequently not always reliable for the slaughterhouses7.
In one of the slaughterhouses visited a representative of the NFSA informed the mission
team that animals with only one yellow eartag were accepted at the slaughterhouse. In
these cases, the NFSA notified the slaughterhouse. However, incorrect identification was
not reported back to the relevant district offices for further follow-up of the holdings8. A
possible missing white eartag could not be detected with the type of arrival checks
currently made by the NFSA.
During the mission, the NFSA representatives and the mission team became aware of a
situation where a farmer had ordered a number of replacement eartags to animals on the
holding, including animals registered in the national databases as slaughtered. The
relevant district office was informed of the observations and carried out a check on the
holding. Because of the observations made the district office adopted a decision restricting
movements of the animals on the holding until compliance with the national requirements
could be ensured9.
In 2007 the head office of the NFSA initiated a campaign to improve the registrations in
the central database. A national list of the holdings with most errors in the registrations
was therefore created. Selection criteria were holdings with more than five events
6 See comment from the NFSA on page 37 of the report. 7 See comment from the NFSA on page 37 of the report. 8 See comment from the NFSA on page 37 of the report. 9 See comment from the NFSA on page 38 of the report.
Page 16
registered more than seven days after they occurred, in a given period (two months),
applications for subsidises without having cattle in the database and the number of animals
in the database diverging in more than five animals from the number of animals in the
applications for subsidises. Letters were sent to approximately 3.900 farmers. The regional
and district offices were expected to follow-up the campaign and some district offices sent
out follow-up letters. However, at the time of the mission it had not been decided whether
to follow-up last year’s letters on a national level. The mission team invited the operator of
the database to print out a similar list for 2008. According to this list approximately 3.700
letters should have been sent out this year.
All district offices have access to the central database and can take into account the
information in the different registers when carrying out on-the-spot checks. However, at
the time of the mission it was not possible to get an overview of the extent for which these
feature was used by the different district offices.
The mission team also asked the NFSA to provide a list of the holdings in two of the
districts to be visited during the latter part of the mission. The criteria should be similar to
those used during the campaign carried out in 2007. Based on this list, the mission team
amended the programme and visited to farms not included in the programme agreed at the
opening meeting. Based on statistical information from the operator of the central database
the mission team visited two other cattle farms not in the initial mission programme (for
details on the observation made in these two farms -see Chapter 4.11 below-). In one of
these farms visited the inspector from the district office of the NFSA wrote a report on-
the-spot that the representative of the farmer signed. The inspector and the farmer’s
representative also agreed on a three weeks deadline for rectification of the non
conformities. In the other farm visited, and following the mission team’s presentation of
the main findings, the inspector from the district office decided to re-visit the farm in order
to make a complete check of all relevant information before deciding on the measures to
be taken.
In one of the farms visited the mission team took note of the NFSA representatives
pointing out to the farmer that he had to take immediate action to improve the state of the
hoofs for some of the animals.
Two auction markets were also visited during the mission. The mission team observed that
the NFSA had not inspected any of these auction markets with the purpose of checking
compliance with legislation on identification of cattle, sheep and goats. However, NFSA
representatives informed the mission team that meetings had been arranged with
representatives of the auction markets where also identification of animals had been on the
agenda. Based on information received during these meetings the NFSA concluded that
inspections of these facilities were not considered as a priority.
4.8 Official control related to labelling of beef and beef products
In the reply to the Authority’s pre-mission questionnaire, the NFSA stated that the
businesses’ own checks systems are systematically examined when the NFSA is carrying
out its inspections. This also includes verification of compliance with the requirements for
labelling. The businesses’ labelling systems as such are not approved, but notice on
decisions can be made if requirements on labelling are not met. Inspections on businesses’
own checks systems are accomplished regularly for beef production establishments.
However, a representative of the NFSA informed the mission team that official checks on
Page 17
the establishments labelling systems could not be confirmed through guidelines,
procedures or checklists.
In two of the slaughterhouses visited a special system for registration of animals and
traceability of the animals through the slaughtering process were in use. In these
slaughterhouses the identification of the animals were registered in a database before
stunning. At the time of skinning the eartags were removed from the carcasses. At the
point for classification of the carcasses the identification of the individual carcasses were
retrieved from the database again. This system had not been approved by the local
competent authority at the time of approval of the slaughterhouse. However, after appeal
to the central competent authority the method had been approved. The mission team could
not establish that the relevant part of the slaughterhouse’s own-checks system contained
sufficient details for handling of deviations, i.e. if the registration into the database was
incorrect for some animals.
In another slaughterhouse visited NFSA representatives informed the mission team that
the internal traceability system in the slaughterhouse had not been approved as such.
However, the system was assessed during inspections and audits of the establishment and
a point regarding the internal traceability systems was included in the checklist used by the
district office.
In one of the district offices visited NFSA representatives informed the mission team that
following the entry into force of the national regulation on labelling of beef and beef
products, in 2001, the office had initiated a campaign where fact sheets and other
information had been distributed to the undertakings. In 2004, a campaign focusing on
handling meat sold over-the-counter had been the main focus, while a similar campaign in
2005 had focused on chillers. Finally, in 2007 a campaign focusing on retail had been
initiated. This campaign would be continued in 2008 with a particular focus on
multicultural retail shops not being part of the chain-stores. In all these campaigns
labelling and traceability of products had been one of the main issues checked.
4.9 Official control related to trade in live animals
According to Norwegian regulation requirements, goats and sheep can be imported to
Norway from other EEA States (Sweden, Finland and Denmark) without being placed in
Isolation. However, isolation of imported small ruminants from these EEA States is
evaluated on a case to case base, for example inadequate health control documentation
can be a reason especially as far as Maedi-Visna viral disease is concerned.
For cattle it is general requirement that animals imported from other EEA States must be
placed in isolation when arriving at the place of destination in Norway.
In one of the farms visited the mission team observed that animals had been imported
from Sweden in 2007. The mission team noted that that the farmer had applied for
exemption from the Norwegian requirement for isolation of bovine animals imported from
other EEA countries. From the documentation related to this particular import and
provided by the NFSA to the mission team during the mission it was not possible to verify
whether the district office had checked the passports that should have accompanied the
imported animals.
Page 18
The mission team also visited a farmer having imported animals from Denmark twice the
last three years. The farmer had applied for exemption from the official requirement for
placing imported animals in isolation. Due to the health status of the animals such
exemption had been granted. The NFSA had visited the farmer within a few days after the
animals had arrived, checked the accompanying documents and taken samples, the last
time, for salmonella. A part from these visits no other official control had been carried out
since 2005. The mission team observed that the colour of the salmon red eartags used on
imported animals faded in only a couple of years so it looked similar to the yellow eartags.
