Entrepreneurial Scan.
We ask that you first fill in the information below so that we can email you the results of the scan afterwards. That way you will receive a reference book that you can use as a guide for any subsequent steps.
Have you disclosed your business to NVWA?
The NVWA (Dutch Food and Consumer Product Safety Authority) stands for the safety of food and consumer products, animal welfare and nature. On the website of the NVWA (www.nvwa.nl) you can find a lot of information about what you have to comply with as an entrepreneur. Among other things, based on European rules, there is an obligation to register as a company with the NVWA.
That's a good start! Every company must register with the NVWA. It supervises all companies in the food sector (and in the non-food sector, for that matter).
Every company is required to register with the NVWA, which oversees all companies in the food sector (and in the non-food sector, for that matter).
You can register your company through the NVWA website.
Is there an approved hygiene code available for your industry?
Every food company is obliged to guarantee the food safety of the products it puts on the market. For all companies where physical products are present (made, handled, processed, packaged, stored and/or transported), the so-called "Basic Conditions" apply. These are requirements imposed on building, rooms, equipment and personnel facilities, among others. Collectively, they ensure hygienic conditions for the production and/or storage of foodstuffs. A hazard and risk analysis must also be conducted. The method followed for this is called "HACCP."
Hazard Analysis and Critical Control Points
The whole of hazard and risk analysis with resulting measures and controls is therefore also called "HACCP study."
A generic HACCP study has been developed for certain industries, which can be applied to any company in that industry. These are the so-called 'Hygiene Codes'. The NVWA has approved a number of hygiene codes as an alternative to their own HACCP study. This makes it easier for smaller companies in particular to comply with food safety legislation.
If a hygiene code exists for your industry, you can still choose to do your own HACCP study. This is necessary, for example, if you would like to have your food safety system certified (about which more below). Also when the hygiene code does not cover exactly all your business processes, it is necessary to perform an additional HACCP study.
Then, as far as food safety is concerned, you can suffice by applying all the rules in this code.
Have you already conducted an HACCP study?
Very good! For all business processes involving food (including raw and semi-manufactured materials), food safety hazards should be identified, control measures implemented and any critical control points (CCPs) identified.
This applies not only to activities such as transportation, goods receiving, production, packaging and storage. A hazard and risk analysis must also be worked out for the raw and auxiliary materials that are purchased. When you import finished products from outside the EU, you are considered a producer in terms of product liability and the HACCP obligation also applies to you. An HACCP study is also mandatory when you trade end products within the EU.
For all business processes involving food (including raw and semi-manufactured materials), food safety hazards should be identified, control measures implemented and any critical control points (CCPs) identified.
This applies not only to activities such as transportation, goods receiving, production, packaging and storage. A hazard and risk analysis must also be developed for the raw and auxiliary materials that are purchased. When you import finished products from outside the EU, you are considered a producer in terms of product liability and the HACCP obligation applies to you as well. An HACCP study is also mandatory when you trade end products within the EU.
NVWA explains food safety management throughout the chain:
Doing HACCP yourself
If you need or want to set up your own HACCP study, you must adhere to the legally prescribed HACCP method. In outline, this includes the following steps:
- Inventory all possible food safety hazards that could occur in your process or may already be present in raw or auxiliary materials. As an aid to determine relevant hazards, legislation is consulted. For example, European legislation sets product standards for various hazards; examples are:
Microbiological criteria ((EC) 2073/2005)
Contaminants in food (EU) 2023/915 - Estimate the probability of those hazards and, combined with severity, determine the risk.
- Identify measures needed to control hazards and identify critical control points (CCPs).
- For each CCP, indicate the critical limits.
- Establish how CCPs are monitored.
- For each CCP, record the corrective actions for when an error is noticed and a potentially unsafe product has been produced.
- Organize periodic verification (evaluation), to check if the process is producing the desired result: demonstrable food safety.
- Keep documentation (agreements and/or work instructions, collected in a handbook, for example) and records (recorded control results).
Do you have a procurement procedure in place?
In addition to a food safety plan based on HACCP, other legal obligations apply:
Purchasing procedure: this should set out the requirements you set for your suppliers and any service providers; obviously these are related to the risk that a purchased raw material or service carries. The raw material hazard analysis, part of the HACCP study, therefore forms the basis.
Note! Service providers can also influence food safety! For example: pest exterminator, cleaning company, product analysis laboratory, clothing laundry, waste handler and technical maintenance mechanics.
That's great!
Remember that vendor performance should be assessed regularly.
It is very important to still establish a procurement procedure.
Do you have a recall procedure and tracking system in place?
