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FOOD STANDARDS AGENCY GUIDANCE NOTES ON ARTICLES 14-16 and 18-20 OF

THE GENERAL FOOD LAW REGULATION (EC) 178/2002 Introduction 1. These Guidance Notes have been produced with the aim of providing

informal, non-statutory advice on compliance with the requirements of Articles 14-16 and 18-20 of Regulation (EC) 178/2002.

2. We have taken account of the previous Food Standards Agency Guidance

Notes on this Regulation issued on 10 March 2005. These previous Guidance Notes included EC Guidance issued on 20 January 2005. We have also taken account of the responses to the public consultation on the EC Guidance in July 2005. The FSA view is that these new Guidance Notes are more appropriate for food businesses in the UK.

3. The notes should be read in conjunction with the Food Safety Act 1990

(Amendment) Regulations 2004 (No. 2990), the General Food Regulations 2004 (No. 3279)1 or, as appropriate, the Feed (Hygiene and Enforcement) Regulations 2005 (see Annex). Food and feed businesses are required to comply with these articles, which are about safety of food and feed, traceability, notification of food and feed safety incidents and withdrawal and recall of unsafe food and feed.

4. These Notes and the examples in them should not be taken as an

authoritative statement or interpretation of the law, as only the Courts can decide whether, in particular circumstances, an offence has been committed under the relevant Regulations. It is the responsibility of individual organisations to ensure their compliance with the law. Organisations with specific queries may wish to seek further advice from their home Food or Feed Authority, i.e.

• their local authority2; • for imported food but not feed, their port health authority3;

• the Food Standards Agency; or

• in relation to feed in Northern Ireland, the Department of Agriculture

and Rural Development (DARD). Purpose of Regulation (EC) 178/2002

1 In Northern Ireland, the Food Safety (Northern Ireland) Order 1991 (Amendment) Regulations (Northern Ireland) 2004 (No. 482) and the General Food Regulations (Northern Ireland) 2004 (No. 505). 2 In Northern Ireland district councils only. 3 Ibid.

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5. Regulation (EC) 178/2002 of the European Parliament and of the Council, lays down the general principles and requirements of food law, establishes the European Food Safety Authority and lays down procedures in matters of food safety. It came into force on 21 February 2002, although certain key provisions applied only from 1 January 2005. The principal aim of this Regulation is to protect human health and consumers’ interests in relation to food.

6. It applies to all stages of production, processing and distribution of food

and feed, but there is an exemption for primary production for private domestic use, and the domestic preparation, handling, or storage of food for private domestic consumption.

Definitions 7. A number of terms are defined in Articles 2 and 3 of the Regulation and,

since they are used in the Guidance, these are included here for ease of reference. For the purposes of Regulation (EC) 178/2002:

• ‘food’ or (‘foodstuff’) means any substance or product, whether

processed, partially processed or unprocessed, intended to be, or reasonably expected to be ingested by humans. ‘Food’ includes drink, chewing gum and any substance, including water, intentionally incorporated into the food during its manufacture, preparation or treatment. It includes water after the point of compliance as defined in Article 6 of Directive 98/83/EC and without prejudice to the requirements of Directives 80/778/EEC and 98/83/EC.

‘Food’ shall not include: (a) feed;

(b) live animals unless they are prepared for placing on the market for

human consumption;

(c) plants prior to harvesting;

(d) medicinal products within the meaning of Council Directives 65/65/EEC and 92/73/EEC;

(e) cosmetics within the meaning of Council Directive 76/ 768/EEC;

(f) tobacco and tobacco products within the meaning of Council

Directive 89/622/EEC;

(g) narcotic or psychotropic substances within the meaning of the United Nations Single Convention on Narcotic Drugs, 1961, and the United Nations Convention on Psychotropic Substances, 1971;

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(h) residues and contaminants. • ‘food law’ means the laws, regulations and administrative provisions

governing food in general, and food safety in particular, whether at Community or national level; it covers any stage of production, processing and distribution of food, and also of feed produced for, or fed to, food producing animals;

• ‘food business’ means any undertaking, whether for profit or not and

whether public or private, carrying out any of the activities related to any stage of production, processing and distribution of food;

• ‘food business operator’ means the natural or legal persons

responsible for ensuring that the requirements of food law are met within the food business under their control;

• ‘feed’ (or ‘feedingstuff’) means any substance or product, including

additives, whether processed, partially processed or unprocessed, intended to be used for oral feeding to animals;

• ‘feed business’ means any undertaking whether for profit or not, and

whether public or private, carrying out any operation of production, manufacture, processing, storage, transport or distribution of feed including any producer producing or storing feed for feeding to animals on his own holding;

• ‘feed business operator’ means the natural or legal person

responsible for ensuring that the requirements of food law are met within the feed business under their control;

• ‘retail’ means the handling and/or processing of food and its storage at

the point of sale or delivery to the final consumer, and includes distribution terminals, catering operations, factory canteens, institutional catering, restaurants and other similar food service operations, shops, supermarket distribution centres and wholesale outlets;

• ‘placing on the market’ means the holding of food or feed for the

purpose of sale, including offering for sale or any other form of transfer, whether free of charge or not, and the sale, distribution, and other forms of transfer themselves;

• ‘risk’ means a function of the probability of an adverse health effect and

the severity of that effect, consequential to a hazard; • ‘risk analysis’ means a process consisting of three interconnected

components: risk assessment, risk management and risk communication;

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• ‘risk assessment’ means a scientifically based process consisting of four steps: hazard identification, hazard characterisation, exposure assessment and risk characterisation;

• ‘risk management’ means the process, distinct from risk assessment,

of weighing policy alternatives in consultation with interested parties, considering risk assessment and other legitimate factors, and, if need be, selecting appropriate prevention and control options;

• ‘risk communication’ means the interactive exchange of information

and opinions throughout the risk analysis process as regards hazards and risks, risk related factors and risk perceptions, among risk assessors, risk managers, consumers, feed and food businesses, the academic community and other interested parties, including the explanation of risk assessment findings and the basis of risk management decisions;

• ‘hazard’ means a biological, chemical or physical agent in, or condition

of, food or feed with the potential to cause an adverse health effect; • ‘traceability’ means the ability to trace and follow a food, feed, food

producing animal or substance intended to be, or expected to be incorporated into a food or feed, through all stages of production, processing and distribution.

Article 14 (Food safety requirements) What the Article says 8. This Article prohibits food being placed on the market if it is unsafe. It is

deemed to be unsafe if it is considered to be:

(a) injurious to health; (b) unfit for human consumption.

9. Although these terms were used in Section 8 of the Food Safety Act

19904, their meaning in the Regulation is not necessarily the same and will be determined by the European Court. The factors listed in Article 14 (3)-(5) were not part of Section 8 and are new to UK food law. These factors should be taken into account when determining whether food is injurious or unfit. Food that is considered to be either ‘injurious to health’ or ‘unfit’ is deemed to be unsafe under Article 14(2), and it follows that such food is subject to the withdrawal, recall and notification requirements of Article 19.

4 Article 7 of the Food Safety Order (Northern Ireland) Order 1991.

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10. There is no longer an offence under Section 8 of the Food Safety Act 1990

of selling food which fails to comply with the food safety requirements. Instead, an offence of failing to comply with the food safety requirements of Article 14(1) is created by Regulation 4(b) of the General Food Regulations 20045, as amended (see Annex).

How we believe businesses can comply 11. The food safety requirements in Article 14 apply to sales and supplies,

including one-off sales and supplies free of charge. The requirements of this Article are not limited to ‘food business operators’. The aim is to protect public health by covering all eventualities, with the exception of private domestic consumption, which is exempted by Article 1(3). It should be noted that this exemption does not extend to food produced by individuals for charitable and similar events.

12. Article 14(3) – 14(5) indicate what factors need to be taken into account

when determining whether food is injurious to health or unfit. Article 14(3) requires that the normal conditions of use of the food, such as cooking, should be taken into account. Article 14(4) requires that the particular health sensitivities of specific categories of consumers be taken into account where the food is intended for that category of consumers. So, for example, food intended for consumers requiring a gluten-free diet could be considered to be injurious if it were found to contain gluten.

13. Conversely, the general requirement not to market unsafe food is not

breached simply because a certain group of people are particularly susceptible to be injured by it. Food intended for general consumption is not injurious for the purposes of this Article because some people are allergic or intolerant and so liable to be injured by it.

Food that is injurious to health 14. Once a hazard is identified which might make food injurious to health, an

assessment of the associated risk should be carried out, taking the factors in Article 14(3) and (4) into account. Not all hazards that might be found in food are controlled by specific regulations. Food could be injurious to health without exceeding a particular legal limit. For example, this could apply when glass, which is not a specifically banned substance, is found to be present in food, or if, for example, a hazardous chemical not specifically identified by legislation on contaminants in food is found to be present. The key point is that once a hazard of any kind has been identified, the need to assess the risk is paramount.

15. When there are concerns that a particular food may be injurious to health,

food businesses then have to consider how serious the risk is. Risk assessment in this context means addressing two key questions:

5 In Northern Ireland, the General Food Regulations (Northern Ireland) 2004 (No. 505).

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• what is the harm that might be caused?

• how likely is it? 16. There is a range of reputable, expert organisations that are able to advise

on particular cases. Food that is unfit 17. The central concept of unfitness is unacceptability. Food can be rendered

unfit by reason of contamination, by the presence of foreign objects, by unacceptable taste or odour as well as by more obvious detrimental deterioration such as putrefaction or decomposition.

Food not in compliance with food safety legislation 18. Where food is found to be in breach of specific legislation governing its

safety, it will be presumed to be either injurious to health or unfit for human consumption and thus ‘unsafe’ for the purposes of Article 14. For example, a breach of a particular legal limit within legislation on contaminants in food would raise the presumption that the food was unfit for human consumption in the light of Article 14(5). In such a case, an assessment should still be carried out, considering the factors in Articles 14(3)-(5) in the light of the legislation on contaminants in food. If that assessment shows that the food is neither injurious to health nor unfit for human consumption it would not be regarded as unsafe for the purposes of Article 14. However, it would still be in breach of the legislation on contaminants in food.

Article 15 (Feed safety requirements) What the Article says 19. This article prohibits feed being placed on the market if it is unsafe, i.e. if it

either:

(a) has an adverse effect on human or animal health;

(b) makes the food derived from food-producing animals unsafe for human consumption.

20. The definition of unsafe (for human consumption) is that in Article 14(2). 21. Animal feed is deemed to be safe if it complies with specific Community

provisions governing feed safety, where such Community provisions exist. The provisions include, for example, maximum permitted levels of undesirable substances (contaminants such as lead, arsenic or aflatoxin B1), conditions governing the authorisation, marketing and use of feed additives, and prohibitions on certain ingredients. However, enforcement

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authorities may also impose restrictions on, or require the withdrawal of, consignments of feed if they believe that the feed is unsafe even though it otherwise complies with feed law requirements. The decision to impose restrictions or require withdrawal will be a matter of judgement by the enforcement authority.

22. The feed safety requirements of this Article apply to all stages of the

production, transport, storage, supply and sale of animal feed, including producers producing, processing or storing feed for feeding their own animals, one-off sales and supplies free of charge. The aim is the protection of both animal and human health, in the latter case by ensuring the safety of animal products (meat, dairy products and eggs) for human consumption.

How we believe businesses can comply 23. Where a potential hazard in feed has been identified, the feed business

operator should carry out an assessment to ascertain if food derived from food-producing animals which have been given that feed is safe. This assessment should take into consideration all available information, including any maximum permitted levels for substances causing the potential hazard, where such limits exist.

24. It should be noted that in addition to this requirement under Regulation

(EC) 178/2002, offences are committed by anyone who places on the market animal feed which does not meet the requirements of other feed legislation, e.g. feed that exceeds maximum permitted levels of undesirable substances.

Article 16 (Presentation) What the Article says 25. This Article stipulates that the labelling, advertising, and presentation of

food shall not mislead consumers. The Article applies to those involved in occasional events as well as to food businesses. The wording of Article 16 says that it is without prejudice to more specific provisions of Community law. Therefore, Article 16 is an additional measure. It does not overrule or otherwise affect other legal provisions, whether at Community or national level, and so applies additionally to the Trade Descriptions Act 1968 and Section 15 of the Food Safety Act 19906. Section 15, which implements the requirements of Article 2 of the Food Labelling Directive 2000/13, continues in place. Unlike Section 15, Article 16 applies in case of a one-off supply free of charge, subject to the exemption in Article 1(3) for private domestic use.

6 Article 14 of the Food Safety (Northern Ireland) Order 1991.

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26. Article 16 also applies to the labelling, advertising and presentation of feed. There are also other provisions on the labelling of feeds, which are set out in Schedule 3 of the Feeding Stuffs Regulations 2005.