Furthermore, NFSA representatives informed the mission team that on one occasion the
passports had not been checked when the cattle had been imported from another EEA
State.
4.10 Producer of eartags visited
According to information provided by the NFSA, currently four producers/distributors of
ear tags provide NFSA’s officially approved ear tags for the identification of bovine, ovine
and caprine animals in Norway. The mission team visited one of these
producers/distributors having the major part of the Norwegian market of animal eartags
and also one of the biggest producers of plastic eartags in the Nordic countries. This
producer was also exporting eartags to several European countries including Great Britain,
the Netherlands and Iceland. The eartags from this producer are both PAS 44 and PAS 66
approved and an ICAR approval was expected later in 2008. This producer could receive
direct orders through phone and telefax, by mail and e-mail and through its homepage.
In Norway the NFSA has organised ordering and distributions of eartags so that the
farmers, the private slaughterhouses, the co-operative slaughterhouses, the dairy co-
operative and the different farmers’ consultancy services can order eartags directly
through the eartag database or through the producers. Orders registered through the eartag
database are transferred to the eartag producers every night.
In case eartags are ordered directly from the producers they must register and have the
orders verified through the eartag database and the central database before effectuation. If
this is not done the NFSA can withdraw the approval of the producers.
4.11 Farms visited
The mission team observed that most of the farmers met during the mission were well
acquainted with the relevant legal requirements related to identification and registration of
animals.
However, in one of the beef farms visited and due to some misunderstandings a number of
calves had been reported to the national database some 300 days after birth. This had
recently been updated and appeared to be correct at the time of the visit. The mission team
also observed that some animals had not been tagged with replacement salmon-red
eartags. Finally, the mission team observed that one animal had only one yellow eartag,
apparently not detected by the farmer.
In another beef farm visited the mission team did not observe any incorrect use of eartags.
However, the farmer had ordered eartags for approximately two year’s need. He registered
Page 19
all relevant information in an own-prepared register and reported the information by mail
to the district office of the NFSA within seven days.
In a dairy farm visited the farmer himself registered information directly into the cattle
database. He informed the mission team that normally he registered information within the
seven day’s limit, but it could take up to 10-14 days in the more busy periods. It appeared
that all relevant information was registered, although not in a holding register as such, but
in different places. A representative of the NFSA informed the mission team that the
NFSA had accepted that the required information could be filed in different places and
still be in compliance with the requirement for keeping a holding register. In this farm the
mission team also observed that the farmer had eartags exceeding one year’s need.
The mission team observed in another dairy farm visited that the farmer reported events to
the national database directly, and through the dairy farmers’ consultancy services when
the time the event occurred was close to when the monthly reporting scheme was sent. The
farmer informed that he could order eartags exceeding one year’s need. However, he
documented good record keeping of all relevant information.
Based on statistical information from the operator of the central database the mission team
visited two other cattle farms not in the initial mission programme. In one of these farms
the mission team observed that the main reason for the delayed reporting (many of the
registrations the last few months were later than 21days after they had occurred) of events
was a merger of two farms. The mission team met a representative of the farmer who was
very familiar with the legal requirements. He informed the mission team that he was in the
process of making the final up-dates of the registrations. He also informed the mission
team that when he orders eartags there were no restrictions on the number of tags that
could be ordered. The mission team observed two calves brought into the farm with only
one eartag from the holding of origin in addition to the white eartag indicating the current
holding.
In the other farm visited the mission team observed that 5-6% of the animals were missing
one eartag. These observations came in addition to the much delayed reporting (on
average approximately 30 days) of events to the central database. Because of the findings
the district office made a follow-up inspection two days later. Similar non-compliances
related to insufficient tagging were observed by the NFSA during the second inspection.
However, the farmer had updated the majority of the incorrect registrations in the central
database and also ordered the necessary replacement eartags. The district office therefore
decided not to place restrictions on the farm, but follow-up in detail that the replacement
eartags were correctly applied and that the remaining updates of the central database were
done.
In both sheep farms visited the mission team observed that the animals were tagged in
accordance with the requirements. The annual inventories in both farms were updated
automatically based on the information registered in the sheep control organised by the
sheep farmers association. However, although movements of sheep were exceptional, the
owners informed the mission team that procedures such as notifications to the central
database were not established. Representatives of the NFSA confirmed this information.
Finally, holding registers containing information about all movements and replacements of
eartags where not in place in any of the sheep farms visited.
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4.12 Auction markets visited
During a mission in 2005 related to the contingency plan for foot and mouth disease the
Authority concluded that the auction markets should have unique registration numbers in
the central database. During this mission the mission team observed that auction markets
had only very recently received such a number and that registration of animals in the
national cattle database had only started few weeks ago.
One of the auction markets visited had auctions twice per year while the other had one
auction every month. In one of the markets approximately 150 animals are passing
through the market per year while in the other approximately 500 animals pass through the
facilities. In one of the auction markets only the cattle that stay at the market overnight
were registered in the central database, while in the other all cattle entering the market
were registered. The mission team observed in one of the markets that it was not easy to
trace the place of destination of the animals, in particular those that had not be sold on the
auction.
One of the auction markets ordered eartags when animals at the market were not marked
correctly, while the other market visited considered this to be the responsibility of the
owner of the animals.
In one of the markets visited the mission team also observed that animals destined for the
auction market could be transported together with animals intended for the nearby
slaughterhouse10.
4.13 Slaughterhouses and cutting plants visited
In the slaughterhouses visited the mission team observed that the staff had good
knowledge about the legal requirements related to identification of live bovine animals
and labelling of beef and beef products. Representatives of one of the slaughterhouse
visited informed the mission team that it was accepted that animals with only one yellow
eartag could be transported to the slaughterhouse for slaughter. However, it was not
possible for the farmers to send for slaughter animals for which the information registered
in the national cattle database were not up-to-date. Furthermore, slaughterhouse
representatives informed the mission team that, where relevant, animals without a white or
salmon read eartag were not accepted for slaughter. The mission team observed that,
although required in the establishment’s own procedures, not all transporters confirmed on
the document accompanying the animals that a check of the identification of the animals
had been carried out.
Representatives of the slaughterhouse also informed the mission team that approximately
one out of 10.000 animals arrived at the slaughterhouse without any eartags. Finally, in the
labelling system established it was possible to trace back meat products to the farms
slaughtered in one particular day.
