This website uses cookies so that we can provide you with the best user experience possible. Cookie information is stored in your browser and performs functions such as recognising you when you return to our website and helping our team to understand which sections of the website you find most interesting and useful.
2023.09.05
Reference response to the Swedish National Food Agency
Swetic is generally positive about the Swedish Food Agency's referral and welcomes the proposed expansion of control. Major innovation is currently underway in both snus-like products and contact materials, which is why increasing the frequency of control is a prerequisite for ensuring safe products on the market and managing any risks to human health and the environment.
However, we choose to highlight some points of view in our response to the consultation. A brief summary of these points follows below.
Regular review of standards
The consultation lists relevant standards for contact material operations, but there are no standards suitable for operations that manufacture snus and snus-like products. Swetic therefore suggests that the table be updated regularly and that the authorities monitor the possibility of adding suitable standards for the purpose.
Added value of third-party certification
Swetic also welcomes the proposal for reduced inspection frequency in the event of good regulatory compliance or third-party certification, but would like to emphasize that the benefits of third-party certification are far greater than reduced inspection frequency by inspection authorities. Third-party standards ensure systematic management of risks in the food process, but also reduce risks that can entail indirect costs for companies. Expenditure on audits linked to third-party certification is therefore not comparable to expenditure linked to inspections by inspection authorities, as the investigation suggests.
Large scale requires secured expertise
The proposals in the consultation result in a small increase in the number of control objects for municipal control authorities, but the variation in the nature of the control objects requires a considerably broader range of expertise among the control authorities. Where controls occur at a lower frequency, competence will therefore likely be difficult to maintain.
Accredited inspection bodies, on the other hand, have national coverage and auditors with broad and deep knowledge of contact material operations. Swetic therefore sees these bodies as a potential asset to assist inspection authorities and welcomes an in-depth dialogue with the Swedish Food Administration regarding the possibility of accredited inspection bodies supporting public municipal food inspection.
