Tr tc 034 changes. Declaration for meat and meat products

11.08.2020

The technical regulation of the Customs Union TR CU 034/2013 "On the safety of meat and meat products" comes into force on May 1, 2014.

From the same time, the following regulations governing the meat industry began to apply. general rules production and turnover of products:

1. TR CU 021/2011 "On food safety"

2. TR CU 022/2011 "Food products in terms of their labeling"

3. TR CU 029/2012 "Safety requirements for food additives, flavorings and technological aids"

4. TR CU 005/2011 "On the safety of packaging"

5. TR CU 027/2012 "On the safety of certain types of specialized food products, including dietary therapeutic and dietary preventive nutrition."

It should be noted that the technical regulations of the Customs Union have minor differences from the regulatory documents of the Russian Federation. This is due to the fact that Russia has a direct influence on the development of technical regulation of the CU, and the standards developed in the USSR are being replaced, updated, and are well suited for use on the territory of the former CIS. Important requirements of technical regulations have a certain bearing on the situation of the transition period of the Customs Union.

It is important to note that, in accordance with the EEC Decision No. 298, adopted on December 10, 2013, documents confirming the conformity of products (declarations, certificates of state registration) issued before May 1, 2013 are valid until their expiration date, but not later than December 31, 2015. Therefore, having a valid declaration, before the expiration of its validity period, manufacturers have the right to produce products under Russian law.

It also follows from the above that on May 1, 2014, it is not required to reissue the declaration of conformity, if it has not yet ceased to be valid. And all declarations received by applicants from that date must be accepted if the products comply with the current technical regulations.

However, producers of meat products now need to outline an action plan to prepare for work within the framework of technical regulations.

First, you need to carefully study the texts of the regulations, correlating the requirements specified in them with the actual work performed in the organization. At the same time, it is important to remember that it is necessary to read not only the text of the regulation, but also the decision on its adoption, since it is this document that contains all the transitional provisions for some requirements. For example, the decision on the adoption of CU TR 034/2013 "On the safety of meat and meat products" contains the following transitional provisions:

The requirement to include in the name of meat products or place in the immediate vicinity of it information about the group (meat product, meat-containing product, meat and vegetable product, vegetable and meat product,) and type (sausage product, meat product, semi-finished product, culinary product, canned food , lard product, dry product, broth) comes into force only after the development of an interstate standard on the procedure for assigning groups of meat products.

The requirement that it is not allowed to label meat products using invented names that are identical or similar to the point of confusion with the names of meat products (for example, Doctor's, Grain, Milk) established in interstate (regional) standards, with the exception of meat products manufactured according to these standards, it comes into effect only after the development of interstate standards for a specific range of products. Attention should also be paid to the fact that the requirement applies only to names established in interstate (GOST), and not national standards (GOST R. STB, ST RK). There are a number of exceptions to this point. It is allowed to use common names formed by anatomical features (for example, brisket, bacon, neck, shank), by a characteristic cut pattern (nalmer, cervelat, salami, ham), by the type of recipe components used (for example, pork, beef, veal ) or widely used in cooking and catering (for example, pastroma, steak).

If we talk about technical regulations, then big changes have affected the labeling of products. First of all, they are defined by TR CU 022/2011 “Food products in terms of their labeling”. Despite. that the specified document for the most part repeats GOST R 51074 “Food products. Information for the consumer ”, there are also a number of new requirements.

First, the requirement for the language in which the marking should be applied. In accordance with the regulations, this language is Russian, however, if required by the legislation of the country - member of the Customs Union, the language of this country is additionally used. For example, at present in Belarus the second national language is Russian, while in the Republic of Kazakhstan only Kazakh is recognized as the state language, therefore, the marking of products that meet the requirements of the regulations must be applied in Russian and Kazakh.

The next important requirement is that if there is an ingredient in food products that consists of two or more components, the composition is indicated in descending order of their mass fraction in the product. In this case, all the components included in its composition are listed, or the compound ingredient is indicated with the addition to it in parentheses of the components in descending order of their mass fraction.