In one slaughterhouse visited slaughtering sheep and goats, the slaughterhouse
representatives informed the mission team that enrolment for slaughter can be done by
phone, SMS and through the internet. Information registered at the time of enrolment is
the identity of the farmer/owner of the animals, the number of animals to be slaughtered,
10 See comment from the NFSA on page 38 of the report.
Page 21
the age and sex, the species, the preferred week for slaughter and whether the owner is
transporting the animals to the slaughterhouse. Owners not approved and registered as
transporters can only transport animals if the distance is less than 50 km. The official
veterinarians at the slaughterhouse are checking the suitability of the means of transport
used by the owners. When arriving, the slaughterhouse representatives check at least the
identity of the owner and the number of animals delivered for slaughter. Representatives
of the slaughterhouse were not aware of whether the slaughterhouse was registered in the
central database as a holding. No information about animals received for slaughter was
sent from the slaughterhouse to this database.
Representative of another slaughterhouse visited informed the mission team that it was
accepted that animals can be transported to the slaughterhouse with only one yellow
eartag.
4.14 Dairy industry’s consultancy services visited
The mission team visited one adviser from the dairy industry’s consultancy services. The
person was very familiar with the requirements related to identification of cattle and
reporting of events to the national database. The adviser informed the mission team that
the consultancy services had informed all the farmers about the legal requirements for
reporting all relevant events within seven days. It was not possible at the time of the visit
to give information about the time from the events occurred until the adviser had received
the information. The old established procedure for monthly reporting information to the
consultancy services appeared to still be applied by some farmers. The adviser had also
observed that sending information by mail from the farmers to the consultancy services
often took around three working days. However, many farmers in the area sent the
information by e-mail or on paper with the tank lorry transporting the milk to the dairy
plants.
The adviser received information from approximately 50 farmers that had to be registered
in the national cattle database. According to the files this was normally done the same day
as received from the farmers. All advisers in the dairy industry’s consultancy services
register the information in the consultancy services’ database. The data registered in this
database is transferred to the national cattle database every night.
Finally, the adviser also informed the mission team that all members are visited twice per
year. During these visits the adviser also checks whether there is compliance between the
information in the national cattle database and the number of animals and registrations
made on the farms.
4.15 Retailers visited
In the supermarkets visited the mission team observed that the persons in charge of the
fresh meat departments were very competent and had a good overview of the procedures
and activities related to labelling and traceability of products.
In one of the supermarkets visited the mission team observed that for fresh products
prepared at the market and sold over the counter and also for fresh packed products the
approval numbers of the slaughterhouses and the cutting plants, in addition to the
reference numbers, were indicated. The area where fresh meat was handled was tidy and
Page 22
well organised. However, the mission team observed both packed and unpacked products
in the refrigerator.
In this supermarket the mission team invited the district office to demonstrate how and
how far back two different batches of minced meat could be traced. Within a few hours
the district office received the relevant information. One of the batches originated from a
day when 107 bovines had been slaughtered originating from 36 different farms. The meat
in the other batch originated from a day’s production in a slaughterhouse having
slaughtered almost 450 bovines that day originating from approximately 150 different
farms.
In another supermarket visited, the supermarket chain’s traceability system was described
and demonstrated. In principle, the producers labelling system of the meat are maintained
by the retailer. However, an internal system was established for the products packed at the
market. Also here the mission team invited the district office to trace back a product. The
district office where the beef was prepared discovered that the country of origin was not
correctly indicated on the labelling. However, it was still possible to trace the product back
to the EEA country of origin and to the slaughterhouse where the animal had been
slaughtered. More detailed checks at the slaughterhouse were not carried out.
Finally, the mission team visited a small grocery not being part of any of the supermarket
chains. In this shop some of the frozen meat observed was only labelled with the day of
freezing and country of origin (Norway). However, from the information available in the
shop it was not possible to trace the product back to the producer or wholesaler. According
to information provided by the district office a number of inspections had been carried out
in this and similar groceries during the last years in particular focusing on labelling and
traceability.
5 Final meeting
A final meeting was held on 29 May at the head of office of the NFSA in Oslo with
representatives from the Ministry of Agriculture and Food and the NFSA. At this meeting,
the mission team presented its main findings and some preliminary conclusions of the
mission.
At the meeting the mission team also explained that, based on a more detailed assessment
of the information received during the mission, additional conclusions could be included
in the report.
The representatives of the competent authorities did not have any objections to the
observations made and the preliminary conclusions presented.
6 Conclusions
6.1 Legislation
6.1.1 Commission Regulation EC (No) 509/1999
Commission Regulation EC (No) 509/1999 of 8 March 1999 concerning an
Page 23
extension of the maximum period laid down for the application of ear-tags to bison
(Bison bison spp.) has not been implemented into Norwegian law.
6.1.2 Commission Decision 2001/672/EC
Commission Decision 2001/672/EC of 20 August 2001 laying down special rules
applicable to movements of bovine animals when put out to summer grazing in
mountain areas has not been implemented into Norwegian law11.
6.1.3 Commission Regulation (EC) No 2006/968
Commission Decision 2006/968/EC of 15 December 2006 implementing Council
Regulation (EC) No 21/2004 as regards guidelines and procedures for the
electronic identification of ovine and caprine animals has not been implemented
into Norwegian law12.
6.2 Application of legislation related to identification and registration of bovine
animals and labelling of beef and beef products
6.2.1 Eartags
Full compliance with Article 1(5) of Regulation (EC) No 911/2004 could not be
ensured since it was possible to order eartags exceeding the need for one year’s
use.
6.2.2 Holding registers
Compliance with Regulation (EC) No 1760/2000 and in particular Article 7(4)
thereof could not be fully ensured since the NFSA had not approved the format of
the holding registers.
6.2.3 Holding registers
Compliance with Regulation (EC) No 911/2004 and in particular Article 8(e)
thereof could not be ensured since the official inspectors are not signing the
registers on the farms when checked.
6.2.4 Controls of holdings
Compliance with Regulation (EC) No 1760/2000 and in particular Article 2
thereof, and with Regulation (EC) No 1082/2003 and in particular Articles 1 and
3(1) thereof, could not be fully ensured since slaughterhouses were not considered
as holdings and therefore not controlled13.
6.2.5 Controls on holdings
Compliance with Regulation (EC) No 1082/2003 and in particular Article 2
thereof, could not be fully ensured since the selection of holdings to be inspected
was often not based on a risk analysis.
11 See comment from the NFSA on page 39 of the report. 12 See comment from the NFSA on page 39 of the report. 13 See comment from the NFSA on page 39 of the report.