How we believe businesses can comply 27. This Article covers misleading labelling and advertising. It also covers

cases where a consumer is misled as to the nature, substance or quality of the food by the setting in which food is displayed. This could apply, for example, if a synthetic cream cake was displayed in a chill cabinet in such a way as to give the impression that it contained fresh dairy cream.

Article 18 (Traceability) What the Article says 28. Under this Article, food and feed businesses are required to

• identify their suppliers of food, feed, food-producing animals and any other substance for incorporation into food or feed,

• identify the businesses to which they have supplied products, and

• produce this information to the competent authorities on demand. 29. The requirements of Article 18 of the Regulation apply to food and feed

business operators at all stages of the food chain. This includes primary producers, manufacturers, wholesalers, retailers, transporters, distributors, those dealing in the purchase and sale of bulk commodities, and caterers. A food or feed business would also include any business that trades in food or feed, even if they do not take physical possession (food/feed broker). Also included are charities where these meet the definition of food business, and businesses importing from third countries, even though their supplier is not within the EU. The requirements do not, however, extend to suppliers in third countries.

30. The products covered are ‘food, feed, food-producing animals, and any

other substance intended to be, or expected to be, incorporated into a food or feed.’ So, for example, seeds will be subject to the traceability requirements only if these go directly into a food product. Live animals supplied for eventual use in food would constitute “food producing animals” and would be subject to the traceability requirements. Veterinary medicines, pesticides and fertilisers do not fall within the scope of the Regulation as they are not within the definition of ‘food’ under Regulation (EC) 178/2002.

How we believe businesses can comply

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31. Taken at face value, the only information Article 18 requires food and feed business operators to provide is the name of businesses who supply them and to whom they supply their products, i.e. one step back – one step forward. However, EC law should be interpreted according to its purpose, and account has to be taken of the relevant recitals and role of Article 18 in supporting the notification requirements of Articles 19 and 20. It follows that, as a minimum, traceability records should also include the address of the customer or supplier, nature and quantity of products, and the date of the transaction and delivery. It is expected that the provision and retention of this type of information is already standard practice in basic invoicing.

32. This requirement should not be taken as meaning that businesses

necessarily need a dedicated traceability system. It is the need to produce information that is important, not the format in which it is kept.

33. Article 18 requires that the traceability records be made available on

demand. As the purpose of the traceability provision is to assist with withdrawals and recalls of unsafe food, food and feed businesses should have their records sufficiently organised and available to be produced within the short timescale needed for them to be of use in any such withdrawal or recall.

34. The Regulation does not specify how long traceability records should be

kept. Again, this article should be interpreted according to its purpose in supporting the notification requirements of Article 19. It is for businesses to decide how long they should keep their records, bearing in mind the nature of the food or feed, its product life, and the circumstances under which they might be required to produce records, should a notification under Articles 19 or 20, or assistance to enforcement authorities, be subsequently required. However, failure to produce such documentation constitutes an offence.

35. Food retailers are not required to keep records of sales to the final

consumer (since consumers are not food businesses). Wholesalers supplying to retail outlets are required to keep records. Where a retailer knows that it is supplying to another food business, for example a catering outlet, traceability requirements should be adhered to. Caterers such as restaurants will need to keep traceability records of inputs, but will not be required to keep records of supplies to the final consumer.

36. The traceability requirements of Article 18 apply without prejudice to more

detailed sector specific requirements. These include the mandatory labelling requirements at the point of sale for fresh and frozen beef; the mandatory cattle identification and registration scheme and the rules relating to consumer information for fish and fish products sold at retail, where commercial documentation (e.g. sales note, invoice) is the usual means of providing this information through the chain.

37. Article 18 does not require internal traceability, i.e. the matching up of all

inputs to outputs. Nor is there any requirement for records to be kept

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identifying how batches are split and combined within a business to create particular products or new batches. For example, a cake manufacturer would not need to specify which batch of flour went into which cakes.

38. Other EC feed legislation (Regulation (EC) Feed Hygiene 183/2005)

specifies in more detail the information that must be recorded by different categories of feed business operators to ensure traceability. This requirement is set out in the record-keeping sections of Annexes I and II of Regulation 183/2005.

Article 19 (Withdrawal, recall, and notification of food) What the Article says 39. This places obligations on food businesses to recall, and/or withdraw, food

from the market if it is not in compliance with the food safety requirements of Article 14, to notify competent authorities (their Home Authorities and the Food Standards Agency), and to collaborate with these authorities on action taken to avoid or reduce risks posed by the food.

40. Article 19(1) requires that, where a food business operator considers or

has reason to believe that a food which it has imported, produced, processed, manufactured or distributed is not in compliance with the food safety requirements, and has left the immediate control of the initial food business, the food should be withdrawn from the market and notified to the competent authorities. (Article 19(3) identifies where there is an obligation to notify immediately.)

41. The obligation to withdraw/recall arises when a food business operator

considers or has reason to believe that a food is unsafe. The test is an objective one. Where products may have reached the consumer, there is an obligation on food businesses to inform consumers effectively and accurately of the reason for the withdrawal of the product and where necessary recall products already supplied. The reason given should provide details as to why the product is unsafe.

42. Article 19(2) imposes a requirement on food business operators

responsible for retail or distribution activities, which do not affect the packaging, labelling, safety or integrity of food. The purpose of this provision is to ensure that such food business operators also play their part in the withdrawal of food not in compliance with food safety requirements, and in passing on relevant information.

43. Article 19(3) imposes an obligation on food business operators to inform

the competent authorities immediately if food that they have placed on the market may be injurious to human health (see Definitions section for clarification of ‘placing on the market’).

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44. Article 19(4) requires that food business operators co-operate with the competent authorities on action taken to avoid or reduce risks posed by a food that they supply or have supplied.

How we believe businesses can comply Withdrawal/Recall 45. For the purposes of these Guidance Notes, the terms ‘withdrawal’ and

‘recall’ mean:

• ‘Withdrawal’ means the process by which a food is removed from the market up to and including the retail stage, and including action by food producers, packers, distributors, wholesalers and retailers, as appropriate.

• ‘Recall’ means the process by which consumers are advised, for

example, by means of public notices and other publicity, to return food supplied to them.

46. Food Business Operators must as a minimum withdraw from the market

food failing to meet the food safety requirements specified in Article 14. Where this is insufficient to provide the required level of health protection to consumers, they must recall the product.

47. The withdrawal of food from the market may take place at any step along

the food chain and not only at time of delivery to the end consumer. The obligation to withdraw from the market applies when the following two cumulative criteria are met:

• When a food is considered by the operator (at any stage of the chain)

as being unsafe (Article 14). In making this judgement, the operator will need to consider the normal conditions of use of the food by the consumer and at each stage of production, processing and distribution.

• Where the food has left the immediate control of that food business

operator. 48. The wording “has left the immediate control of that initial food business

operator” stresses that the initial food business operator is no longer able to take action by itself to remedy the non-compliance, but needs to request/require co-operation from other operators it has supplied. The words “of the initial food business operator” are important. It means that the food has left, for example, the processing unit and is in the hands of another operator (change of step inside the food chain).

49. We consider that it is the responsibility of any ethical business to let

suppliers know of any problems in order to protect human health. If an operator considers that a raw material or an ingredient is not compliant with food safety requirements, it should inform its supplier of this non-

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compliance. The supplier will then have reason to consider or to believe that a food not under its immediate control is non-compliant with the food safety requirements. This supplier should, therefore, withdraw the affected food from the market and notify this withdrawal to the competent authorities.

50. Where retailers sell a branded product that does not meet the food safety

requirements, the brand owners will be responsible for notification and withdrawal/recall, but the retailer is required to co-operate as necessary under Article 19(2).

51. In addition to the requirements of Article 19(1), competent authorities can

advise food business operators to withdraw a food which is under their immediate control whenever such measures are justified.

Notifying competent authorities 52. When a food business operator withdraws a food in accordance with

Article 19(1), it should notify this withdrawal to the competent authorities. Where products may have reached the consumer, a food business must also inform consumers of the reason for the withdrawal of the product and, if necessary, recall from consumers products already supplied to them.

53. If food that does not meet food safety requirements has not left the

immediate control of the food business operator, removal of the food from the food chain does not constitute a withdrawal and there is therefore no obligation to notify the competent authority.

54. Important: Article 19 (3) states that if an operator at any stage of the food

distribution chain considers that food which it has placed on the market may be injurious to health, they shall immediately notify the competent authorities and detail the action taken to prevent the risk. The assessment as to whether the food might be injurious to health should be objective (see paragraph 13). Under Article 19(3), operators are also required not to prevent or discourage anyone from co-operating with the competent authorities to prevent, reduce or eliminate the risk arising from a food.

55. Businesses should submit the necessary information under Article 19(1) or

19(3) to the Agency’s Incidents Branch (http://www.food.gov.uk/foodindustry/foodfeedform or fax: 020 7276 8446), to the local authority where the food business operator is based, and in the case of imports, the relevant port health authority.

Article 20 (Withdrawal, recall, and notification of feed) What the Article says 56. This places obligations on feed business operators to recall and/or

withdraw feed from the market if it is not in compliance with feed safety

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requirements (see paragraph 17 above), and to notify competent authorities.

How we believe businesses can comply 57. A feed business operator which considers or has reason to believe that a

feed which it has imported, produced, processed, manufactured or distributed does not comply with feed safety requirements should withdraw it from the market and notify the competent authorities. Operators responsible only for feed retail and distribution activities should still initiate recall action of affected product that it has in its possession or has distributed.

58. All feed business operators must immediately inform the competent

authorities (the enforcement authority and the Food Standards Agency) if it has reason to believe that a feed placed on the market may not satisfy feed safety requirements and indicate the action being taken to prevent the risk arising from the use of the feed. All feed business operators are required to co-operate with the action being taken by other feed business operators and competent authorities. This will include passing on information to enable affected products to be traced.

59. The notification procedure for feed incidents is the same as for food

incidents (see paragraph 54.) Enforcement 60. Regulation 3 of the General Food Regulations 2004 designates food

authorities, port health authorities, and the Food Standards Agency as the competent authorities in relation to food7. Enforcement authorities are specified in Regulation 6 as food authorities or port health authorities in relation to Articles 14, 16, 18 and 19 of Regulation (EC) 178/2002. The Agency is specified as an additional enforcement authority in relation to Articles 14 and 19 to allow, for example, for the flexibility of the Meat Hygiene Service enforcing Regulation 178/2002 requirements in meat plants, where this would be more effective.

61. This means that port health authorities or local authorities8 are responsible

for enforcing all provisions. However, the Agency is an additional enforcement authority in relation to the enforcement of the food safety requirements, and also recall, withdrawal and notification requirements under Article 19 under certain circumstances. This is to allow, for example, for the flexibility of the Meat Hygiene Service enforcing these requirements in meat plants, where this would be more effective.

7 Regulation 3 of the General Food Regulations (Northern Ireland) 2004 designates district councils only. 8 Ibid.

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62. The Regulations also specify offences in relation to the above requirements and impose penalties for these offences. These penalties are consistent with those currently in operation under the Food Safety Act 19909 for food law offences.

63. In Great Britain, local authorities (mainly trading standards departments)

are responsible for enforcing the feed provisions of Regulation (EC) 178/2002. In Northern Ireland, the enforcement authority is the Department of Agriculture and Rural Development. This duty to enforce the provisions is set out in the Feed (Hygiene and Enforcement) Regulations 2005. There are separate Regulations for England, Scotland, Wales and Northern Ireland. These Regulations also specify offences for contravention of the feed provisions of Regulation (EC) 178/2002 and related penalties.