Recall Procedure: Every food company is required to be able to recall its products from the market when they are found to be potentially unsafe. There is a legally required deadline of 4 hours (in Regulation 178/2002). For the recall procedure a procedure should be in place that describes the necessary steps to carry out the recall.
A mandatory part of the procedure is the notification of (possibly) unsafe food to the NVWA. On the website you will find further instructions and the link to the digital reporting form.
Traceability: in order to carry out a recall, a traceability system should be in place that allows products to be traced back one link back and one link forward in the chain: from which supplier did a raw material originate and to which customer(s) was a product delivered?
Very good!
Make sure that the procedure is tested regularly and that it is certain that you can trace the products in both directions.
To avoid having to think about how to carry out the recall at the time of an incident, it is mandatory to have this defined in a procedure. The procedure should also be tested regularly to make sure that you can trace your products in both directions.
Do you have a grievance procedure with a record-keeping system?
Complaints procedure: you should offer your customers an opportunity to report product deviations. Any complaint (or a series of similar complaints) could be an indication that you do not have your process under control and should be followed up with a cause investigation and improvement action.
Good job
Provide regular complaint analysis, to quickly identify and follow up on any "trends" (e.g., a repetition of the same complaint, from multiple customers).
Establish working methods so that tasks and responsibilities in your organization are clear to all employees (also useful for a very small company, to establish and remember a set way of working). Also consider regular complaint analysis to quickly identify and follow up on any "trends" (e.g., a repetition of the same complaint, from multiple customers).
Do you market pre-packaged finished products intended for consumers?
Labeling: when you are responsible for packaging, which is intended for consumers, legal requirements apply to you.
Your product information on packaging (printing, labels) and also any product information on a website (web shop) must comply with the labeling requirements according to Regulation (EU) No. 1169/2011.
Article 9 of this regulation lists all the information that must appear on the packaging. These include information such as the commodity product name, list of ingredients, allergens and nutritional values.
Raw material/product specifications from your supplier are required to produce complete, legal product information.
The regulation also specifies the minimum information that should appear on a secondary packaging (such as a carton box).
Do you list the contents of a package with the e-sign?
Specific product information, to be displayed on label: declaration of contents with e-sign.
Then your company must set up a company control system (e-sign system) in accordance with "Commodities Act Decree quantities for pre-packaging" and have this system recognized by the NMi.
Then you should always deliver at least the weight (or number) stated on the package. Of course, this will have to be checked regularly.
Moreover, it is important, that you be sure that the scale reads the correct weight. For this, calibration is necessary.
In your business, do you work with scales, thermometers or perhaps other measuring devices?
Remember to calibrate your measuring equipment. It is important to make sure that your equipment indicates the correct measurement value. For example, you are supposed to provide the customer with the correct (agreed upon and stated on the packaging) weight. But also, for example, a thermometer must indicate the correct value to be sure that a heating or cooling operation is correct. There are also products where pH determines food safety. In that case, the pH meter must be calibrated.
Do you pack food products?
The packaging material must be suitable for food packaging. No harmful substances may penetrate ("migrate") from the material into the product. Legislation applies to this. This legislation must be demonstrably complied with. This can be done through results of migration tests, a calculation in software or through so-called worst-case calculations. In some cases, such as plastic, a declaration of conformity is also required. If you do not change the packaging yourself, you can request the documents from the supplier.
Make sure your product falls within the range of suitability specified by the supplier. For example, some packaging materials are suitable for packaging dry powders. This does not mean that the packaging material is also suitable for packaging liquids. Suitability must be demonstrated by reported migration tests (mentioned in the statement).
Note: The legal requirements apply not only to packaging materials, but also to all materials in your process (equipment) that make contact with raw material, semi-finished or finished product.
Do you want (or need) to get food safety certification?
It is possible to have your food safety system certified. This is not required by law, but is often expected or even required by retailers and other companies in the food industry. Commonly used certification schemes are: BRCGS, IFS and FSSC 22000. These standards are primarily intended for manufacturers, but usually also have a special variant for trading companies or logistics service providers, for example.
Meeting the legal obligations is then sufficient.
Want to display a seal of approval on your product?
Companies are increasingly opting for a certain label, for example vegetarian, vegan, gluten-free, fair trade, Halal or Kosher, for reasons of sustainability, religious beliefs and/or health. However, these kinds of logos are not allowed to simply appear on packaging. For this, the relevant foundation imposes requirements on the product, the ingredients and often also on the production process.
To be allowed to call a product "organic," there is even a legal requirement to obtain a Skal certificate.
Closing
Thank you for completing the 'Entrepreneur Scan'!
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