Page 24
6.2.6 Passports
The requirement that all imported animals from other EEA Countries must at all
times after arriving in Norway be accompanied by a passport issued by the NFSA
is not in compliance with Regulation (EC) No 1760/2000 and in particular Article
6(3) thereof.
6.2.7 Passports
For one consignment of live animals imported from another EEA States the
passport were neither checked nor surrendered to the NFSA at the time of arrival
of the animals. Compliance with Regulation (EC) No 1760/2000 and in particular
Article 6(3) could therefore not be ensured.
6.2.8 Labelling of beef products
Compliance with Regulation (EC) No 1760/2000 and in particular Article 13(1)
thereof could not be ensured since beef products were not labelled so that a link
was established between the beef and the animal/group of animals concerned.
6.2.9 Sanctions
Compliance with Regulation (EC) No 494/98 and in particular Article 4 thereof
could not be ensured since the NFSA had not taken appropriate measures when
farmer had failed to respect the deadline set out in Article 7(1) of Regulation (EC)
No 1760/2000.
6.3 Application of legislation related to identification and registration of ovine and
caprine animals
6.3.1 Registration of movements of ovine and caprine animals
Compliance with Regulation (EC) No 21/2004 and in particular Article 8(2)
thereof could not be ensured since information about movements of ovine and
caprine animals were not provided to the competent authority.
6.3.2 Holding registers
Compliance with Regulation (EC) No 21/2004 and in particular Article 3(1)(b)
thereof could not be ensured since holding registers were not established or used.
6.3.3 Holding registers
Compliance with Regulation (EC) No 21/2004 and in particular Article 5(3)
thereof could not be ensured since the format of the holding register was not
approved by the competent Authority.
6.3.4 Checks of holdings
Compliance with Regulation (EC) No 21/2004 and in particular Articles 2 and
12(1) thereof, and with Regulation (EC) No 1505/2006 and in particular Article 1
thereof, could not be fully ensured since slaughterhouses were not considered as
holdings and therefore not checked14.
14 See comment from the NFSA on page 39 of the report.
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6.4 Application of legislation related to veterinary checks related to trade in live
animals
6.4.1 Quarantine and isolation
The requirement of placing cattle and sheep originating in other EEA States in
isolation at the place of destination is not in compliance with Directive
90/425/EEC and in particular Articles 1, 5 and 6 thereof15.
7 Recommendations to the Norwegian competent authority
Notification of corrective action and a plan for completion of measures
Norway should inform the Authority in its reply to the draft report, by way of written
evidence, of the corrective actions taken and a plan for corrective measures and actions,
including a timetable for completion of measures still outstanding, relevant to all the
conclusions under Chapter 6 of this report. This information will be annexed to the final
report. The Authority should also be kept informed of the completion of the measures
included in the timetable.
15 See comment from the NFSA on page 40 of the report.
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Annex 1 List of abbreviations and terms used in the report
Authority EFTA Surveillance Authority
EC European Community
EEA European Economic Area
EEA Agreement Agreement on the European Economic Area
NFSA Norwegian Food Safety Authority
PAS 44 British standard specification of official identification eartags for
cattle
PAS 66 British standard specification of official identification eartags for
sheep and goats
ICAR International Committee for Animal Recording
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Annex 2 Relevant legislation
The main EEA Acts relevant for this mission are:
1 Acts related to identification and registration of bovine animals and
regarding the labelling of beef and beef products:
a) The Act referred to at Point 1.1.7a of Chapter I of Annex I to the EEA
Agreement, Council Regulation (EC) No 820/97 of 21 April 1997 establishing
a system for the identification and registration of bovine animals and
regarding the labelling of beef and beef products;
Although still not incorporated into the EEA Agreement the Authority will
take the following acts into account as appropriate and where relevant:
Regulation (EC) No 1760/2000 of the European Parliament and of the Council
of 17 July 2000 establishing a system for the identification and registration of
bovine animals and regarding the labelling of beef and beef products and
repealing Council Regulation (EC) No 820/97, as amended;
Commission Regulation (EC) No 1082/2003 of 23 June 2003 laying down
detailed rules for the implementation of Regulation (EC) No 1760/2000 of the
European Parliament and of the Council as regards the minimum level of
controls to be carried out in the framework of the system for the identification
and registration of bovine animals;
Commission Regulation (EC) No 911/2004 of 29 April 2004 implementing
Regulation (EC) No 1760/2000 of the European Parliament and of the Council
as regards eartags, passports and holding registers;
b) The Act referred to at Point 4.1.1 of Chapter I of Annex I to the EEA
Agreement, Council Directive 64/432/EEC of 26 June 1964 on health
problems affecting intra-Community trade in bovine animals and swine, as
amended and as adapted to the EEA Agreement by the sectoral adaptations
referred to in Annex I to that Agreement;
c) The Act referred to at Point 1.2.20 of Chapter I of Annex I to the EEA
Agreement, Commission Decision 93/317/EEC of 21 April 1993 concerning
the content of the code to be used on bovine ear marks, as amended and as
adapted to the EEA Agreement by the sectoral adaptations referred to in
Annex I to that Agreement;
d) The Act referred to at Point 1.2.70 of Chapter I of Annex I to the EEA
Agreement, Commission Regulation (EC) No 2628/97 of 29 December 1997
laying down detailed rules for the implementation of Council Regulation (EC)
No 820/97 as regards transitional provisions for the start-up period of the
system for the identification and registration of bovine animals, as amended;
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e) The Act referred to at Point 1.2.71 of Chapter I of Annex I to the EEA
Agreement, Commission Regulation (EC) No 2629/97 of 29 December 1997
laying down detailed rules for the implementation of Council Regulation (EC)
No 820/97 as regards eartags, holding registers and passports in the
framework of the system for the identification and registration of bovine
animals, as amended;
f) The Act referred to at Point 1.2.72 of Chapter I of Annex I to the EEA
Agreement, Commission Regulation (EC) No 2630/97 of 29 December 1997
laying down detailed rules for the implementation of Council Regulation (EC)
No 820/97 as regards the minimum level of controls to be carried out in the
framework of the system for the identification and registration of bovine
animals, as amended;
g) The Act referred to at Point 1.2.76 of Chapter I of Annex I to the EEA
Agreement, Commission Regulation (EC) No 494/98 of 27 February 1998
laying down detailed rules for the implementation of Council Regulation (EC)
No 820/97 as regards the application of minimum administrative sanctions in
the framework of bovine animals;
h) The Act referred to at Point 1.2.86a of Chapter I of Annex I to the EEA
Agreement, Commission Regulation (EC) No 509/1999 of 8 March 1999
concerning an extension of the maximum period laid down for the application
of ear-tags to bison (Bison bison spp.);
i) The Act referred to at Point 1.2.112 of Chapter I of Annex I to the EEA
Agreement, Commission Decision 2001/672/EC of 20 August 2001 laying
down special rules applicable to movements of bovine animals when put out to
summer grazing in mountain areas;
j) EFTA Surveillance Authority Decision 17/03/COL of 5 February 2003
recognising the fully operational character of the Norwegian database for
bovine animals.
