HACCP and trade

The Final Act of the Uruguay Round of the General Agreement on Tariffs and Trade (GATT), particularly the Agreement on the Application of Sanitary and Phytosanitary Measures (the “SPS Agreement”) and the Agreement on Technical Barriers to Trade, has significant implications for the Codex Alimentarius Commission. Specifically, Codex standards, guidelines and other recommendations have been identified as the baseline for consumer protection under the SPS Agreement. In this environment they take on unprecedented importance with respect to consumer protection and international food trade, As a result, the work of the Codex Alimentarius Commission (including the Guidelines for the Application of the HACCP System) has become the reference for international food safety requirements. Thus it is imperative that the Codex guidelines for the application of HACCP be unequivocal; otherwise conflicts on food safety grounds may arise.

While the improved level of food safety associated with implementation of HACCP and the leading role taken by the food industry are recognized, the application of HACCP as a public policy requires definition of the role of government in the HACCP process. Recent moves by some importing countries to require application of HACCP principles by exporting countries to food produced for export may result in significant trade barriers for countries unable to meet these requirements, The mandatory requirement to use HACCP and any subsequent barriers or other constraints to trade for developing countries need to be considered and identified, Application of HACCP to all segments of the food chain and the impact of this application on small and medium-sized food industries should also be addressed.