What Members of the European Parliament need to know to call for a science-based regulation for food safety in the European fish processing industry

In December 2023, the European Commission proposed a Delegated Regulation setting new standards for the fish processing industry in Europe. 

The Delegated Regulation targets a key processing step in the production of smoked salmon, called stiffening. Stiffening consists in reducing the ambient temperature between -4 and -14°C to slice the smoked salmon. This passage ensures safety and quality throughout the production of smoked salmon, and is carried out under recognised sectoral guidelines known as the HACCP standards. 

The proposed Delegated Regulation limits the stiffening period to 96 hours, consequently prohibiting already proven safe procedures in place and authorised in several Member States. If enforced, these proposed changes will cause a shift in the entire European industry to less safe practices, increasing food safety risks like the presence of bacteria (listeria) and food waste. Consequences will include shortage of smoked salmon in the EU market, ultimately raising product prices and endangering thousands of industry jobs, the costs of which will be borne by millions of EU consumers and workers. 

The Polish Association of Fish Processors (PSPR) and its members have repeatedly expressed concerns about the proposed time period for stiffening. Despite multiple requests from the industry, the Commission has decided to adopt the Delegated Regulation without requesting the expert opinion of the European Food Safety Authority (EFSA). PSPR wishes to highlight that the Commission, under EU law, has to consult EFSA on food safety legislation. In developing these new legal standards, the Commission relied solely on a single recommendation from the European Salmon Smokers Association (ESSA), which is not representative of the entire European industry, but only a fraction of it. 

PSPR is convinced that EFSA’s opinion is essential to the Delegated Regulation’s scope as it would provide the needed scientific evidence that the proposed 96-hours’ time limitation to the stiffening period is indispensable to ensure the safety and quality of the processed fish products in large scale production. PSPR would like to clarify that the Polish industry is not against a time limitation to stiffening and it is committed to adjust to all new measures that will come forth from EFSA’s opinion.

In numerous occasions, the European Commission called on breaches to the EU legislation made by the industry, in particular in Poland, to justify the absence of an EFSA consultation in the process. This argument however lacks substance: any amendment to the legislation should be supported by an EFSA opinion.

PSPR wishes to highlight that the industry it represents desires nothing more than to maintain the quality of its products for its consumers and protect the job of its workers, in the respect of European legislation and a level playing field among European companies to employ different procedures that provide the highest food safety in accordance with HACCP standards.

In light of the consequences that the Delegated Regulation will have on the European market, a Motion for Resolution has been tabled calling to reject the proposed act to the upcoming plenary session of 10-11 April 2024.

Underlining the need for a robust scientific foundation to evaluate the influence of stiffening time on processed fish product safety, quality, and consumer well-being, PSPR calls on the Members of the European Parliament to support the Motion for Resolution by rejecting the Commission’s proposed Delegated Regulation and referring it back to the European Commission with the recommendation to request scientific evidence provided by EFSA.