2 Acts related to identification and registration of ovine and caprine
animals:
a) The Act referred to at Point 1.1.7b of Chapter I of Annex I to the EEA
Agreement, Council Regulation (EC) No 21/2004 of 17 December 2003
establishing a system for the identification and registration of ovine and
caprine animals and amending Regulation (EC) No 1782/2003 and Directives
92/102/EEC and 64/432/EEC, as amended and as adapted to the EEA
Agreement by the sectoral adaptations referred to in Annex I to that
Agreement;
b) The Act referred to at Point 1.1.7 of Chapter I of Annex I to the EEA
Agreement, Council Directive 92/102/EEC of 27 November 1992 on the
identification and registration of animals, as amended;
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c) The Act referred to at Point 1.2.131 of Chapter I of Annex I to the EEA
Agreement, Commission Regulation (EC) No 1505/2006 of 11 October 2006
implementing Council Regulation (EC) No 21/2004 as regards the minimum
level of checks to be carried out in relation to the identification and
registration of ovine and caprine animals;
d) The Act referred to at Point 1.2.132 of Chapter I of Annex I to the EEA
Agreement, Commission Decision 2006/968/EC of 15 December 2006
implementing Council Regulation (EC) No 21/2004 as regards guidelines and
procedures for the electronic identification of ovine and caprine animals.
3 Acts related to veterinary and zootechnical checks applicable in intra-
Community trade in certain live animals and products:
a) The Act referred to at Point 1.1.2 of Chapter I of Annex I to the EEA
Agreement, Council Directive 90/425/EEC of 26 June 1990 concerning
veterinary and zootechnical checks applicable in intra-Community trade in
certain live animals and products with a view to the completion of the internal
market, as amended and as adapted to the EEA Agreement by the sectoral
adaptations referred to in Annex I to that Agreement;
b) The Act referred to at Point 1.2.2 of Chapter I of Annex I to the EEA
Agreement, Commission Decision 91/398/EEC of 19 July 1991 on a
computerised network linking veterinary authorities (Animo);
c) The Act referred to at Point 1.2.3 of Chapter I of Annex I to the EEA
Agreement, Commission Decision 91/585/EEC of 4 November 1991
determining the minimal configuration of certain equipment for the
computerised network linking veterinary authorities (Animo);
d) The Act referred to at Point 1.2.4 of Chapter I of Annex I to the EEA
Agreement, Commission Decision 91/637/EEC of 3 December 1991 on
establishing the model for the message to be transmitted by means of the
computerised network "Animo", as amended;
e) The Act referred to at Point 1.2.5 of Chapter I of Annex I to the EEA
Agreement, Commission Decision 91/638/EEC of 3 December 1991 on the
designation of a common host centre for the computerised network "Animo";
f) The Act referred to at Point 1.2.6 of Chapter I of Annex I to the EEA
Agreement, Commission Decision 92/176/EEC of 2 March 1992 concerning
maps to be provided for use for the Animo network;
g) The Act referred to at Point 1.2.8 of Chapter I of Annex I to the EEA
Agreement, Commission Decision 92/341/EEC of 3 June 1992 relating to the
computer retrieval of local Animo units, as amended and as adapted to the EEA
Agreement by the sectoral adaptations referred to in Annex I to that
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Agreement;
h) The Act referred to at Part 1.2.9 of Chapter I of Annex I to the EEA
Agreement, Commission Decision 92/373/EEC of 2 July 1992 designating the
host centre "Animo";
i) The Act referred to at Part 1.2.12 of Chapter I of Annex I to the EEA
Agreement, Commission Decision 92/486/EEC of 25 September 1992
establishing the form of cooperation between the Animo host centre and
Member States, as amended.
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Annex 3 Information on production and trade
Figure 2: Total number of holdings, total number of animals born, total number
of animals slaughtered and meat produced16
2006 2007 2008
Total number of holdings17
a) bovine 24.300 21.226 20.425
b) ovine 16.853 15.800 16.219
c) caprine 1.300 1.228 1.287
Total number of animals born
a) bovine 335.469 325.174 60.318
b) ovine18 1.431.576 1.370.867
c) caprine
Total number of animals slaughtered
a) bovine19 333.892 320.885
b) ovine 1.237.281 1.164.083
c) caprine 23.244 22.180
Meat production (tons, excluding condemns)
a) beef 53.208
b) calves 2.116
c) lamb and mutton 25.153
d) goats (kids and adults) 297
16 Updated statistical information is not easily accessible for the NFSA related to animals slaughtered and
meat produced. A new system in the process of being developed by the NFSA will improve this situation.
17 Total number of holdings is per 31 March 2008.
18 There is no register of total number of ovine and caprine born, the number given in the table is for the total
number of ovine which are less than 1 year old per 01.01.07, and 01.01.08 for preceding years 2006 and
2007 respectively, total numbers for the year 2008 will not be known/published by the Statistisk sentralbyrå
(Statistics Norway) before 01.01.09.
19 Total include calves, dairy and beef cattle. The total numbers for slaughtered animals per 01.01 of each
year are published by the Statistisk sentralbyrå (statistics Norway) for the preceding year. Therefore total
number for animals (bovine and caprine) slaughtered during 2008 will not be known/published before
01.01.09.