In the event that the mass fraction of a constituent component is 2% or less, it is allowed not to indicate the components included in it, with the exception of food additives, flavorings and their constituent food ingredients, biologically active substances and medicinal plants, components obtained with the use of GMOs, and allergens. Thus, if a manufacturer uses in a recipe, for example, a sausage product, more than 2% cheese, then in the composition it will be necessary to indicate "cheese" and all the components of which it consists. It should be emphasized that nutritional supplements and flavorings (including those included in complex mixtures) are indicated regardless of the percentage in the product.

Regardless of the amount, the composition necessarily contains substances that can cause allergic reactions. At the same time, it is not necessary to separately focus on their allergenic properties in the form of additional inscriptions such as "contains allergens".

In cases where allergens were not used in the production of food products, but their presence cannot be completely excluded, information on the possible presence of such components is posted immediately after the indication of its composition. Examples of this can already be found on product packaging, for example. "Possibly insignificant content of milk protein", "Contraindicated for people with intolerance to soy protein", etc.

Thus, enterprises producing food products intended for export to the countries of the Customs Union need to analyze the entire range, raw materials and auxiliary materials, identify products containing allergens, request information on the presence of allergens from suppliers of spices and additives, and develop an allergen control system. at the enterprise.

Clause 18 of Article 4 of the technical regulation states that for food products containing dyes (azorubin E122, yellow quinoline E104, yellow "sunset" FCF E110, charming red AC E129, ponso 4R E124 and tartrazine E102), a warning must be applied information: "Contains dye (dyes), which (which) may (may) have a negative effect on the activity and attention of children."

If we talk about the labeling requirements specific to meat products, then they are established in TR CU 034/2013 "On the safety of meat and meat products."

So, with the entry into force of the regulation, it is not allowed to mark general-purpose meat products using names that are associatively perceived as meat products for baby food(for example, sausages "Children", sausage "Karapuzik", "Krepysh", "Toptyzhka"). Many manufacturers assign similar names to products, referring to the size of the product, but the consumer evaluates them as products for baby food.

The labeling is not allowed to indicate such information as “made from chilled raw materials” or similar in meaning, if raw materials of a different thermal state, except for chilled, are used in the production of meat products.

If mechanical deboning (additional deboning) of poultry meat is used in the manufacture of meat products, information about this is given in the composition of such products (for example, “mechanically deboned poultry meat”).

Water, which is a part of slaughter products and meat products, is given in their labeling for any method of application (ice, brine, solution, etc.).

In the labeling of sausages and meat products, the starting cultures of microorganisms must be indicated in cases where they were used in production.

The labeling of slaughter products and meat products treated with enzyme preparations must contain information on their use if the activity, including residual, of the enzyme preparation in the finished product is preserved.

In addition, the regulation contains a number of labeling requirements for each type of meat product.

HACCP principles in the vehicle

Technical Regulations TR CU: 021/2011 "On 6 food safety" contains the basic minimum requirements for food safety, as well as for the processes of its production and circulation.

An important issue that determines the regulation is the types and procedures for assessing (confirming) the conformity of products with their production processes. Regarding this issue, the document under consideration lays down the principle of “one product - one document”.

The second important issue that the regulation touches on is the presence of a traceability system and a food safety system based on the principles of HACCP at food enterprises.

Due to the fact that safety is the characteristic that requires systemic management on the part of the organization, the TR CU establishes requirements for the processes of production, storage, transportation and sale of food products. Thus, Article 10 "Ensuring the safety of food products during its production, storage, transportation, sale" TR CU 021/2011 obliges manufacturers to develop, implement and maintain procedures based on the principles of HACCP (Hazard Analysis and Critical Control Points - risk analysis and critical control points), and develop and implement traceability procedures for food products.

