[Charles.C]

Dear All,

There is another thread here where I posted relevant links and also uploads (I think) and some discussion.

Sorry but don't remember the thread off-hand. The net result is that freezing manufacturers are routinely employing temps > -18degC as "critical" limits, and similarly for reception of "deep-frozen cargo".

Rgds / Charles.C

Added later - post / thread referred above here -

http://www.ifsqn.com...dpost__p__48191

As can be seen, "interpretations" are involved. Nonetheless IMEX, the usage was auditorially accepted.

[maurocon]

Philip.H, on 12 January 2012 - 06:35 PM, said:

Dear petitloup,

I would like to add if you're process is not set to -18°C you are not in order with EU legislation
following 89/108/EEC law relating to quick-frozen foodstuffs for human consumption.
To call a product frozen you need to make sure -18 degrees is reached.

Cheers Phil

I completely agree.
The company must produce “safe and legal products” (clause 1.1.1). The voluntary production of foods that don’t fulfil the legislation is considered as a failure to comply with a Fundamental clause.
It’s completely different the situation in which there was a production of a non conforming product due to a problem. In this scenario you will have e treatment of the product, a corrective action and so on.

[Jayqc]

Although I agree with the -18 deg C, my understanding is that with regards to the quick frozen foodstuff regs these only relate to products that you are actually labelling as quick frozen

[Charles.C]

Dear All,

This is an extension of previous post.

Also not necessarily disagreeing with the comments in earlier post but the actual legal situation is not quite as straightforward as one might think.

It is true, I think, that as discussed in this forum, the freezing/storage/etc aspects of “quick-frozen foodstuffs” as given in the EC directive of 1989 have been incorporated into all ( or maybe most?) of the national legislation of member states of EU.

I don’t know about Italy but this document (2007) seems to summarize the current UK situation –

 UK quickfrozenregs1107.pdf (54.58K)
Number of downloads: 7

(Note the use of terms such as thermal stabilisation and the relevant refrigerant media).

Also note these comments in another (parallel) UK related (2007) document -

5.2 The QFF Regulations only apply to foods labelled ‘Quick Frozen’.
Trade bodies have estimated that food labelled as ‘Quick Frozen’
accounts for a maximum of 15-20% of the total Frozen Food (FF)
market (this upper percentage is estimated at approx. £862 million in
2005) . The voluntary labelling of foods as having been ‘Quick Frozen’
is generally used as a marketing/consumer information device,
although in practice it is not currently a term widely recognised by
consumers although those that do would view it as a quality indication.

5.3 The frozen food market is characterised by own label products, which
account for more than 47% of total value sales . Intelligence from
Trade Bodies suggests that only one major retailer and two major
manufacturers label their QFF as such, along with some smaller
manufacturers.

5.5 There is no legal requirement to label QFF as such, and the
requirements do not apply to frozen products that are not labelled as
QFF.

 impact assessment UK - qffeng07ria.pdf (194.6K)
Number of downloads: 6

In respect to safety, IMEX many (but not all) haccp plans do not categorise the freezing or storage steps of deep-frozen goods as CCPs. The quality aspect is a different matter of course.

Rgds / Charles.C