At the request of the Netherlands Food and Consumer Product Safety Authority (NVWA), we are informing the GMP+ Community about sesame seeds contaminated with ethylene oxide from India.
In the batches listed below, the standard for the use of ethylene oxide permitted within the EU has been exceeded. Several RASFF alerts have now been issued. A number of GMP+ certified companies have submitted EWS notifications. All of these companies have informed their customers and have the situation under control.
Always check the GMP+ Companies database
As a member of the GMP+ Community, you have a crucial role in ensuring safe animal feed throughout the chain by checking whether your suppliers have GMP+ (or equivalent) certification. If in doubt, check the GMP+ Company database [link].
If you have any questions, please contact the national authority.
At the request of the NVWA, we are sharing the following information:
Information on companies and batches involved
Suppliers have been identified who have delivered contaminated batches. At the bottom of this e-mail, you will find a list of all the suppliers involved, as well as all the batches concerned.
19-047/2; 19-060/3; 19-105/1; 19-105/2; 19-141/1; 19-141/3; 3677/20; 6109/19; 4219; 6109; 1920; 20-004; 20-003; DAE/10330; DAE/10333; DAE/10331; DAE/10337; DAE/11375; DAE/18032; DAE/18139; L10289; HS.A.09958T.02; OIL-2807 0720-6, 2020220128.01; 2020220128.02, HS.A.09962A.01; HS.A.09987A.02; HS.A.09987A.01.02; HS.53932; HS.54146; HS.A.10040T.01; HS.A.10040T.02; HS.A.10040T.02H; HS.A.10016T.01; HS54018; HS.54344; TR.A.10046T; HS.53950, OPI/CN138/19/133/OHSS; OPI/CN138/20/137/OHSS MHD, Lot 157-04; B0056145; PTR191073-01; PTR191041-01
What are the legal obligations for your company?
Procedure for handling contaminated batches of animal feed or ingredients intended for animal feed
In response to questions on how to deal with batches of animal feed or ingredients intended for animal feed that contain or may contain contaminated sesame seeds, I would like to clarify the procedure described in my e-mails of 12-10-2020 and 26-10-2020. Below I also specify a change to the policy for withdrawing contaminated feed from the market up to and including the farmer (end user).
Below you will find further explanation on how to act. The exact procedure depends on whether it is known whether the batch of sesame seed was contaminated or whether this is/was unknown.
If the contaminated sesame seed originates from batches and importers identified by the NVWA (see the list of companies in the e-mails with information about EtO), or from another batch which has been shown (e.g. by the supplier) to contain residues of ethylene oxide higher than the MRL, the procedure is as follows:
If you have sesame seeds or processed foodstuffs containing sesame seeds (ingredients intended for animal feed or animal feed itself) and those sesame seeds originate from other batches from the suppliers concerned or batches from other or unknown suppliers from India, the procedure is as follows:
The background to this procedure is your legal obligation to ensure that any animal feed you place on the market meets the legal requirements for food and feed safety. This also applies to feed already on the market or still in storage, and which, upon further investigation, is suspected of being unsafe. In view of the fact that more and more ingredients (in this case sesame seeds from India) contain ethylene oxide above the MRL value, you should include this risk in your HACCP plan and therefore also assure and verify it.
What should you do if contaminated batches of food are presented for animal feed?
Due to the recalls and laboratory analyses carried out by food businesses, contaminated batches may be offered on the market as animal feed. It is the responsibility of the animal feed company to determine which of the above regimes the batch in question falls under and to act accordingly.
Contaminated batches from suppliers involved
If you have imported, traded or processed sesame seeds from the contaminated batches from the Indian suppliers listed, these batches must be withdrawn from sale immediately. Products in which the contaminated sesame seeds have been processed must also be removed from sale. These products may no longer be sold as food or feed. You must notify the NVWA (GFL notification) and specify which corrective actions you are taking/have taken.
Other batches from the suppliers concerned and batches from other or unknown suppliers in India
The NVWA reminds you of your legal obligation to ensure that any food or feed you place on the market meets the legal requirements for food and feed safety. This also applies to food and feed already on the market or still in storage, and which, upon further investigation, are suspected of being unsafe. Your responsibility is explained below.
Batches of sesame seeds originating from India which have not yet been delivered.
You must verify whether these sesame seeds meet the food safety requirements. You can do so by blocking the relevant batches of sesame seeds and taking a representative sample and having it analysed for ethylene oxide residues. If this analysis reveals that the level of ethylene oxide residues is below the MRL, this batch may be traded/processed. If the analysis reveals that the level of ethylene oxide residues is above the MRL, you must notify the NVWA (GFL notification). These batches may no longer be traded or processed.
Products incorporating sesame seeds from India
In order to verify whether products in which sesame seeds have been used and which are already on the market comply with food safety regulations, the NVWA recommends that you have your retention samples analysed for residues of ethylene oxide. If the analysis reveals that the level of ethylene oxide residues in the compound foodstuff is below the MRL for ethylene oxide in sesame seeds, you do not need to do anything. If the level of ethylene oxide residues is above the MRL for ethylene oxide in sesame seeds, you must notify your customers and withdraw the contaminated products from the market.
New batches of sesame seeds from India
The NVWA considers the risk of contamination of sesame seeds from India with residues of ethylene oxide to be high. It is important that companies adjust the HACCP to reflect the risk of contamination with ethylene oxide.
If you import or trade sesame seeds from India, you must adjust your HACCP and take steps to ensure that you do not import and/or trade contaminated batches. You can do so by having batches you want to import or trade analysed for ethylene oxide residues as part of your inspections/acceptance checks. If the MRL is exceeded, the product may not be imported, placed on the market or processed and you must notify the NVWA (GFL notification) if the batch of sesame seeds has already been imported.
If you import or trade sesame seeds from India (or any products derived from them), you must adjust your HACCP and take steps to ensure that you do not import and/or trade contaminated batches. If you are not sure (e.g. as a result of analytical reports) whether the sesame seeds processed/to be processed comply with the MRL, you can have analyses carried out yourself on the products/compound products you process or produce. Again, if the MRL is exceeded, the NVWA must be notified and the relevant batches of sesame seeds or processed products may not be traded.