The HACCP system is positioned and considered in all developed countries of the world as a general methodology for ensuring food safety. It complements traditional inspection methods and removes dependence on sampling results. finished products, focusing on the manageability of production and service processes. This system allows you to focus on those points in the process that are critical to the safety of the product, and to implement preventive measures to prevent the emergence or development of hazardous factors, managing the causes of their occurrence at all stages of production.

The principles of the HACCP system are defined in the Codex Alimentarius Commission document - CAC / RCP 1-1969.

Despite the fact that the TR CU for food products does not require mandatory certification of the HACCP system, an independent assessment by an accredited certification body that this system in an organization meets the requirements established in the state is one of the ways to confirm the implementation of the HACCP system and thereby fulfill the requirements of TR CU in relation to ensuring safety in the production of food products.

It should also be emphasized that the organization should clearly define the scope of the HACCP system in relation to products covered by the CU TR. The area of ​​application shall identify the products or types of products, processes and production sites that are subject to the HACCP system.

Thus, food products after the entry into force of the CU TR, taking into account the transition period, it should be released into circulation on the unified customs territory of the CU only with full compliance with the requirements of all CU TR and passing the conformity assessment procedures established by the technical regulations that apply to it, including the implementation of the principles of the HACCP system by manufacturers to this product. In this case, the products must be marked with a single mark of product circulation on the market of the CU member states.

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The technical regulation establishes safety requirements for slaughter products and meat products, mandatory for application and execution in the customs territory of the Customs Union, and related requirements for the processes of production, storage, transportation, sale and disposal, as well as requirements for labeling and packaging of slaughter products and meat products. to ensure the free movement of products released into circulation in the customs territory of the Customs Union

On the procedure for enactment of the technical regulation of the Customs Union "On the safety of meat and meat products" see the Decision of the Board of the Eurasian Economic Commission dated December 10, 2013 No. 298

I. Scope

II. Basic concepts

III. Rules for the identification of slaughter products and meat products

IV. Rules for the circulation of slaughter products and meat products on the market of the Member States of the Customs Union and the Common Economic Space

V. Safety requirements for slaughter products and meat products

Vi. Requirements for the production processes of slaughter products and meat products

Vii. Requirements for slaughter products and their production processes

VIII. Requirements for meat products and their production processes

IX. Requirements for the processes of storage, transportation, sale and disposal

X. Requirements for packaging of products of slaughter and meat products

XI. Requirements for Labeling of Slaughter Products and Meat Products

XII. Ensuring the compliance of slaughter products and meat products with safety requirements

XIII. Assessment (confirmation) of conformity of slaughter products and meat products

XIV. Marking with a single mark of product circulation on the market of the Member States of the Customs Union

XV. State control (supervision) over compliance with the requirements of this technical regulation

XVI. Safeguard clause

Appendix No. 1 Microbiological safety standards for slaughter products and meat products

Appendix No. 2 Microbiological safety standards (industrial sterility) of canned food

Appendix No. 3 Hygienic safety requirements for slaughter products intended for the production of meat products for baby food

Appendix No. 4 Requirements for physical and chemical parameters of meat products for baby food

Appendix No. 5 Maximum permissible levels of residues of veterinary (zootechnical) drugs, animal growth stimulants (including hormonal drugs) and drugs (including antibiotics) in slaughter products, controlled according to information on their use

  • Technical regulation of the customs union 005/2011 for Decision 769
  • Amendment for Decision 769

By the decision of the EEC Commission No. 68 of 09.10.2013, the technical regulation of the Customs Union "On the safety of meat and meat products" (TR CU 034/2013) was approved, which entered into force on May 1, 2014. TR CU 034/2013 establishes mandatory safety requirements for slaughter products and meat products and related requirements for production, storage, transportation, sale and disposal, as well as for labeling and packaging of meat and meat products.