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Figure 3: Information on trade and movements of live animals
bovine ovine caprine
A) Animals moved from one holding to another
2006 105.492 10.000
2007 108.886 9.600
2008 29.249 900
B) Animals imported from other EEA Countries
2006 28 27 20
2007 2 3 0
2008 0 0 0
C) Animals imported from third countries
2006 0 0 0
2007 0 0 0
2008 0 0 0
C) Animals exported to other EEA Countries
2006 0 5 0
2007 0 218 0
2008 7 0 0
D) Animals exported to third countries
2006 0 0 0
2007 0 0 0
2008 0 50 0
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Annex 4 Official control related to identification of bovine, ovine and
caprine animals
Figure 5 Information related to official control carried out of bovine animals
2006 2007 2008
Number of bovine holdings and number of inspections
carried out
Total number of holdings registered 24.300 21.229 20.411
Total number of holdings inspected 1.224 1.156 332
Total number of inspections carried out 1.354 1.233 348
Total number of bovine livestock 972.203 924.270 921.142
Total number of bovines inspected 50.510 51.545 14.901
Total number of non-compliances found related to
a) physical checks 2.001 2.337 642
b) documentary checks 975 1493 453
c) checks on delayed notifications 5.129 4.651 1.161
Total number of sanctions imposed related to
a) restriction of movements of individual bovines 9 32 6
b) restriction of movements of all bovines on the holding 64 83 21
c) destruction of animals 0 0 0
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Figure 6 Information related to official control carried out of ovine and caprine
animals
2006 2007 2008
Number of ovine and caprine holdings and number of
inspections carried out
Total number of ovine holdings registered 16.853 15.800 16.219
Total number of caprine holdings registered 1.300 1.228 1.287
Total number of mixed ovine/caprine holdings registered 792 719 744
Total number of holdings registered 19.476 19.120 18.710
Total number of holdings inspected 240 2.231 859
Total number of inspections made 251 2.361 887
Total number of ovine and caprine livestock 1.137.093 1.088.491 1.159.862
Total number of animals in holdings checked 14.731 174.241 70.138
Percentage of holdings inspected 1.27 12.08 4.59
Percentage of animals inspected 1.29 16.00 6.04
Total number of non-compliances found related to
a) identification of ovine animals 1436 2823 1012
b) identification of caprine animals 556 1727 318
c) holding register discrepancy 1363 1554 318
d) failure to notify movement20
e) movement document anomaly 2 31 20
f) animals/holdings with only one finding of non-
compliance as listed in points a) to e)
1.776/66 3.830/359 1.363/116
g) animals/holdings with more than one finding of non-
compliance as listed in points a) to e)
1.581/46 2.305/104 270/20
h) total number of findings of non compliance concerning
animals/holdings (points f) and g)
3.357/112 6.135/463 1.633/136
Figure 7 Total number of sanctions imposed 2006 2007 2008
Ovine/caprine, affected animals 3.704 1.588 369
Ovine/caprine, affected holdings 28 16 4
Bovine, affected animals 2.574 3.702 845
Bovine, affected holdings 100 91 22
20 Movements are not registered in the central database. The NFSA has recently started to develop a system
for such registrations.
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Annex 5 Comments to the draft report and information on the corrective
actions already taken and planned by the Norwegian competent
authority
Dear Sir/Madam
EFTA SURVEILLANCE AUTHORITY - MISSION TO NORWAY FROM 19 TO 29 MAY 2008 REGARDING THE APPLICATION OF EEA LEGISLATION RELATED TO IDENTIFICATION AND REGISTRATION OF ANIMALS and LABELLING OF BEEF AND BEEF PRODUCTS - DRAFT REPORT We have received the draft report from the mission to Norway 19 to 29 May 2008 regarding the application of EEA legislation related to the identification and registration of bovine animals, labelling of beef and beef products, identification and registration of ovine and caprine animals, and related to veterinary and zoo technical checks applicable in intra-community trade in certain live animals products. The Norwegian Food Safety Authority (NFSA) is hereby responding to ESA’s recommendations and encloses its comment on the factual content and notification of corrective actions, supported by documentation when possible and as requested.
Comments on the factual content :
4.1 National legislation
NFSA informed in the reply to ESA`s pre-mission questionnaire, that the following EEA acts have not been implemented into Norwegian law: a) Commission Regulation EC (No) 509/1999 of 8 March 1999 concerning an extension of the maximum period laid down for the application of ear-tags to bison (Bison bison spp.);
We suggest to change this paragraph as a new Norwegian regulation implementing Commission Regulation EC (No) 509/1999, together with Regulation (EC) No 1760/2000, is currently under preparation and expected to enter into force before 15 January 2009.
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b) Commission Decision 2001/672/EC of 20 August 2001 laying down special rules applicable to movements of bovine animals when put out to summer grazing in mountain areas; and ???
Commission Decision 2001/672/EC has not been implemented in Norwegian regulation because the decision applies to the movements of bovine animal within the following Member States or part of these states: France, Italia, Austria and Portugal. The Decision has been incorporated in Annex I Chapter 1 section 1.2 (“application texts”) by mistake. Like other acts addressed to specific Member States, it should rather have been incorporated under “Acts which the EFTA States and the EFTA Surveillance Authority shall take due account”. c) Commission Decision 2006/968/EC of 15 December 2006 implementing Council Regulation (EC) No 21/2004 as regards guidelines and procedures for the electronic identification of ovine and caprine animals.
Commission Decision 2006/968/EC is fully implemented in Norwegian Regulation FOR 2008-04-23 nr 395: Forskrift om krav til identifikator, avleser og
prøvingslaboratorium i forbindelse med elektronisk identifikasjon av småfe, which entered into force on the 23rd April 2008. A copy of the regulation is enclosed. 4.2.1 General information
The NFSA comprises a head office located in Oslo, eight regional offices and 61 district offices. We suggest the following amendment:
The NFSA comprises a head office, eight regional offices and 61 district offices.. The head office personnel are distributed on six different geographical locations in Norway; Oslo is one of them.
4.3 Identification and registration of bovine animals
According to statistical information provided by the NFSA during the mission, on average, 54 percent of the relevant events were reported to the national database within seven days of the event occurring. We suggest the following amendments: According to statistical information provided by the NFSA during the mission, on average, 61.5 percent of the relevant events were reported to the national database within seven days of the event occurring. Enclosed statistic’s table for the 12 months period of (June 2007 – May 2008), which shows that an average of 61.5 percent of relevant events were reported to the national database within seven days of the event occurring.