Further information about these Guidance Notes 64. Enquiries about, and further copies of these Guidance Notes may be

obtained from: Bill Drennan Room 115C Food Law Policy Branch Food Standards Agency Aviation House 125 Kingsway London WC2B 6NH

Tel: 020 7276 8138 Fax: 020 7276 8193 E-mail: guidance@foodstandards.gsi.gov.uk 65. Any queries specific to feed should be addressed to:

Joseph Nicholas Room 415B Animal Feed Unit Food Standards Agency Aviation House 125 Kingsway London WC2B 6NH

Tel: 020 7276 8462 Fax: 020 7276 8478 E-mail: joseph.nicholas@foodstandards.gsi.gov.uk 66. In Northern Ireland, for general queries please contact:

9 In Northern Ireland, the Food Safety (Northern Ireland) Order 1991.

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Trevor Williamson General Food Hygiene and Incidents Unit Food Standards Agency Northern Ireland 10c Clarendon Road Belfast BT1 3BG

Tel: 028 9041 7713 Fax: 028 9041 7728 e-mail: trevor.williamson@foodstandards.gsi.gov.uk 67. In Scotland, for general queries please contact:

Jacqui Bunyan Local Authority Food Law Enforcement Branch Food Standards Agency Scotland 6th Floor, St Magnus House 25 Guild Street Aberdeen AB11 6NJ

Tel: 01224 285175 Mobile: 07876 131648 e-mail: jackie.bunyan@foodstandards.gsi.gov.uk 68. In Wales, for general queries please contact:

Phil Morgan Food Standards Agency Wales 11th Floor Southgate House Wood Street Cardiff CF10 1EW

Tel: 029 2067 8913 e-mail: phil.morgan@foodstandards.gsi.gov.uk

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ANNEX Legislation relevant to Regulation (EC) 178/2002 1. The draft Regulation was subject to an extensive consultation process with

stakeholders. It was published in the Official Journal No. L 31 on 1 February 2002, and can be accessed via the Commission’s web site at:

http://europa.eu.int/eur-lex/en/archive/2002/l_03120020201en.html 2. Although as a Regulation it is directly applicable in Member States, there

was a need to introduce new enforcement powers and penalties in relation to the new obligations on food and feed businesses in Articles 14 – 20 of Regulation (EC) 178/2002, which have applied from 1 January 2005. The necessary changes to domestic food and feed law have been effected by means of Statutory Instruments under the Food Safety Act 199010, the Agriculture Act 1970 and the European Communities Act 1972.

Food Safety Act 1990 (Amendment) Regulations 200411

3. These Regulations are made under the European Communities Act 1972.

The case law of the European Court of Justice makes clear that it is not open to Member States to retain provisions in national legislation in so far as they duplicate, gloss or conflict with directly applicable provisions of EU Regulations. These Regulations therefore narrow the scope of the public consultation requirement in Sections 40 and 48 of the Food Safety Act 199012 so that it does not apply in cases where the public consultation requirements of Article 9 of Regulation (EC) 178/2002 apply.

4. The Food Safety Act 1990 (Amendment) Regulations 2004 bring in the

new definition of ‘food’ contained in Regulation (EC) 178/2002 (see Definitions). This new definition excludes medicinal products within the meaning of Directive 2001/83/EC. This meaning is based on the presentation of a product as treating or preventing disease in humans, or its use with a view to correcting, restoring or modifying physiological function. However, certain borderline products for medicinal use which are not medicinal products within the meaning of Directive 2001/83/EC are now included in the new definition. It will continue to fall to the Medicines and Healthcare Products Regulatory Agency (MHRA), on behalf of the UK licensing authority, to determine whether a product is a medicinal product within the meaning of the Medicines Directive on a case by case basis, having regard to the overall presentation and function of the product.

5. The new definition of food automatically applies to other legislation that

uses the previous definition in the Food Safety Act 1990, for example the Food Standards Act 1999 and the Food and Environment Protection Act 1985, as well as to Regulations and Orders made under all these Acts.

10 In Northern Ireland, the Food Safety (Northern Ireland) Order 1991. 11 Ibid. 12 Articles 39 and 47 of the Food Safety (Northern Ireland) Order 1991.

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6. The revised definition of food excludes live animals unless they are

prepared for placing on the market for human consumption, oysters for example.

General Food Regulations 2004 (as amended by the Official Feed and Food Controls (England) Regulations 2005)13

7. The main purpose of these Regulations is to create offences under UK law

and provide enforcement powers in respect of obligations applying from 1 January 2005 under Regulation (EC) 178/2002. These are Articles 12, 14, 16 (in so far as it relates to food), 18 (in so far as it relates to food business operators), and 19.

8. ‘Food business’ and ‘food business operator’ are defined in Article 3.2 and

3.3 of Regulation (EC) 178/2002. In particular, ‘food business’ means ‘any undertaking, whether for profit or not, and whether public or private, carrying out any of the activities related to any stage of production, processing and distribution of food’. The expression ‘stages of production, processing and distribution’ is defined in Article 3.16 and covers all stages from and including primary production (as defined in Article 3.17) up to and including sale or supply to the final consumer. For example, the activities of farmers, importers, manufacturers, wholesalers, distributors, transporters, retailers and caterers are covered.

9. The extent to which home-producers or charities fall within the definition of

‘food business’ will need to be decided on a case-by-case basis. The definition uses the expression ‘an undertaking’, which implies a certain continuity of activities and a certain degree of organisation. If you have any doubt as to whether you operate a food business or not, then you might wish to consult their Home Authority for further advice.

Feed (Hygiene and Enforcement) Regulations 2005 10. These Regulations create offences and penalties in relation to the feed

provisions of Regulation (EC) 178/2002. These are Articles 12, 16 and 18 (in so far as it relates to feed or feed business operators) and Articles 15 and 19. The Regulations also designate the authorities responsible for enforcing the provisions and provide those authorities with enforcement powers (e.g. powers of entry, seizure and detention of suspect feed).

Legislation in the devolved administrations 11. Following the process of devolution, food and feed legislation is now

commonly made on a separate basis in England, Scotland, Wales and Northern Ireland. However, it was decided that it would be appropriate for the Regulations enforcing food aspects of Regulation (EC) 178/2002 to apply to Great Britain. Details of the separate Regulations applying in

13 In Northern Ireland, the General Food Regulations (Northern Ireland) 2004 (No. 505) as amended by the Official Feed and Food Controls Regulations (Northern Ireland) 2006.

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DRAFT

Northern Ireland, which differ only in the powers under which they are made, and the food authorities given the responsibility for enforcement, can be found in the footnotes. There are separate Regulations enforcing feed aspects of Regulation (EC) 178/2002 for England, Northern Ireland, Scotland and Wales.

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PARTIAL REGULATORY IMPACT ASSESSMENT: DRAFT FOOD STANDARDS AGENCY GUIDANCE ON GENERAL FOOD LAW REGULATION (EC) 178/2002 TITLE OF PROPOSAL 1. Food Standards Agency (FSA) Guidance Notes on Articles 14-16 and 18-

20 of the General Food Regulation (EC) 178/2002 (subsequently referred to as ‘the Regulation’.)

PURPOSE AND INTENDED EFFECT OF MEASURE Objective 2. This Regulatory Impact Assessment (RIA) represents our analysis of the

impact of introducing national guidance. The Agency view is that these new Guidance Notes are the most appropriate guidance for food businesses in the UK.

3. These new FSA Guidance Notes provide advice on compliance with legal

requirements covering food and feed safety, traceability provisions and the need to notify, withdraw and/or recall products not conforming with the food and feed safety requirements applying under the Regulation.

4. Stakeholder comments will be used to determine whether the guidance in

these Notes is proportionate. Responses refining our preliminary estimates of the costs and benefits of the Guidance Notes or highlighting costs and benefits that do not feature in this RIA are particularly welcome.

Background 5. Regulation (EC) 178/2002, laying down the general principles and

requirements of food law, establishing the European Safety Authority and laying down procedures in matters of food safety, came into force on 21 February 2002. The draft Regulation was subject to an extensive consultation process with stakeholders in 2001. It was published in the Official Journal No. L 31 on 1 February 2002, and can be accessed via the European Commission’s web site at

http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32002R0178:EN:HTML

6. Whilst the Regulation came into force on 21 January 2002, certain key

provisions applied only as from 1 January 2005. These included new food and feed safety requirements, new traceability requirements and measures to ensure effective product recall/withdrawals and notification to competent authorities.

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7. Although the Regulation was directly applicable in Member States, there was still a need to make changes to domestic legislation, to introduce new enforcement provisions and to ensure conformity with EU law.

8. FSA Guidance Notes on the new food requirements were originally issued

on 31 December 2004. EC Guidance was issued on 20 January 2005, which replaced the Food Standards Agency guidance on Articles 11, 12 and 16-20. An amended version of the FSA Guidance Notes on this Regulation was issued on 10 March 2005, which referred to and included a copy of the EC Guidance. The current FSA Guidance Notes have taken account of all this previous guidance.

9. In July 2005 the Agency consulted on how the EC Guidance had been

working in practice. In view of the responses to this consultation exercise and the extra costs the food industry said it was incurring due to following the EC Guidance, the Agency has decided to issue its own guidance, which it believes is the most appropriate guidance for food businesses in the UK.

Rationale for Government Intervention 10. In the responses to the consultation in July 2005, some stakeholders

commented that following the best practice recommendations in the EC Guidance would incur substantial costs due to the length of time records should be kept and unnecessary burdens resulting from the need to produce traceability records immediately on demand. These recommendations are not specified in the legislation itself.

11. The new FSA Guidance Notes address these concerns and include

• greater discretion to food businesses over time requirements for keeping traceability records;

• changing the need for immediate production of traceability records in

certain cases to a need to produce these within “a short timescale”; and

• concentrating on the requirements of the legislation and providing

minimal advice on good practice. 12. The overall aim is to have informative and accurate guidance on the

Regulation, so that the public health protection offered by the Regulation is achieved without imposing disproportionate burdens on either business or enforcers.

CONSULTATION • Within Government

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13. The Agency is consulting with the Cabinet Office, the Small Business Service, the Department for Environment, Food and Rural Affairs and the Department of Trade and Industry. The Agency has also consulted the European Commission on the status of the EC Guidance.

• Public Consultation 14. There was extensive public consultation during the negotiations on the

Regulation in 2001. This was followed by a public consultation on domestic enforcing legislation and FSA Guidance Notes, which took place in August 2004. Regulatory Impact Assessments were produced for both of these consultation exercises, which concluded that the cost implications of complying with the Regulation would not be significant (as it reflected existing business practice).

15. Revised FSA Guidance Notes, incorporating the EC Guidance on Articles

11, 12 and 16-20 of the Regulation, were widely circulated to stakeholders, including industry groups, on 10 March 2005. In addition, they were placed on the Agency’s website.

16. In July 2005 a public consultation was carried out on the EC Guidance to

Articles 11, 12 and 16-20 of the Regulation to inform the Agency’s negotiating position on an EC review of the Guidance. Replies to the consultation indicated that there were significant costs to food business operators arising from the EC Guidance, primarily owing to suggested best practice on traceability, not legally required under Article 18 of the Regulation.

17. This consultation seeks views on the cost impact of implementing the new

FSA Guidance Notes as the most appropriate guidance for food businesses in the UK.

OPTIONS 18. Two options have been considered: Option 1 19. Do nothing. Do not introduce new FSA Guidance Notes on the Regulation.

The current EC Guidance would remain as the primary advice on compliance with legal requirements.

Option 2 20. Introduce new FSA Guidance Notes on the Regulation as the most

appropriate guidance for food businesses in the UK on Articles 14-16 and 18-20.

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COSTS AND BENEFITS Sectors and groups affected 21. All food businesses (including small businesses); voluntary organisations

and charities that fall under the definition of a “food business” in Article 2 of the Regulation; and local authorities. There are approximately 346,000 food businesses in the UK.

22. The British Retail Consortium estimated in 2006 that complying with the

EC Guidance would require major retailers to develop new IT systems, generating a one-off cost of £37m, as well as maintenance costs of £19m over five years. Those estimates relate to the 15 largest food retailers, which account for more than 85% of all food sales in the UK.

23. The cross-Government Administrative Burden Measurement Exercise

conducted in 2005 estimated the administrative burden for all food businesses to comply with the EC Guidance to be £16 million annually. This does not include the burden incurred by business in complying with the legal requirements of the Regulation.

Benefits 24. Option 1: Food businesses would not have to change practices adopted in

order to follow the EC guidance. 25. Option 2: The new FSA Guidance Notes remove the additional burdens

resulting from the recommendations of the EC guidance, which will lead to a decrease in the administrative burden borne by food businesses. The results of previous consultations on the Regulation and the associated domestic General Food Regulations 2004 suggest that the new FSA Guidance Notes would not impose costs on businesses in excess of what they incur during their normal course of operation. It is therefore estimated that the introduction of the new FSA Guidance Notes would remove the majority of the administrative burden created by following the EC Guidance, identified as £16 million annually in the Administrative Burden Measurement Exercise .

26. In addition, the new FSA Guidance Notes are more concise than the EC

Guidance and help to clarify the requirements of the Regulation. They should be easier for food business operators and others who work with food to follow.

27. The new FSA Guidance Notes ask businesses to judge for themselves

how long it is necessary to keep traceability records (to ensure they can comply with Article 19 should action be necessary), rather than the 5 years in most cases recommended in the EC Guidance. For large retailers, these savings are likely to be negligible as the records are kept

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electronically, but for the majority of food businesses that keep paper records, the benefit could be substantial. Evidence received in response to last year’s consultation on the EC Guidance suggests that the benefit from having to store records for periods of less than five years could be £14,000 per year for a typical food manufacturer. Another food company with 300 workers reported that the requirement to keep records for three years would force them to build suitable storage facilities at a cost of £15-20,000.