This TR CU 034/2013 applies to the following types of products:

  • slaughter products and meat products:
    • meat,
    • offal,
    • crude fat and products of its processing
    • blood and products of its processing
    • bone and products of its processing
    • mechanically deboned meat (additional deboning)
    • intestinal raw materials
    • collagen-containing raw materials and products of its processing (including gelatin)
    • meat and meat products from meat, sausages, semi-finished products and culinary products, canned food, broths
    • bacon products
    • slaughter products and meat products for baby food
  • processes of production, storage, transportation, sale, disposal of meat and meat products
and does not apply to:
  • poultry meat and products from it, as well as products containing poultry meat with a mass fraction greater than the proportion of other slaughter products
  • specialized meat products (excluding products for baby food)
  • food additives and dietary supplements, medicines, animal feed, products not intended for food purposes
  • food products of enterprises Catering
  • food products with less than 5% meat ingredients
  • processes of production, storage, transportation, sale and disposal of meat and non-industrial meat products

When circulating in the territory of the Customs Union, slaughter products must be accompanied by a veterinary certificate and marked with a sign of compliance with the technical regulations of the CU.

Packaging and closures for slaughter products and meat products must comply with the requirements of CU TR 005/2011 "On the safety of packaging". Requirements for the labeling of meat and meat products are contained in TR CU 021/2011 "Food products in terms of their labeling".

Declaration for meat and meat products.

  • Slaughter products, including those intended for baby food, must undergo a veterinary and epidemiological examination before being placed on the market.
  • Meat products (with the exception of products for baby food and new types of products), before being released into circulation on the territory of the Customs Union, must go through the procedure for declaring compliance with the requirements of TR CU 034/2011.
The validity period of the declaration issued for the serial production of meat products is 3 years. With the ISO 22000 certificate for the quality management system and food safety, the declaration period is extended to 5 years.

The declaration for a batch of meat and meat products is valid until the expiration date of such products.

Certification of meat and meat products is mandatory for CU manufacturers and importers. With the exception of specialized meat products, poultry meat, dietary supplements, medicines, animal feed, products not intended for food purposes, public catering products and food products in which the content of meat ingredients is less than 5%, as well as slaughter products and meat products, produced by citizens at home. Meat and meat products are subject to mandatory confirmation of conformity within the framework of the declaration, veterinary and sanitary examination.

Declaration of meat and meat products.

It is necessary to issue a declaration of conformity for:

  1. Meat of cattle, fresh or chilled
  2. Pork fresh, chilled or frozen
  3. Lamb or goat meat, fresh, chilled or frozen
  4. Meat of horses, donkeys, mules or hinnies, fresh, chilled or frozen
  5. Edible offal of cattle, pigs, sheep, goats, horses, donkeys, mules or hinnies, fresh, chilled or frozen
  6. Other meat and edible meat offal, fresh, chilled or frozen
  7. Pork fat, separated from lean meat, not rendered or otherwise extracted, fresh, chilled, frozen, salted, in brine, dried or smoked
  8. Meat and edible meat offal, salted, in brine, dried or smoked; food flour of fine and coarse from meat or meat offal
  9. Sausages and similar products of meat, meat offal or blood; ready foodstuffs based on them
  10. Other prepared or preserved products of meat, meat offal or blood

The applicant has the right to choose any suitable declaration scheme:

Scheme

Schema element

Application

Product tests are carried out

Production control

laboratory

Serial production, no more than 3 years

laboratory

Batch for the shelf life of this meat product

laboratory

Serial production in the presence of HACCP, no more than 5 years

The applicant can be a legal entity or an individual entrepreneur from the countries of the Customs Union. In order to receive the declaration, it is necessary to form a set of documents and submit them to any certification authority (by e-mail). The list of documents must contain: a copy of the OGRN (BIN / UNP); TU, GOST, STO or product description; test reports (if any); contract, agreement, invoice, invoice (for scheme 4D), ISO 22000 or HACCP certificate (for scheme 6D). The certification body analyzes the documentation, assists in testing, registers the declaration. After that, the products are marked with the EAC sign and can be sold under the CU. Evidence materials must be kept by the applicant for 10 years or at least 5 years (with a batch).