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4.7 Official control related to identification of bovine, ovine and caprine animals
With regard to inspections of slaughterhouses it was not clear, in at least two of the regions visited, whether these were inspected in the same manner as other holdings. The regional office had not distributed any information to the district offices related to such inspections. In another slaughterhouse visited (only slaughtering sheep) the representatives of the NFSA could not confirm whether the slaughterhouse was registered in the central database. NFSA confirm that identification is part of the ante mortem control at the slaughterhouse. The slaughterhouses are registered in the central database. They report slaughtering of cattle on individual base to the central database. Representatives of one of the regional offices visited informed the mission team that slaughterhouses sometimes accepted that animals with restrictions on movements were accepted for slaughter. However, it is possible that the district office can grant derogations from these restrictions. As these derogations are not linked to the central database the information in that database is consequently not always reliable for the slaughterhouses. We would like to clarify that when the district office grants derogations from restrictions, a copy of the decision is sent to the slaughterhouse. In one of the slaughterhouses visited a representative of the NFSA informed the mission team that animals with only one yellow ear tag were accepted at the slaughterhouse. In these cases, the NFSA notified the slaughterhouse. However, incorrect identification was not reported back to the relevant district offices for further follow-up of the holdings. NFSA is aware that such cases can occur, however, the official veterinarians at the slaughterhouses are instructed to inform the relevant local district office, and the district office has to consider a follow-up of the relevant holdings. The following enclosed documents are NFSA’s guidelines for proper identification procedures at the slaughterhouse. During the mission, the NFSA representatives and the mission team became aware of a situation where a farmer had ordered a number of replacement ear tags to animals on the holding, including animals registered in the national databases as slaughtered. The relevant district office was informed of the observations and carried out a check on the holding. Because of the observations made the district office adopted a decision restricting movements of the animals on the holding until compliance with the national requirements could be ensured.
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NFSA’s district office followed up this case closely. The decision to movement restrictions was repealed, when animal identification was insured, and all animals on the holding were correctly ear tagged and registered in the central database. 4.9 Official control related to trade in live animals
Representatives of the NFSA informed the mission team that according to Norwegian requirements goats can be imported to Norway from other EEA States without being placed in isolation. For sheep and cattle it is a general requirement that animals imported from other EEA States must be placed in isolation when arriving at the place of destination in Norway. The NFSA can grant derogation from the isolation requirement, depending on the status of the holding and region of origin compared with the status of the farm of destination. In general isolation is used at the place of destination for animals originating in other EEA countries while quarantine is used for animals imported from third countries. Norwegian regulation requirements do not differentiate between sheep and goat and as the paragraph implies and therefore we suggest the following amendment: According to Norwegian regulation requirements, goats and sheep can be imported to Norway from other EEA States (Sweden, Finland and Denmark) without being placed in Isolation. However, isolation of imported small ruminants from these EEA States is evaluated on a case to case base, for example inadequate health control documentation can be a reason especially as far as Maedi-Visna viral disease is concerned. For cattle it is general requirement that animals imported from other EEA States must be placed in isolation when arriving at the place of destination in Norway.
4.10 Producer of ear tags visited
According to information provided by the NFSA, four producers/distributors of ear tags have been approved for providing ear tags for identification of bovine, ovine and caprine animals in Norway. We suggest the following amendment as NFSA approves ear tags and not producers/ distributors: According to information provided by the NFSA, currently four producers/distributors of ear tags provide NFSA’s officially approved ear tags for the identification of bovine, ovine and caprine animals in Norway.
4.12 Auction markets visited
In one of the markets visited the mission team also observed that animals destined for the auction market could be transported together with animals intended for the nearby slaughterhouse. We suggest amendment of this paragraph as animals transported to auction markets are never accompanied with animals intended for the slaughterhouse. However after the auction has taken place, it may happen that animals not sold at the auction are transported together with sold animals when those are to be
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transported from the auction to the new owner. In such cases the slaughterhouse will always be the last stop.
6.1.2 Commission Decision 2001/672/EC
Commission Decision 2001/672/EC of 20 August 2001 laying down special rules applicable to movements of bovine animals when put out to summer grazing in mountain areas has not been implemented into Norwegian law.
Commission Decision 2001/672/EC applies to the movements of bovine animal within the following Member States or part of these states: France, Italia, Austria and Portugal. The Decision has been incorporated in Annex I Chapter 1 section 1.2 (“application texts”) by mistake. Like other acts addressed to specific Member States, the Decision should rather have been incorporated under “Acts which the EFTA States and the EFTA Surveillance Authority shall take due account”. 6.1.3 Commission Regulation (EC) No 2006/968
Commission Decision 2006/968/EC of 15 December 2006 implementing Council Regulation (EC) No 21/2004 as regards guidelines and procedures for the electronic identification of ovine and caprine animals has not been implemented into Norwegian law.
NFSA suggests elimination of this paragraph Commission Regulation (EC) No 2006/968 is fully implemented in Norwegian Regulation FOR 2008-04-23 nr 395: Forskrift om krav til identifikator, avleser og prøvingslaboratorium i forbindelse med elektronisk identifikasjon av småfe, which entered into force on the 23rd April 2008. Please find enclosed a copy of the regulation. 6.2.4 Controls of holdings
Compliance with Regulation (EC) No 1760/2000 and in particular Article 2 thereof, and with Regulation (EC) No 1082/2003 and in particular Articles 1 and 3(1) thereof, could not be fully ensured since slaughterhouses were not considered as holdings and therefore not controlled.
Identification of animals is part of the ante mortem control. Slaughterhouses report’s slaughtering of cattle on individual base to the central register.
6.3.4 Checks of holdings
Compliance with Regulation (EC) No 21/2004 and in particular Articles 2 and 12(1) thereof, and with Regulation (EC) No 1505/2006 and in particular Article 1 thereof, could not be fully ensured since slaughterhouses were not considered as holdings and therefore not checked.
NFSA confirms that identification of animals is part of the ante mortem control.
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6.4.1 Quarantine and isolation
The requirement of placing cattle and sheep originating in other EEA States in isolation at the place of destination is not in compliance with Directive 90/425/EEC and in particular Articles 1, 5 and 6 thereof.
Norway previously, and in a series of package meetings, during the period 2002 - 2007 has answered this point when raised by ESA. We would like to refer to our latest letter dated 29 January 2007 where the following position was elaborated: Norway does not consider the isolation requirements as it has been described previously and is described once again during this mission to be in conflict with the EEA requirements in Council Directive 90/425/EEC. The isolation requirement is a provision pertaining to surveillance and control of diseases in Norway and is applied to trade in animals whose health status is not sufficiently documented. The decision is therefore taken on a case by case basis and applies to any movement of animals. This is considered to be part of our national surveillance and control system and is not related to import.
Notification of NFSA’s corrective actions:
4.9 Official control related to trade in live animals
In one of the farms visited the mission team observed that animals had been imported from Sweden in 2007. The mission team noted that that the farmer had applied for exemption from the Norwegian requirement for isolation of bovine animals imported from other EEA countries. From the documentation related to this particular import and provided by the NFSA to the mission team during the mission it was not possible to verify whether the district office had checked the passports that should have accompanied the imported animals. Renewed information is posted on NFSA’s intranet website to emphasis regulations and use of bovine passport (July 2008)
6.1.1 Commission Regulation EC (No) 509/1999
Commission Regulation EC (No) 509/1999 of 8 March 1999 concerning an extension of the maximum period laid down for the application of ear-tags to bison (Bison bison spp.) has not been implemented into Norwegian law.