28. The removal of the need to supply traceability information immediately, where the severity of the incident does not justify it, will mean that the requirement becomes more proportionate in these cases.

Costs 29. Option 1: There would still be the estimated cost of £16 million annually to

food businesses from following the best practice recommendations in the EC Guidance.

30. Option 2: The new Agency Guidance Notes are less stringent than the EC

Guidance, and any costs should be “business as usual” costs only. Previous RIAs support that view, indicating that the costs of compliance with the requirements of the Regulation would not be significant.

31. There will, however, be a one-off additional cost of reading and

understanding the new FSA Guidance Notes. Assuming that it takes 30 minutes for a manager to complete that task, and relying on the wage rates and overheads used in the Administrative Burden Measurement Exercise, that cost is estimated to be worth £3.65 million.

32. If you can identify aspects of the new FSA Guidance Notes that incur

additional costs for your business, please specify what these will be, on an annual basis, and provide examples.

Administrative burden of keeping traceability records 33. The Regulation does not specify the time period for keeping traceability

records. The Commission’s best practice guidance suggested that for most products records should be kept for a minimum of five years. Responses to the consultation exercise on the EC Guidance indicated that this was unnecessary and would result in disproportionate cost for food businesses. This was confirmed by the Administrative Burdens Measurement Exercise. The new FSA Guidance Notes say that it is for businesses to decide how long they should keep their records, bearing in mind the business risks that would be posed by the unavailability of records that would be required should a withdrawal/recall notification of unsafe food be necessary.

34. The EC Guidance classifies traceability information in two categories, the

first to meet the legal requirements and the second to be followed as best practice. Responses from food businesses to the consultation exercise on

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the EC Guidance indicated that following such best practice guidance could result in additional costs. The new FSA Guidance Notes therefore focus primarily on the legal requirements. We believe that the new FSA Guidance Notes would not impose any administrative costs to business that they do not already incur through the normal course of business. We would welcome comments on this. (Please do not include costs that result from complying with the legal requirements of the Regulation).

CONSULTATION WITH SMALL BUSINESSES: THE SMALL FIRMS IMPACT TEST 35. Small businesses may find it less of a burden not to have to produce

traceability records immediately, and are likely to find the more concise nature of the Guidance Notes helpful in understanding the requirements. Conversely, it is possible that modification of record-keeping systems to accommodate the FSA Guidance Notes would impose a one-off cost that would be easier to bear by larger businesses. However, given that the requirements of the Guidance Notes are not as stringent as those of the EC Guidance, we consider it likely that companies could keep their existing record-keeping systems and there is therefore no reason to believe that the Guidance Notes might put small businesses at a disadvantage.

COMPETITION ASSESSMENT 36. The introduction of the new FSA Guidance Notes is not anticipated to have

any significant impact on competition in the food sector. ENFORCEMENT, SANCTIONS AND MONITORING 37. The FSA Guidance Notes are not legally enforceable. However, any

person who contravenes or fails to comply with any of Articles 14(1), 16 in so far as it relates to food, 18(2) and 18(3) in so far as they relate to food business operators and Article 19 of the Regulation is guilty of an offence under the General Food Regulations 2004 (as amended), and the Guidance Notes might be used by courts in their interpretation of the Regulation. Local authorities will use the provisions of the Agency Guidance Notes when inspecting premises.

38. A review of the impact of the new FSA Guidance Notes will be conducted

within 2 years of publication.

SUMMARY AND RECOMMENDATION 39. To be added following the consultation.

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MINISTERIAL DECLARATION 40. To be added following the consultation. Contact Point Name: Bill Drennan E-mail: guidance@foodstandards.gsi.gov.uk Division: Consumer Choice, Food Standards and Special Projects

Division Address: Room 115B, Aviation House, 125 Kingsway, London WC2B

6NH Telephone: 020 7276 8138 Date: 30 October 2006

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INTERESTED PARTIES

1990 TRUST (THE) 3663 4 CHILDREN 4 THE FORUM A H ALLEN & PARTNERS A POORTMAN (LONDON) LTD A WATSON & CO LTD ABBEY VETERINARY GROUP ABBOTT LABORATORIES LTD ACACIA FOODS LTD ACADEMY OF CULINARY ARTS ACORN FEED PRODUCTS LTD ACTION ON SMOKING AND HEALTH (ASH) ADAS GLEADTHORPE ADAS HOLDINGS LIMITED ADM ADVERTISING ASSOCIATION ADVERTISING STANDARDS AUTHORITY ADVOCACY LTD AFC / COMMITTEE BRITISH STANDARDS INSTITUTION AGRI-EUROPE AGRICULTURAL & ALLIED WORKERS AGRICULTURAL AND FOOD RESEARCH COUNCIL AGRICULTURE & COUNTRYSIDE BOARD AIC (AGRICULTURAL INDUSTRIES CONFEDERATION) AIR CARGO ADVISORY SERVICES AIRLINE OPERATORS COMMITTEE CARGO AL NEMEH FOOD INDUSTRYS CO LTD ALAN TURNER CONSULTANCY ALCONTROL LABORATORIES ALFA CHEMICALS ALLERGY ALLIANCE ALLIED BAKERIES LTD ALLIED BREWERIES LTD ALLIED BREWERY TRADERS ASSOCIATION ALLIED DOMECQ ALLIED MEAT IMPORTERS LTD ALLSPORTS INTERNATIONAL LTD ALPHAMAX LTD ALSTEAD AMERICAN PEANUT COUNCIL AMICUS ANDREW SMITH ANGLO-SCOTTISH FISH PRODUCERS' ORGANISATION LTD ANIMAL AIRCARE ANIMAL HEALTH DISTRIBUTORS ASSOCIATION (UK) LTD ANIMAL HEALTH TRADE ASSOCIATION

ANIMAL HEALTH TRUST ANIMAL MEDICINES INSPECTORATE ANIMAL TRANSPORTATION ASSOCIATION ANNE THURLOW ANZFA APAG APARTADO DE CORREOS 129 APLIN AND BARRETT LTD AQUINAS COLLEGE ARABIAN SEAFISH UK LTD ARAS SERVICES ARKARIUS LIMITED ARMITAGE BROS PLC ASDA STORES LTD ASHURST MORRIS CRISP ASHWELL ASSOCIATES ASSOC OF BRITISH PHARMACEUTICAL INDUSTRIES ASSOC OF CEREAL FOOD MANUFACTURERS ASSOC OF MALT PRODUCTS MANUFACTURERS ASSOC OF PUBLIC ANALYSTS OF SCOTLAND ASSOC. FOR IMPROVEMENTS IN MATERNITY ASSOCIATE PARLIAMENTARY FOOD AND HEALTH FORUM ASSOCIATED BRITISH FOODS PLC ASSOCIATED BRITISH NUTRITION ASSOCIATION OF CONVENIENCE STORES (ACS) ASSOCIATION FOR CONSUMER RESEARCH ASSOCIATION FOR PUBLIC HEALTH ASSOCIATION OF AGRICULTURAL EDUCATIONAL STAFF ASSOCIATION OF BAKERY INGREDIENTS MANUFACTURERS ASSOCIATION OF BREAST FEEDING MOTHERS ASSOCIATION OF BRITISH ABATTIOR OWNERS ASSOCIATION OF BRITISH CHAMBERS OF COMMERCE ASSOCIATION OF BRITISH HEALTH CARE INDUSTRIES ASSOCIATION OF BRITISH SALTED FISH CURERS AND EXPORTERS ASSOCIATION OF BUTTER AND CHEESE PACKERS ASSOCIATION OF CEREAL FOOD MANUFACTURERS ASSOCIATION OF CHEESE PROCESSORS ASSOCIATION OF FISH CANNERS

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ASSOCIATION OF INDEPENDENT CROP CONSULTANTS ASSOCIATION OF LICENSED MULTIPLE RETAILERS ASSOCIATION OF LIVESTOCK EXPORTERS ASSOCIATION OF LONDON AUTHORITIES ASSOCIATION OF LONDON CHIEF ENVIRONMENTAL HEALTH OFFICERS ASSOCIATION OF LONDON CHIEF HEALTH OFFICERS ASSOCIATION OF LONDON GOVERNMENT ASSOCIATION OF MEAT INSPECTORS ASSOCIATION OF MEDICAL MICROBIOLOGISTS ASSOCIATION OF PORT HEALTH AUTHORITIES ASSOCIATION OF PRIVATE MARKET OPERATORS ASSOCIATION OF PUBLIC ANALYSTS ASSOCIATION OF RADICAL MIDWIVES ASSOCIATION OF SCOTTISH SHELLFISH GROWERS ASSOCIATION OF SEA FISHERIES COMMITTEES OF ENGLAND AND WALES ASSOCIATION OF UNPASTEURISED MILK PRODUCERS AND CONSUMERS ASSOCIATION OF VETERINARIANS IN INDUSTRY ASSOCIATION OF VETERINARY SALES MANAGERS ATLANTIC BAR AND GRILL ATLANTIC CONTAINER LINE UK LTD AUSTRALIAN EMBASSY AUSTRALIAN HIGH COMMISSION AUTOMATIC VENDING ASSOCIATION OF GREAT BRITAIN AVON GLOS AND SOMERSET ENVIR MONIT COMM AYLESBURY VALE COMMUNITY HEALTHCARE BABY MILK ACTION GROUP BAKERY AND ALLIED TRADES ASSOCIATION BARBER INDEX BARBOUR INDEX PLC BARNARD AND GOODING GOAT'S MILK LTD BARNET COUNCIL BAYER PLC BBC GOOD FOOD MAGAZINE BBC REFERENCE LIBRARY BBSRC BCVA BEDFORD BUSINESS CENTRE BEE SERVICES BEE FARMERS ASSOCIATION OF THE UK BELASCO T/A SASSCO BELL DAVIE

BELSO'S (UK) CEREALS LTD. BERNARD MATTHEWS FOODS LTD BERRY EMBRYOS BERRY OTTAWAY AND ASSOCIATES LTD BERRYSTOCK FEEDING CO BEST FOODS UK LTD BESTWAY CASH AND CARRY LTD BEVAN ASHFORD (LIBARIAN) BIBRA INTERNATIONAL BICODE LTD BIDEFORD TRAWLERMEN'S CO-OPERATIVE LTD BIOWHITTAKER UK BIRD AND BIRD BIRD FOOD STANDARDS ASSOCIATION BIRDS EYE FOODS LTD BIRMINGHAM CITY COUNCIL BIRMINGHAM CITY LABORATORIES BIRMINGHAM LIBRARY SERVICES BISCUIT CAKE CHOCOLATE & CONFECTIONARY ALLIANCE BISHOP BURTON COLLEGE OF AGRICULTURE BLYTH BOROUGH COUNCIL BMMA BOLTON MBC BONGRAIN UK LTD BONNIA PETITE BANQUETING LTD BOOKER CASH & CARRY BOOTS COMPANY PLC BORDER SHEEPSKIN LIMITED BOURNE SALADS BOURNE STIR FRY BOWYERS (WILTSHIRE) LTD BRAVE BROS FOODSERV LTD BRETBY ANALYTICAL CONSULTANTS LTD BREWING RESEARCH INT BRIDGE FARM DAIRIES LTD BRITISH ASSOCIATION BRITISH CHEESE BOARD BRITISH ALPACA SOCIETY BRITISH ANGORA GOAT SOCIETY BRITISH ASSOCIATION OF CANNED & PRESERVED FOOD BRITISH ASSOCIATION OF FEED SUPPLEMENT AND ADDITIVE MANUFACTURERS LTD BRITISH ASSOCIATION OF PLANT BREEDERS BRITISH BAKERS LTD BRITISH BISON ASSOCIATION BRITISH BROSH MAKERS ASSOCIATION BRITISH CARAMEL MANUFACTURERS ASSOC BRITISH CATTLE VETERINARY ASSOCIATION BRITISH COFFEE ASSOSCIATION BRITISH COMPRESSED GASSES ASSOCIATION

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BRITISH CONFECTIONERS ASSOCIATION BRITISH DENTAL ASSOC BRITISH DIABETIC ASSOCIATION BRITISH EGG INDUSTRY COUNCIL BRITISH EGG PRODUCTS ASSOCIATION BRITISH ESSENCE MANUFACTURERS ASSOCIATION BRITISH ESSENTIAL OILS ASSOC BRITISH FARMERS DEER ASSOCIATION BRITISH FEATHER CO LTD BRITISH FERMENTATION PRODUCTS BRITISH FISHERMEN'S ASSOCIATION BRITISH FOOD MANUFACTURING INDUSTRIES RESEARCH ASSOCIATION BRITISH FREE RANGE EGG PRODUCERS ASSOCIATION. BRITISH FROZEN FOOD FEDERATION BRITISH FRUIT & VEGETABLE MANUFACTURES ASSOCIATION BRITISH FUR ASSOCIATION BRITISH GOAT SOCIETY BRITISH HERBAL MEDICINE ASSOCIATION BRITISH HIGH COMMISSION BRITISH HONEY IMPORTERS AND PACKERS ASSOCIATION BRITISH HOSPITALITY ASSOCIATION BRITISH INDEPENDENT GROCERS ASSOCIATION BRITISH INSTITUTE OF AGRICULTURE CONSULTANTS BRITISH INSTITUTE OF INNKEEPING BRITISH LEATHER CONFEDERATION BRITISH MARINE FINFISH ASSOCIATION BRITISH MEAT FEDERATION BRITISH MEDICAL ASSOCIATION BRITISH NUTRITION FOUNDATION BRITISH PASTA PRODUCTS ASSOCIATION BRITISH PEPPER AND SPICE BRITISH PEST CONTROL ASSOCIATION BRITISH PIG ASSOCIATION BRITISH PORT ASSOCIATION BRITISH POTATO COUNCIL BRITISH POULTRY COUNCIL BRITISH REFRIGERATION ASSOCIATION BRITISH REGULATORY AFFAIRS BRITISH RETAIL CONSORTIUM (BRC) BRITISH RICE ASSOCIATION BRITISH SANDWICH ASSOCIATION BRITISH SOCIETY OF ANIMAL PRODUCTION BRITISH SOCIETY OF PAEDIATRIC DENTISTRY BRITISH SOFT DRINKS ASSOCIATION BRITISH SOLUBLE COFFEE PARKERS AND IMPORTERS ASSOCIATION BRITISH STARCH INDUSTRY ASSOCIATION BRITISH SUGAR PLC

BRITISH SUGAR REFINERS ASSOCIATION BRITISH TROUT ASSOCIATION BRITISH UNITED TURKEYS LTD BRITISH VETERINARY ASSOCIATION BRITISH WILD BOAR ASSOCIATION BRITVIC LTD. BRIXHAM TRAWLER OWNER'S ASSOCIATION BROADLAND FOODS LTD BUCKINGHAMSHIRE HEALTH AUTHORITY BURGER KING LTD BURGES SALMON SOLICITORS BURGESS SUPAFEEDS BURY TRADING STANDARDS DEPT BUSH BOAKE ALLEN LTD BUSINESS IN SPORT AND LEISURE BUTCHERS HALL C L AUDITING SERVICES C/O FOOD AND DRINK INDUSTRY DIVISION CADBURY SCHWEPPES PLC CALYMPEX LTD CAMBRIDGE MANUFACTURING COMPANY LTD CAMERON MCKENNA CAMPBELLS CAMPDEN FOOD AND DRINK RESEARCH ASSOCIATION CAMRA (CAMPAIGN FOR REAL ALE LTD) CANFIELDS FARM CAPTIVA BRANDS INT. CARDINAL HEALTH CARVER WILDE COMMUNICATIONS CASELLA CASELLA GMSS LTD CATERER AND HOTEL KEEPER MAGAZINE CATERERS MARKETING AND ADVISORY SERVICE CATERING EQUIPMENT MANUFACTURERS ASSOCIATION CATERING EQUIPMENT SUPPLIERS ASSOC CATERING UPDATE CATHAY PACIFIC AIRWAYS CATTLE TECH LTD CBI SMALL AND MEDIUM ENTERPRISE COUNCIL CELCAA CENTRAL LIBRARY CENTRAL MIDDLESEX HOSPITAL CENTRAL PUBLIC HEALTH LABORATORY CENTRAL SCIENTIFIC LABOATORIES CENTURA FOODS CEREAL INGREDIENTS MANUFACTURERS ASSOCIATION CEREAL PARTNERS WORLDWIDE CHAMBER OF SHIPPING CHANNEL 4

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CHARTERED INSTITUTE OF ENVIRONMENTAL HEALTH CHEMICAL & FEEDS LTD CHEMIST & DRUGGIST CHERRY VALLEY FARMS LTD CHEW VALLEY HIDE & SKIN CO LTD CHILD ACTION PREVENTION TRUST CHILDREN'S SOCIETY CHILLED FOOD ASSOCIATION CHITTY WHOLESALE LTD CHRISTIAN AID CHRISTIAN SALVESEN LTD CIAA CITES TEAM, HM CUSTOMS & EXCISE CITY OF LONDON CITY OF YORK COUNCIL CIVIC CATERING ASSOCIATION CLIFFORD CHANCE CMA UK CO-OPERATIVE GROUP CO-OPERATIVE UNION LTD CO-OPERATIVE WOMENS GUILD COCA COLA GREATER EUROPE CODE MONITORING COMMITTEE COELIAC UK (LTD) COFFEE TRADE FEDERATION (THE) COLD STORAGE AND DISTRIBUTION FEDERATION COLIN SHEPHERD MP COMMITTEE OF ADVERTISING PRACTICE COMMUNITY AND PRIORITY CARE SERVICES COMMUNITY FOODS LTD COMMUNITY NUTRITION GROUP COMPASSION IN WORLD FARMING CONFEDERATION OF BRITISH INDUSTRY CONFEDERATION OF BRITISH WOOL TEXTILES LTD CONSORTIUM OF CATERERS & ADMINISTRATORS (IN EDUCATION) CONSULTANT NUTRITIONIST & DIETITIAN CONSUMERS FOR HEALTH CHOICE CONSUMERS' ASSOCIATION CONTINENTAL FOOD SUPPLIES LTD CONTINENTAL PASTAS LTD CONTINENTAL WINE EXPERTS LTD CONTRACT FOODS LTD CORNISH FISH PRODUCERS' ORGANISATION LTD CORNISH GUILD OF SMALLHOLDERS CORNWALL COUNTY COUNCIL CORNWALL INSHORE FISHERMEN'S FEDERATION CORNWALL SEA FISHERIES COMMITTEE COUNCIL FOR RESPONSIBLE NUTRITION

COUNCIL FOR THE PROTECTION OF RURAL ENGLAND COUNSEL LTD COUNTRY HARVEST NATURAL FOODS LTD COUNTRY LANDOWNERS ASSOCIATION COUNTRY LANDOWNERS AND BUSINESS ASSOCIATION COURAGE LTD COVENT GARDEN MARKET AUTHORITY COVENTRY HEALTH AUTHORITY COVINGTON & BURLING CP KELCO UK LTD CRAB PROCESSORS' ASSOCIATION CRAIG WHITEHOUSE CONSULTANCY SERVICES CRANSWICK MILL LTD CREAMERY PROPRIETORS ASSOCIATION CROCODILE CREEK CRODA COLLOIDS LTD CROMARTY FIRTH PORT AUTHORITY CROP PROTECTION ASSOCIATION CROWN CHICKEN LTD CUMBERLAND COUNTY COUNCIL CUMBRIA COUNTY COUNCIL CUSSONS UK LTD CUSTOM PHARMACEUTICALS LTD DAILY MAIL DAIRY CREST LTD DAIRY INDUSTRY ASSOCIATION LTD DAIRY INDUSTRY FEDERATION LTD DAIRY INGREDIENTS (UK) LTD DAIRY TRADE FEDERATION DALEGETY PRODUCE DALEHEAD FOODS LTD DANISH BACON COMPANY PLC DANISH EMBASSY DARLINGTON CATTLE BREEDING CENTRE DAVID T BOYD DAVTECH DAWN FOODS LTD DAWNFRESH FOODS DAYLA SOFT DRINKS LTD DAYLAY FOODS LIMITED DEBENHAMS PLC DECHERT DECLERCQ TRADING DEFENCE CATERING GROUP DEFRA DEFRA - BASD DEFRA - CPU DEFRA- EUROPEAN UNION INTERNATIONAL DEFRA-FDID A, FMI BRANCH DEL MONTE FOODS (UK) LTD DELBANCO MEYER & CO LTD

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DEPARTMENT FOR CULTURE MEDIA AND SPORT DEPARTMENT FOR INTERNATIONAL DEVELOPMENT DEPARTMENT OF AGRICULTURE AND FISHERIES DEPARTMENT OF HEALTH DEPARTMENT OF LOCAL GOVERNMENT & THE ENVIRONMENT DEPARTMENT OF TRADING STANDARDS DEPT OF AGRICULTURE FOR NI DEPT OF CLINICAL VETERINARY MEDICINE DEPT. OF FOOD SCIENCE & TECHNOLOGY DESIGN AND TECHNOLOGY ASSOCIATION (DATA) DESSERT & CAKE MIXES ASSOCIATION DEVON DIRECT SERVICES CATERERS DEVON SEA FISHERIES COMMITTEE DHSS/NI DIABETES UK DIETETIC DEPARTMENT DIETICIAN'S DEPARTMENT DIMERCO EXPRESS (UK) LTD DIRECT SELLERS CO-OPERATIVE LTD DOANE PET CARE UK DOMESTIC FOWL TRUST DOVER HARBOUR BOARD DOVER PORT HEALTH DOW CORNING COORDINATION CENTER DRUCES AND ATTLEE DTI, CONSUMER AFFAIRS C DUGDALE NUTRITION LTD DUNN NUTRITION LABORATORY DURHAM COUNTY COUNCIL E BOTHAM & SON LTD E SLINGER & SONS LTD EALING TRADING STANDARDS EAST DEVON FISHERMEN'S ASSOCIATION EAST MIDLANDS AIRPORT EASTERN SEA FISHERIES COMMITTEE EDLONG COMPANY LTD (THE) EDWARD PAUL & CO (GROCERS) LTD ELLIOTT AND COMPANY EM CONSULTANTS EMA CARGO WEST ENDS ENVIRONMENT AGENCY ENVIRONMENTAL HEALTH BRIEFING ENVIRONMENTAL SERVICES ENVIRONSAFE LIMITED ESSENTIAL TRADING CO-OPERATIVE LTD ETHICAL CONSUMER RESEARCH ASSOCIATION EURO COOP EURO ENVIRONMENTAL CONTAINERS

EUROCOMMERCE EUROFINS SCIENTIFIC LTD EUROPA FOODS LTD EUROPEAN CATERERS ASSOCIATION EUROPEAN CEREAL INGREDIENTS ASSOCIATION EUROPEAN FEDERATION OF HONEY PACKERS AND DISTRIBUTORS EUROPEAN FOOD LAW ASSOCIATION (UK SECTION) EUROPEAN MODERN RESTAURANT ASSOCIATION EUROPEAN MOLASSES IMPORTERS & DIST ASSOC EUROPEAN PUBLIC POLICY ADVISORS UK LTD EUROPEAN SPICE ASSOCIATION EUROPEAN UNION OF WHOLESALE WITH EGGS, EGG PRODUCTS, POULTRY AND GAME (EUWEP) EUROWAY ASSOCIATES LTD EVERSHEDS EVILLE & JONES V.F.H. EXETER TRAWLERMEN'S ASSOCIATION F GUTKIND & COMPANY F HOFFMAN - LA ROCHE LTD FACULTY OF PUBLIC HEALTH MEDICINE FACULTY OF THE ENVIRONMENT FAMILY FARMERS ASSOCIATION FARM AND FOOD SOCIETY FARM RETAIL ASSOCIATION FARMHOUSE CHEESEMAKERS LTD FAYRE OAKS LTD FDB DISTRIBUTION LTD FDF SERVICES FED OF OILS SEEDS AND FATS ASSOC (FOSFA) FEDERATION OF BRITISH PORT WHOLESALE FISH MERCHANTS' ASSOCIATION FEDERATION OF AGRICULTURAL CO-OPERATIVES FEDERATION OF CITY FARMS AND COMMUNITY GARDENS FEDERATION OF DANISH PIG PRODUCERS AND SLAUGHTERHOUSES FEDERATION OF FRESH MEAT WHOLESALERS FEDERATION OF MILK GROUPS (UK) FEDERATION OF OILS, SEEDS & FATS ASSOCIATION LTD FEDERATION OF SMALL BUSINESSES FEDERATION OF SYNAGOGUES FEDERATION OF WHOLESALE DISTRIBUTORS FEED FAT ASSOCIATION FERRERO UK LTD