A new Norwegian regulation implementing Commission Regulation EC (No) 509/1999, together with Regulation (EC) No 1760/2000, is currently under preparation and expected to enter into force before 15 January 2009. 6.2.1 Ear tags
Full compliance with Article 1(5) of Regulation (EC) No 911/2004 could not be ensured since it was possible to order ear tags exceeding the need for one year’s use.
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NFSA have now (July 2008) blocked all possibilities to order ear tags exceeding the need for one year’s use throughout the eaters ordering system.
6.2.2 Holding registers
Compliance with Regulation (EC) No 1760/2000 and in particular Article 7(4) thereof could not be fully ensured since the NFSA had not approved the format of the holding registers.
To avoid burdening producers with time consuming registration of information, NFSA is currently reviewing the holding registration formats of the various organisations which bovine producers have membership in. This is done in efforts to approve a written and an electronic format for a holding register which would ensures both, compliance with 1760/2000 requirements, and information required by the producers organisations. NFSA plan to achieve an approved format by the end of 2008.
6.2.3 Holding registers
Compliance with Regulation (EC) No 911/2004 and in particular Article 8(e) thereof could not be ensured since the official inspectors are not signing the registers on the farms when checked.
In addition to comments attached to point 6.2.2 above, insuring official inspectors signature on registers when farms are checked, would be achieved by incorporating a field for signature in the approved format for holdings register. Also by sending instructions to NFSA’s district offices, to emphasis the importance of signing the registers on the farms when checked. 6.2.5 Controls on holdings
Compliance with Regulation (EC) No 1082/2003 and in particular Article 2 thereof, could not be fully ensured since the selection of holdings to be inspected was often not based on a risk analysis.
During a meeting with the Chief Regional Officers in June 2008, it was pointed that inspections regarding identification of animals should be given priority and that these inspections should be based on a risk analysis. Chief Regional Officers were instructed to send Instructions to their district offices on the utilization of these reports for risk analysis and planning of inspections, enclosed a copy of the case formulation which was forwarded to the meeting and the meetings report.
6.2.6 Passports
The requirement that all imported animals from other EEA Countries must at all times after arriving in Norway be accompanied by a passport issued by the NFSA is not in compliance with Regulation (EC) No 1760/2000 and in particular Article 6(3) thereof.
6.2.7 Passports
For one consignment of live animals imported from another EEA States the passport were neither checked nor surrendered to the NFSA at the time of
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arrival of the animals. Compliance with Regulation (EC) No 1760/2000 and in particular Article 6(3) could therefore not be ensured.
: Renewed information posted on NFSA’s intra-net website to emphasis regulations regarding use of bovine passport. Attached is a copy of the information posted on the intranet July 2008. 6.2.8 Labelling of beef products
Compliance with Regulation (EC) No 1760/2000 and in particular Article 13(1) thereof could not be ensured since beef products were not labelled so that a link was established between the beef and the animal/group of animals concerned.
NFSA’s District Offices are the competent authority responsible for controlling that beef products are labelled so that a link could be established between the beef and the animal/group of animals concerned, they have the authority to take appropriate measures in cases of non compliance. NFSA acknowledge this short coming observed during ESA’s inspection and has planed it as an item on agenda for next Head Office meeting with the Chief Regional Officers scheduled during September 2008. This is planed in action to prompt district offices to take more effective measures for ensure compliance with legislations.
6.2.9 Sanctions
Compliance with Regulation (EC) No 494/98 and in particular Article 4 thereof could not be ensured since the NFSA had not taken appropriate measures when farmer had failed to respect the deadline set out in Article 7(1) of Regulation (EC) No 1760/2000.
In the meeting with the Chief Regional Officers in June 2008, it was pointed that inspections regarding identification of animals should be given priority and that these inspections should be based on a risk analysis. It was further pointed that sanctions should be used in case of non-compliance. Enclosed a copy of the case
report, which was forwarded to the meeting, and the meeting’s report.
NFSA has also considered the obligation to fine farmers who don’t respect the deadline of 7 days to report actions to the central database. This action will require a new regulation, which NFSA is going to start with by autumn 2008.
NFSA’s further actions: During May 2008 negotiations between The Ministry of Agriculture and The Farmers Associations reached an agreement on the use of information in the central register (cattle register) as information database for calculating state subsidies (page 21 attached document). A schedule for how and when to effectuate this was part of the negotiations. When fully operated, the number of days each cattle has been on the holding will be used as the basis for calculating the subsidies. This information will be extracted from information registered in the central register (cattle register). A pilot project is planed during August 2009 and expected to be fully operable in August 2011. Please find enclosed a copy of
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meeting’s report and the plan for using the central register as an information database. 6.3.1 Registration of movements of ovine and caprine animals
Compliance with Regulation (EC) No 21/2004 and in particular Article 8(2) thereof could not be ensured since information about movements of ovine and caprine animals were not provided to the competent authority.
Information about movements of ovine and caprine would be insured after the integration of the central register into MATS21.This is expected to be achieved within 6 months. Please find enclosed recent information on MATS posted on NFSA’s intranet. 6.3.2 Holding registers
Compliance with Regulation (EC) No 21/2004 and in particular Article 3(1)(b) thereof could not be ensured since holding registers were not established or used.
6.3.3 Holding registers
Compliance with Regulation (EC) No 21/2004 and in particular Article 5(3) thereof could not be ensured since the format of the holding register was not approved by the competent Authority. Article 3(1)(b) requires an “ up-to-date registers kept on each holding”. Article 5(3) requirement “the register shall be in a format approved by NFSA”.
To avoid burdening producers with time consuming registration of information, NFSA is currently reviewing the holding registration formats of the various organisations which ovine and caprine producers have membership in. This is done in efforts to approve written and electronic holding register formats which would ensures both, compliance with 21/2004 requirements, and information required by the producers organisations. NFSA aims to advice and control the keeping of an up-to date registers on each holding after it have an approved format for a holding register by the end of 2008. Yours Sincerely Kristina Landsverk Deputy Director General
• 21 MATS is a workflow system that supports the control activities of NFSA . When fully
implemented it will support all control activities carried out in the field by NFSA inspectors across
all areas of control, MATS will also provide extensive reporting capabilities.