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FI DATA SERVICES FIBRISOL SERVICE LTD FINDUS LTD FISHER CHILLED FOODS LTD FISHERMANS FEATHERS FISHERMENS' FEDERATION OF NORTHUMBERLAND FISHMONGERS COMPANY FLEETWOOD FISH PRODUCERS' ORGANISATION LTD FLOOR 1W FMF-CODE MONITORING COMMITTEE FOLKESTONE FISHERMEN'S ASSOCIATION FOOD & HEALTH RESEARCH FOOD ADDITIVES AND INGREDIENTS ASSOCIATION FOOD ADDITIVES INDUSTRY ASSOCIATION LIMITED FOOD AND DRINK FEDERATION FOOD AND DRINK INDUSTRY DIVISION FOOD BRAND GROUP (THE) FOOD BRANDS GROUP FOOD BROKERS LTD FOOD CASINGS ASSOCIATION FOOD CERTIFICATION INTERNATIONAL LTD FOOD COMMISSION FOOD ETHICS COUNCIL FOOD FROM BRITAIN FOOD INGREDIENTS BUREAU FOOD LABELLING AGENDA FOOD LABELLING AND STANDARDS FOOD MANUFACTURERS FEDERATION FOOD POLICY RESEARCH UNIT FOOD POLICY UPDATE FOOD REGULATORY AFFAIRS CONSULTING LTD FOOD SAFETY TRAINING SERVICES FOOD STANDARDS AGENCY (SCOTLAND) FOOD TRANSPORT CAMPAIGN FOODAWARE FOODFEN FOODS CASINGS ASSOCIATION FORUM OF PRIVATE BUSINESS FORUM PRODUCTS FOSFA INTERNATIONAL LIMITED FPMA FPS INTERNATIONAL FR BENSON & PARTNERS LTD37942 FRAMPTONS LTD FREEDOM FOODS FREELANCE DIETITIAN AND CONSULTANT TO APRO UK LTD FREIGHT TRANSPORT ASSOCIATION FRESH FRUIT & VEGETABLE INFORMATION BUREAU

FRESH PRODUCE CONSORTIUM (UK) FRIENDS OF THE EARTH UK LTD FROMAGES DE FRANCE LTD FROZEN & CHILLED POTATO PROCESSERS ASSOCIATION FRUIT & VEGETABLE CANNERS ASSOCIATION FRUIT IMPORTERS ASSOCIATION FRUIT PREPARATION MANUFACTURERS ASSOCIATION FSA - MSN FSA ANF FSA FLSCPD 'C' FSA NORTHERN IRELAND G R LANE HEALTH PRODUCTS LTD G R MICRO LTD G'S MARKETING LTD GAME CONSERVANCY TRUST GARDNER MERCHANT GATEGOURMET LONDON GEEST PLC GENERAL CONSUMER COUNCIL FOR NORTHERN IRELAND GENERAL DIETARY LTD GENERAL MANAGER-OPERATIONS GEOGE ADAMS & SON (HOLDINGS) LTD GEOLOGISTICS LTD GEORGE HARKER AND COMPANY LTD GERARD J HOMAN LTD GERBER FOODS/SOFT DRINKS LTD GHR FOODS LTD GILBERT KOSHER FOOD GILBERTSON & PAGE LTD GIN AND VODKA ASSOCIATION OF GREAT BRITAIN GIRACT GIRAG SA GLENRYK (UK) LTD GLOUCESTERSHIRE COUNTY COUNCIL GOAT ADVISORY BUREAU GOAT VETERINARY SOCIETY GOAT'S MILK PROCESSORS FEDERATION GOLD CROWN FOODS LTD GOLD LINE FEEDS LTD GOLDEN ACRES LTD GOOD HOUSEKEEPING MAGAZINE GOODMAN DERRICK GORDON CONRAD LTD GOSPORT COMMERCIAL FISHERMEN'S ASSOCIATION GRAIG FARM ORGANICS GRAIN & TRADE FEED TRADE ASSOCIATION GREAT YARMOUTH MEDITERRANEAN HERRING EXPORTERS' ASSOCIATION GRIMSBY FISH DOCK ENTERPRISES LTD GRIMSBY FISH MERCHANTS ASSOCIATION

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GRIMSBY FISH PRODUCERS' ORGANISATION LTD GRIMSBY FISHING VESSEL OWNERS' ASSOCIATION GRIMSBY SEINERS' ASSOCIATION LTD GUILDHAY LTD H M PRISON SERVICE CATERING GROUP H T WEBB AND CO LTD HACKNEY LONDON BOROUGH OF HAFOD HALAL FOOD AUTHORITY HALDANE FOODS GROUP HAMPSHIRE SCIENTIFIC SERVICE HARINGAY LONDON BOROUGH OF HARRIS ASSOCIATES LTD HARRISON GMBH HARRODS OCCUPATIONAL HEALTH & SAFETY DEPT HARTWELL FOOD RESEARCH LTD HARVEY FOODS LTD HARWICH FISHERMANS' ASSOCIATION HASSAS (LONDON) LTD HCIMA HEAD OF FOOD SCIENCE HEALAN INGREDIENTS LTD HEALTH DEVELOPMENT AGENCY HEALTH EDUCATION AUTHORITY HEALTH HYGIENE & SAFETY CONSUTANCY HEALTH VISITORS ASSOCIATION HEATHER PAINE ASSOCIATES HENRY HIRST (PROVISIONS) LTD HERBISON HERTFORD FOODS LTD HILLSDOWN HOUSE HILLSIDE ORNAMENTAL WATERFOWL HM CUSTOMS & EXCISE HOLCHEM LABORATORIES LTD HOLLAND AND BARRETT HOLSTEIN UK HOME GROWN CEREALS AUTHORITY HONEY ASSOCIATION HOSPITAL CATERERS ASSOCIATION HOTEL & CATERING INTERNATIONAL MANAGEMENT ASSOCIATION HOTEL AND CATERING INSTITUTIONAL MANAGEMENT ASSOC HOTREC HOUNSLOW (LONDON BOROUGH OF) HOWARD LONG INTERNATIONAL HP BULMER LTD HP FOODS LTD HULL FISH MERCHANTS PROTECTION ASSOCIATION HUMANE SLAUGHTER ASSOCIATION HUMBERSIDE COUNTY SCIENTIFIC SERVICES

HUNTINGDON LIFE SCIENCES HUSH HYGIENE AND NUTRITION IN FOOD SERVICE I B FOOD MARKETING LTD IAN ROSS ASSOCIATES IBP INTERNATIONAL INC EUROPE ICE CREAM ALLIANCE LTD ICE CREAM FEDERATION ICEBRIT LTD ICM MARKETING LTD ILS LTD INDEPENDENT FOOD RETAILERS CONFEDERATION INDEPENDENT TELEVISION COMMISSION INFANT & DIETETIC FOOD ASSOCIATION INFORMATION CENTRE TRADING STANDARDS INSTITUTE INSTITUTE OF AGRICULTURAL MEDICINE INSTITUTE OF ARABLE CROPS RESEARCH INSTITUTE OF CONSUMER SCIENCES INSTITUTE OF FISHERIES MANAGEMENT INSTITUTE OF FOOD RESEARCH INSTITUTE OF FOOD SCIENCE AND TECHNOLOGY INSTITUTE OF GROCERY DISTRIBUTION INSTITUTE OF MECHANICAL ENGINEERS INSTITUTE OF PRACTITIONERS IN ADVERTIS INSTITUTE OF PROFESSIONALS, MANAGERS AND SPECIALISTS INSTITUTE OF REFRIGERATION INTERNATIONAL CENTER FOR HEALTH AND SOCIETY INTERNATIONAL FEDERATION OF ESSENTIAL OILS AND AROMA TRADES INTERNATIONAL FISH MEAL AND OIL MANUFACTURERS ASSOCIATION INTERNATIONAL FLIGHT CATERING INTERNATIONAL FOOD LINK LTD INTERNATIONAL MEAT TRADE ASSOCIATION INTERNATIONAL ROAD FREIGHT OFFICE ISLE OF MAN FISH PROCESSORS' ASSOCIATION ISLE OF MAN FISHERMEN'S ASSOCIATION ISLE OF SCILLY SEA FISHERIES COMMITTEE J C GILBERT J SAINSBURY PLC J WHARTON (SHIPPING) LTD JAFFE JAMES BUDGET SUGARS LTD JAMES BURDEN LTD JAMES GROVE & SONS LTD JAMES HALL JAMES PAGET HOSPITAL JAMES ROBERTSON AND SONS LTD JARDOX CONCENTRATED PRODUCTS LTD

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JAYTEE SEAFORDS LTD JC DUDLEY & CO LTD JEFFORY DAVIES & DAVIES LTD JESS SHIRLEY & SON LTD JETRO (JAPAN TRADE CENTRE) JG QUICKE & PARTNERS JK FOODS UK JOHN & PASCALIS JOHN BIFFEN MP JOHN DAVIES & CO JOHN HALL (ANIMAL FEEDS) LTD JOHN HOGARTH LTD JOHN LEWIS PARTNERSHIP JOHN RUSSELL ASSOCIATES JOHN SUTCLIFFE & SONS (GRIMSBY) LTD JOHN WEST FOODS LTD JOHN WHARTON MEATS LTD JOHN WYETH & BROTHER LTD JOHNSON'S SEA ENTERPRISES JOHNSTON CONSULTING JOINT BREASTFEEDING INITIATIVE JOINT CONSULTATIVE COUNCIL FOR MEAT TRADE JOINT FOOD SERVICE INDUSTRY GROUP JOINT HOSPITALITY INDUSTRY CONGRESS JPG SERVICES JPHP CONSULTANTS JRH BIOSCIENCES K J LOVERING & CO LTD KARLSHAMNS LTD KATSOURIS BROS LTD KEDDER TRAINING KEITH ANDERSON SERVICES KELLOGG COMPANY OF GREAT BRITAIN LTD KENT AND ESSEX SEA FISHERIES COMMITTEE KEY COUNTRY FOODS LTD KEYNOTE KIMPTON BROTHERS LTD KITCHEN RANGE FOODS LTD KRAEBER (UK) LTD KRAFT FOODS INTERNATIONAL KRAFT JACOBS SUCHARD LTD KWIK SAVE STORES LTD L B CROYDON FOOD TEAM LA LECHE LEAGUE (GB) LABORATORY ANALYTICAL & BACTERIOLOGICAL SERVICES LABORATORY OF THE GOVERNMENT CHEMIST LACORS LAKELAND FOODS LTD LANCASHIRE COUNTY COUNCIL LANWADES BUSINESS PARK LARD ASSOCIATION (THE)

LAW COMMISSION LAW LABORATORIES LAW LABORATORIES LTD LAWCODE LAWDATA LTD LBL (COOKED MEATS) LTD LEATHERHEAD FOOD RESEARCH LEATHERHEAD FOOD RESEARCH ASSOCIATION LEE KUM KEE (HONG KONG) FOODS LIMITED LEEDEX PUBLIC RELATIONS LEEDS AND DISTRICT FISH FRIERS' ASSOCIATION LEEDS CITY COUNCIL LEICESTER CITY LIBRARIES LEICESTERSHIRE COUNTY ANALYSTS LAB LEICESTERSHIRE LIBRARIES AND LEICS. COUNTY TRADING STANDARDS DEPT. LEWIS SILKIN SOLICITORS LICENCED ANIMAL SLAUGHTERERS & SALVAGE ASSOCIATION LINKING ENVIRONMENT AND FARMING (LEAF) LINX PRINTING TECHNOLOGIES PLC LIQUID FOOD CARTON MANUFACTURERS ASSOCIATION LIVERPOOL CHAMBER OF COMMERCE AND LIVERPOOL CITY COUNCIL LIVERPOOL TRADING STANDARDS SERVICES LIVESTOCK & COMMISSION FOR N.I. LIVESTOCK AUCTIONEERS ASSOCIATION LOCAL AUTHORITIES CO-ORDINATORS OF REGULATORY SERVICES (LACORS) LOCAL AUTHORITY CATERERS ASSOCIATION LONDON BOROUGH OF BRENT (ENVIRONMENTAL HEALTH) LONDON BOROUGH OF EALING LONDON BOROUGH OF ENFIELD LONDON BOROUGH OF HARROW LONDON BOROUGH OF HAVERING LONDON BOROUGH OF SOUTHWARK LONDON CENTRAL MARKETS LONDON CHAMBER OF COMMERCE AND INDUSTRY LONDON FOOD CO-ORDINATING GROUP LONDON FOOD STUDY GROUP LONDON RETAIL MEAT TRADERS ASSOC LTD LONG ASHTON RESEARCH ASSOCIATION LONGDAY FOODS LTD LOOE FISHERMEN'S PROTECTION SOCIETY LOVELL WHITE DURRANT LOWESTOFT FISH PRODUCERS' ORGANISATION LTD LOWESTOFT INSHORE FISHING VESSEL OWNERS' ASSOCIATION

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LOWESTOFT TRAWL FISH MERCHANTS' ASSOCIATION LTD LYNDALE FOODS LTD M & J SEAFOODS M D C FOODS LTD MACCLESFIELD BRANCH OF THE NFU MACFARLANES MALTON BACON FACTORY LTD MALTSTERS ASSOC OF GREAT BRITAIN MALVERN CHEESEWRIGHTS MANOR BAKERIES LTD MANSFIELD COMMUNITY HOSPITAL MAPLE LEAF FOODS UK LTD MAPLE LEAF MILLS LTD MARCUSE GLUES AND CHEMICALS MARDON PLC MARKS & SPENCER PLC MARLOW FOODS LTD MARR FOODS LIMITED MARS CONFECTIONERY LTD MARSHALL FARMER LTD MARUBENI EUROPE PLC MARYVALE FARMS MATERNITY ALLIANCE MATTHEW CLARK PLC MCCONOMY & CO LTD MCCORMICK (UK) PLC MCDONALDS'S RESTAURANTS LTD MCKENNA AND CO MCKEY FOOD SERVICE LTD MD FOODS PLC MEAD JOHNSON NUTRITIONALS MEADOW VALE FOODS LTD MEAT & LIVESTOCK COMMISSION MEAT HYGIENE SERVICE MEAT INDUSTRY LIAISON GROUP MEAT TRAINING COUNCIL MEDEVA PHARMA MEDICAL AND VETERINARY SUPPLIES LTD MEDICAL RESEARCH COUNCIL MEDICINESAND HEALTHCARE PRODUCTS REGULATION AGENCY MELIA WHITE HOUSE HOTEL - LOMONDO LTD MELLING AND ARDERN LTD MERCK LTD MERRYDOWN WINE PLC METROPOLITAN POLICE SERVICE MICHAEL TREND MP MICROFERM LIMITED MICRON2 MICROPHARM MIDDLE ENGLAND FINE FOODS MIDWIVES INFORMATION & RESOURCE SERVICE MIKE GILES MEAT LTD

MILK DEVELOPMENT COUNCIL MILK FOR SCHOOLS MILK QUALITY FORUM MILL STREET MILLENNIUM FRESH FOODS LTD MILLFORD HAVEN SHELLFISHERMEN'S ASSOCIATION MILUPA LIMITED MINSTREL PA SOLUTIONS LTD MJSR ASSOCIATES MONARCH FOOD INT LTD MONITOR GROUP MONSANTO PLC MOULVALEY FARMERS LTD MR J MAKIN MR R MCKINLEY MRS EM FARLEY MRS M YOUNGS MRS S EADE MRS V GARLAND MS P MARGIOTTA MS S BOND MULTILABELS MUREX BIOTECH LTD MURRAY VERNON LTD MUSKAAN LTD BRIGHOUSE BUSINESS VILLAGE N.I. AGRICULTURAL PRODUCERS' ASSOCIATION N.I. FOOD & DRINK ASSOCIATION N.I. MEAT EXPORTERS ASSOCIATION NABMA NATIONAL ANIMAL HEALTH & WELFARE PANEL NATIONAL ASSOCIATION FOR MATERNAL & CHILD WELFARE NATIONAL ASSOCIATION OF MASTER BAKERS NATIONAL CONSUMER FEDERATION NATIONAL FEDERATION OF FISHMONGERS LTD NATIONAL ASSN. OF POULTRY SUPPLIERS NATIONAL ASSOCIATION OF BRITISH AND IRISH MILLERS NATIONAL ASSOCIATION OF CATERING BUTCHERS NATIONAL ASSOCIATION OF CIDER MAKERS NATIONAL ASSOCIATION OF CITIZENS ADVICE BUREAUX NATIONAL ASSOCIATION OF HEALTH STORES NATIONAL ASSOCIATION OF MASTER BAKERS, CONFECTIONERS AND CATERERS NATIONAL ASSOCIATION OF PERRY MAKERS NATIONAL ASSOCIATION OF SPECIALITY FOOD & DRINK PRODUCERS

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NATIONAL ASSOCIATION OF SPFDP: FOOD FROM NORTHUMBERLAND NATIONAL ASSOCIATION OF SPFDP: HAMPSHIRE FARE NATIONAL ASSOCIATION OF SPFDP: ISLE OF WIGHT FINE FOODS NATIONAL ASSOCIATION OF SPFDP: KENTISH FARE NATIONAL ASSOCIATION OF SPFDP: MIDDLE COUNTIES SPECIALITY FOODS NATIONAL ASSOCIATION OF SPFDP: SHIRE FOODS NATIONAL ASSOCIATION OF SPFDP: TASTE OF ANGLIA NATIONAL ASSOCIATION OF SPFDP: TASTE OF THE SOUTH EAST LTD NATIONAL ASSOCIATION OF SPFDP: TASTE OF THE WEST NATIONAL ASSOCIATION OF SPFDP: YORKSHIRE PANTRY NATIONAL ASSOCIATION OF WOMEN'S CLUBS NATIONAL BEEF ASSOCIATION NATIONAL BOARD OF CATHOLIC WOMEN NATIONAL CHILDBIRTH TRUST NATIONAL CONSUMER COUNCIL NATIONAL CONSUMER FEDERATION NATIONAL DAIRYMEN'S ASSOCIATION NATIONAL DRIED FRUIT TRADE ASSOCIATION NATIONAL EDIBLE OIL DISTRIBUTORS ASSOCIATION NATIONAL FARMERS UNION ENGLAND & WALES NATIONAL FARMERS' UNION (ENGLAND) NATIONAL FEDERATION OF INLAND WHOLESALE FISH MERCHANTS NATIONAL FEDERATION OF BRITISH PORT WHOLESALE FISH MERCHANTS NATIONAL FEDERATION OF FISH FRYERS LTD NATIONAL FEDERATION OF FISHERMEN'S ORGANISATION NATIONAL FEDERATION OF POULTRY MEAT MERCHANTS NATIONAL FEDERATION OF WOMEN'S INSTITUTES NATIONAL GAME DEALERS ASSOCIATION NATIONAL GAMEKEEPERS ORGANISATION NATIONAL HEART FORUM NATIONAL INSTITUTE OF MEDICAL HERBALISTS LTD NATIONAL MEAT TRADERS ASSOCIATION NATIONAL OFFICE OF ANIMAL HEALTH NATIONAL PHARMACEUTICAL ASSOC NATIONAL RENDERERS ASSOCIATION NATIONAL RESOURCES RESEARCH DEPARTMENT

NATIONAL SHEEP ASSOCIATION NATURAL ADHESIVE CO LTD NATURAL RESOURCE INSTITUTE NCH ACTION FOR CHILDREN NESTLE UK LTD NET-TEX AGRICULTURE LTD NETHER HALL NEW PRIMEBAKE NEW ZEALAND MISSION TO THE EUROPEAN COMMUNITIES NEWHAVEN (SUSSEX) FISH & FLAKE ICE SOCIETY LTD NEWLYN FISH MERCHANTS' ASSOCIATION NEWSPAPER SOCIETY (THE) NEX-TEX AGRICULTURAL NORFOLK RURAL COMMUNITY COUNCIL NORTH DERBYSHIRE HEALTH AUTHORITY NORTH EASTERN SEA FISHERIES COMMITTEE NORTH HERTFORDSHIRE NHS TRUST NORTH SEA FISHERMENS' ORGANISATION LTD NORTH WESTERN & NORTH WALES SEA FISHERIES COMMITTEE NORTHAMPTONSHIRE COUNTY COUNCIL NORTHUMBERLAND SEA FISHERIES COMMITTEE NORTON ROSE NORWEGIAN FOOD CONTROL AUTHORITY NOTTINGHAM CITY HOSPITAL TRUST NOTTINGHAM TRENT UNIVERSITY NOTTINGHAMSHIRE COUNTY COUNCIL NOVARTIS CROP PRODUCTION UK LTD NPA NUTRICIA NUTRITION AND DIETETIC DEPARTMENT NYLABONE LTD OAKFIELD (FOODS) LTD OAKLAND FAST FOOD OAKLEIGH MANUFACTURING ORNAMENTAL FISH INDUSTRY UK LTD OSGROW 2000 OXFORD DIOCESAN SYNOD OXFORDSHIRE COUNTY COUNCIL OXOID LTD PAI LTD PASTA FOODS LTD PASTA REALE PEEL HOLROYD & ASSOCIATES PEERLESS FOOD PRODUCTS PEPSI COLA INTERNATIONAL PERCHARD'S PERFECTA FOOD INGREDIENTS PERIODICAL PUBLISHERS ASSOCIATION PERRY SCOTT NASH

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PERSHORE GROUP OF COLLEGES PESTICIDES ACTION NETWORK UK PET CARE TRUST PET FOOD MANUFACTURERS ASSOCIATION PETER BLACK HEALTHCARE LTD PETER THOMSON GROUP PLC PETER VASSALLO LTD PETTIFOR MORROW PICKLES AND SAUCES ASSOCIATION PILSBURY PIZZA TWO FOUR LTD PLAIN ENGLISH CAMPAIGN PLUMA UK LTD PLYMOUTH CONSUMER GROUP PLYMOUTH TRAWLERS OWNERS' ASSOCIATION POLAR FURS LTD POLITICS INTERNATIONAL POOLE AND DISTRICT FISHERMEN'S ASSOCIATION PORT SUTTON BRIDGE LTD POTATO GROWERS ACTION GROUP POTATO MARKETING BOARD POULTRY CLUB OF GREAT BRITAIN POULTRY WORLD PRE-PACKED FLOUR ASSOCIATION PRECISION LABELLING SYSTEMS LTD PREMIER INTERNATIONAL FOODS PREPARED FISH PRODUCTS ASSOCIATION PRESTON COUNTY LABORATORY PRINCES SOFT DRINKS PROCESS QUALITY MANAGEMENT GROUP PROCHILE PROTEIN TECHNOLOGY INTERNATIONAL PROVISION TRADE FEDERATION LTD PUBLIC HEALTH LABORATORY SERVICE PUBLIC HEALTH MEDICINE ENVIRONMENTAL GROUP PURA FOODS LTD Q LABORATORIES LTD QUAKER OATS LTD QUALITY ASSURANCE DEPARTMENT QUALITY MILK PRODUCERS LTD QUEEN ELIZABETH HOSPITAL QUEST INTERNATIONAL R F BROOKES R P M INTERNATIONAL LTD R.N.I.B. RALSTON PURINA RANK HOVIS LTD RARE BREEDS SURVIVAL TRUST LTD RAY WHITNEY ESQ OBE MP RCC REGISTRATION AND REAPERS REED BUSINESS PUBLISHING

REFERENCE AND INFORMATION LIBRARY REFRIGERATED FOOD INDUSTRY CONFEDERATION REFRIGERATION INDUSTRY BOARD REGULATORY AFFAIRS JOURNAL REINDEER FOODS LIMITED RESPONSIBLE USE OF MEDICINES IN AGRICULTURE (RUMA) ALLIANCE RGB COFFEE LTD RHM FOODSERVICE RHM FROZEN FOODS LTD RHM INGREDIENT SUPPLIES LTD RHM TECHNOLOGY LTD RIDPATH PEK LTD RIO PACIFIC FOOD SEVICES LTD (FUNNYBONES) RIO TRADING CO (HEALTH)LTD RIVERSIDE ANIMAL FEEDS RME ASSOCIATES ROAD HAULAGE ASSOCIATION LTD ROBERT JACKSON MP ROCHE CONSUMER HEALTH ROCHE PRODUCTS LIMITED RODFIELDS LTD ROSE MAUND EXPERIMENTAL FARM ROSEMEAD 105 ROSS YOUNGS INTERNATIONAL LTD ROTHERHAM HEALTH AUTHORITY ROYAL ASSOCIATION OF BRITISH DAIRY FARMERS ROYAL COLLEGE OF GENERAL PRACTITIONERS ROYAL COLLEGE OF MIDWIVES ROYAL COLLEGE OF NURSING ROYAL COLLEGE OF OBSTETRICIANS ROYAL COLLEGE OF PAEDIATRICS AND CHILD HEALTH ROYAL COLLEGE OF PATHOLOGISTS ROYAL COLLEGE OF VETERINARY SURGEONS ROYAL DANISH EMBASSY ROYAL INSTITUTE OF PUBLIC HEALTH AND HYGIENE ROYAL NETHERLANDS EMBASSY ROYAL PHARMACEUTICAL SOCIETY OF GREAT BRITAIN. ROYAL SOCIETY OF HEALTH RSPCA RUDDOCK & SHERRATT RUDOLPH DESCO LTD RVC RYECROFT FOODS LTD RYVITA CO LTD S MOORES S.M.A. NUTRITION

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SAFEPHARM LABORATORIES LTD SAFEWAY STORES PLC SAINSBURY'S SUPERMARKETS LTD SALMON AND TROUT ASSOCIATION SALT UNION MANUFACTURERS LTD SAMSON GEMMEL CHAIR SAMUEL SMITH BREWERY SANDERS PRODUCTS LTD. SANDWELL INFORMATION SERVICE SARA LEE PERSONAL CARE UK LTD SBS/REGULATORY ISSUES TEAM SCHOOL OF SCIENCE AND TECHNOLOGY SCHOOL OF VETERINARY SCIENCE SCHWEPPES EUROPE SCOTTISH CONSUMER COUNCIL SCOTTISH DAIRY ASSOCIATION SCOTTISH EXECUTIVE RURAL AFFAIRS DEPT. SCOTTISH FOOD CO-ORDINATING COMMITTEE SCOTTISH LANDOWNERS FEDERATION SDF FOODS LTD SDIA SEA FISH AUTHORITY SEA FISH INDUSTRY AUTHORITY SEAFOOD LABORATORIES LTD SEAFOOD MARKETING INTERNATIONAL PLC SEAFOOD PROCESSORS ASSOCIATION LTD. SEASONING AND SPICE ASSOCIATION SEED CRUSHERS & OIL PRODUCERS ASSOCIATION SEROTEC LTD SEVEN SEAS LTD SHELLFISH ASSOCIATION OF GREAT BRITAIN SHS INTERNATIONAL LTD SIGMA ALDRICH CO LTD SIMMONS AND SIMMONS SIMPKINS PARTNERSHIP SINCLAIR ANIMAL & HOUSEHOLD CARE LTD SLOUGH BOROUGH COUNCIL SMALL BUSINESS SERVICE SMALL INDEPENDENT BREWERS ASSOCIATION SMITHFIELD MURRAY SMITHKLINE BEECHAM CONSUMER CARE SNACK, NUT AND CRISP MANUFACTURERS, ASSOCIATION SOCIETY FOR PROMOTION OF NUTRITIONAL THERAPY SOCIETY OF DAIRY TECHNOLOGY SOCIETY OF FOOD HYGIENE TECHNOLOGY SOIL ASSOCIATION SOMERFIELD STORES LTD SOMERSET COUNTY COUNCIL SOMERSET SCIENTIFIC SERVICES SONEVOL S.A.

SOUP & GRAVY MANUFACURERS ASSOC SOUTH AFRICAN HIGH COMMISSION SOUTH BANK UNIVERSITY SOUTH DEVON & CHANNEL SHELFISHERMEN LTD SOUTH EAST FISHERMEN'S FEDERATION SOUTH WEST HANDLINE FISHERMEN'S ASSOCIATION SOUTH WESTERN FISH BUYER'S AND PROCESSORS' ASSOCIATION SOUTH WESTERN FISH PRODUCERS' ORGANISATION LTD SOUTHERN COMMERCIAL FISHERMEN SOUTHERN SEA FISHERIES COMMITTEE SOUTHERN SEA FISHERIES DISTRICT FISHERMEN'S COUNCIL SOUTHRIDGE ASSOCIATES SOUTHWARK PUBLIC ANALYST DEPARTMENT SOVEREIGN FOOD GROUP SPECIALIST CHEESEMAKERS ASSOCIATION ST BARTHOLOMEWS HOSPITAL ST IVEL LTD ST IVEL PROVISIONS ST MARY'S STAFFORDSHIRE COUNTY COUNCIL STATES COMMITTEE FOR AGRICULTURE STATION ROAD STEPHEN RHODES ASSOCIATES (SRA) STILTON CHEESE MAKERS' ASSOCIATION STOCKTON HIDE & SKIN CO LTD STRATEGIC AFFAIRS DIRECTOR STRATEGY RESEARCH & ACTION LTD STRATFORD UPON AVON FOODS STUTE FOODS LTD SUFFOLK SMALL HOLDERS ASSOCIATION SUGAR BUREAU SUPERSIRES LTD SUPPORT TRAINING SERVICES LTD SURREY TRADING STANDARDS SUSSEX GAME FARM SUSSEX SEA FISHERIES COMMITTEE SUSTAIN - THE ALLIANCE FOR BETTER FOOD AND FARMING SUTTON LONDON BOROUGH OF SVS DEFRA SWIFT COMPUTER SYSTEMS T&GWU FOOD DRINK AND TOBACCO GROUP TAMESIDE M B C TAS INTERNATIONAL TATE & LYLE TATE & LYLE EUROPE TCS CELLWORKS LTD TEA PACKERS ASSOC TEC INDEXIES TECHNICAL INDEXES

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TESCO PLC TESCO STORES LTD TETLEY GB LTD THAMES VALLEY SCHOOL OF HOSPITALITY STUDIES THAMES VALLEY UNIVERSITY THAMES VALLEY UNIVERSITY WOLFSON INSTITUTE OF HEALTH SCIENCES THE FOOD CLUB THE AIR CONDITIONING AND REFRIGERATION INDUSTRY BOARD THE ALLIANCE OF INDEPENDENT RETAILERS THE BCCA THE BINDING SITE LTD THE BISCUIT, CAKE, CHOCOLATE & CONFECTIONERY ALLIANCE THE BRISTOL PORT COMPANY THE BRITISH ASSOCIATION FOR SHOOTING AND CONSERVATION THE BRITISH DEER SOCIETY THE BRITISH INSTITUTE OF CLEANING SCIENCE THE BRITISH MEDICAL ASSOCIATION THE BRITISH OAT AND BARLEY MILLERS ASSOCIATION THE BRITISH RETAIL CONSORTIUM THE BRITISH SHEEP DAIRYING ASSOCIATION THE CHINESE TAKEAWAY ASSOCIATION (UK) THE CLERK AND SUPERINTENDENTS OFFICE THE COFFEE TRADE FEDERATION THE COOKERY & FOOD ASSOCIATION THE DAIRY COUNCIL FOR NORTHERN IRELAND THE FERTILIZER MANUFACTURERS ASSOCIATION THE FISH PRODUCERS' ORGANISATION LTD THE FLOUR MILLING & BAKING RESEARCH ASSOCIATION THE FOOD CONSULTANCY THE FOOD HYGIENE BUREAU LTD THE FREEDOWN FOODS CO LTD THE GAME FARMERS ASSOCIATION THE GROSVENOR CONFECTIONERY COMPANY THE GUILD OF FINE FOOD RETAILERS C/O FORTNUM & MASON PLC THE INCORPORATED NATIONAL ASSOCIATION OF BRITISH & IRISH MILLERS LTD THE INSTITUTE OF REFRIGERATION THE INTERNATIONAL SOCIETY FOR PHENYLKE THE LAW SOCIETY OF SCOTLAND THE LONDON SCHOOL OF ECONOMICS AND POLITICAL SCIENCE

THE MILL HOUSE THE NATIONAL DAIRY COUNCIL THE NATIONAL FEDERATION OF MEAT AND FOOD TRADERS THE NATIONAL FOOD ALLIANCE FOR BETTER FOOD AND FARMING THE NEWSPAPER SOCIETY THE PIZZA , PASTA & FOOD ASSOCIATION THE PORT OF FELIXSTOWE THE POTATO PROCESSORS ASSOCIATION THE RAYNE INSTITUTE THE RESTAURANT ASSOCIATION THE RICE ASSOCIATION THE ROAD HAULAGE ASSOCIATION LTD THE ROYAL COLLEGE OF PAEDIATRICS AND CHILD HEALTH THE ROYAL COLLEGE OF PHYSICIANS THE ROYAL COLLEGE OF SURGEONS OF ENGLAND THE ROYAL SOCIETY FOR THE PROMOTION OF HEALTH THE RT HON JOHN PATTEN MP THE SAINSBURY LABORATORY THE SCOTCH WHISKY ASSOCIATION THE SEAHAM HARBOUR DOCK COMPANY THE SOCIETY OF FOOD HYGIENE TECHNOLOGY THE SOCIETY OF INDEPENDENT BREWERS THE SOCIETY OF OCCUPATIONAL MEDICINE THE SUGAR BUREAU THE UK FEDERATION OF F.A.C.E THE UK RENDERER'S ASSOCIATION THE UNION OF INDEPENDENT COMPANIES THE UNITED REFORM CHURCH THE WHITEHOUSE CONSULTANCY LIMITED THE WINE AND SPIRIT ASSOCIATION OF GREAT BRITAIN AND NORTHERN IRELAND THE WOMENS ENVIROMENTAL NETWORK THE WORSHIPFUL COMPANY OF BUTCHERS THERAPEUTIC ANTIBODIES THOMAS EUROPE THOMPSON AND CAPPER LTD THORNTONS PLC TILBURY CONTAINER SERVICES TIM BRIDGESTOCKE ASSOCIATES TOWN AND COUNTRY PETFOODS LTD TOWNSWOMENS' GUILDS TRADE UNION CONGRESS TRADING STANDARDS INSTITUTE TRADITIONAL FARM FRESH TURKEY ASSOC TRANSOCEANIC MEAT CO LTD TRANSPORT & GENERAL WORKERS UNION TREATS ICE CREAM LTD TULIP INTERNATIONAL (UK) TULIP INTERNATIONAL (UK) LTD

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VEGA RESEARCH UK ASSOCIATION OF FISH MEAL MANUFACTURERS VEGAN SOCIETY (THE)

VEGETARIAN ECONOMY AND GREEN ALLIANCE

UK ASSOCIATION OF FROZEN FOOD PRODUCERS (UKAFFP)

VERNER WHEELOCK ASSOCIATES LTD UK ASSOCIATION OF MANUFACTURERS OF BAKERS YEAST VETERINARY CLINICAL SCIENCE DEPT

VILIGANT COMMUNICATION UK CHEESE GUILD VILLA SOFT DRINKS LTD UK COMMITTEE FOR UNICEF VITACARE LTD UK FISH MERCHANTS' AND PROCESSORS'

ASSOCIATION VIVA VOLUNTARY ACTION CUMBRIA UK MAIZE MILLERS' ASSOCIATION WAFCOL CA DIVISION OF ARMITAGE BROS PLC

UK REGISTER OF ORGANIC FOOD STANDARDS (UKROFS)

WAGG FOODS LTD UK RENDERERS ASSOCIATION LTD WAITROSE LTD UK SWEET SPREAD ASSOCIATION WALKER & SONS (LEICESTER) LTD ULLAPOOL BOAT OWNERS' ASSOCIATION WALSALL METROPOLITAN BOROUGH COUNCIL

ULSTER FARMERS UNION UNIGATE (ST IVEL )

WANDSWORTH COMMUNITY HEALTH COUNCIL

UNIGATE EUROPEAN FOOD UNIGREG LIMITED

WARBURTONS LTD UNILEVER PLC WARNER LAMBERT CONFECTIONERY UNION OF CONSTRUCTION, ALLIED TRADES

AND TECHNICIANS WARRANT LOGISTICS LTD WASTE FOOD FEEDERS ASSOCIATION UNION OF SHOP DISTRIBUTIVE AND ALLIED

WORKERS WATCHBEL LTD WEDDEL SWIFT UNIPATH LTD WEETABIX LTD UNISON WEST DORSET SAFE ENERGY CAMPAIGN UNITED BISCUIT UK LTD WEST YORKSHIRE COUNTY COUNCIL UNITED FISHERMEN'S ASSOCIATION WESTERN RESEARCH LABORATORIES UNITED GROUP RMD WESTLER UNITED KINGDOM REGISTER OF ORGANIC

FOOD STANDARDS WHITBREAD PLC WHITWORTHS FOODS GROUP LTD UNITED STATES EMBASSY (USDA) WI COUNTRY MARKETS LTD UNIVERSAL TRADER LTD WILLIAM MORISON SUPERMARKET UNIVERSE FOODS INGREDIENTS WILTS. TRADING STANDARDS DEPT. UNIVERSITY OF BIRMINGHAM WILTSHIRE DIRECT SERVICES UNIVERSITY OF BRISTOL WINE AND SPIRIT ASSOC UNIVERSITY OF CENTRAL LANCASHIRE WINE STANDARDS BOARD UNIVERSITY OF HUDDERSFIELD WIRRAL FOODS LTD UNIVERSITY OF LEICESTER WOMEN'S FOOD AND FARMING UNION UNIVERSITY OF LIVERPOOL WOMEN'S NATIONAL COMMISSION UNIVERSITY OF NEWCASTLE WORCESTER COUNTY COUNCIL UNIVERSITY OF NOTTINGHAM WORCESTER SCIENTIFIC SERVICES UNIVERSITY OF READING XYROFIN (UK) LTD UNIVERSITY OF SURREY YORK NUTRITIONAL LABORATORY UNIVERSITY OF SUSSEX YORKSHIRE AND ANGLIA FISH PRODUCERS' ORGANISATION LTD

UPS VAN DEN BERGH FOODS LTD

YORKSHIRE PANTRY (THE) VAN LUIN POULTRY & MEAT PRODUCTS LTD ZENECA BIO PRODUCTS VANDERMOORTELE (UK) LTD

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