One of the important roles of SMEs in the European food business is that they offer a great cultural diversity in Europe. That food diversity is largely provided by the 99% of small food enterprises. They face a growing level of restrictions in their way of operation. A string of problems with public health in the past, mostly with big industry, has lead to rules and standards independent of size. We need to make these rules size-dependent to make them usable for the average Food Operator.

In standardisation we are active in ISO and CEN.

• In ISO we work in TC 34 that developed the new food hygiene management standard ISO 22000. We contributed to the writing and got a level of sensitivity to SME-needs. Like we achieved that management procedures are adapted to size and that written procedures can be reduced. That ISO 22000 standard was recently extended with an application guideline ISO 22004.
• CEN TC 153 - Food processing machinery focuses on machine cleaning criteria and works also on materials in contact with food. Overall food standard policy is decided in the CEN BT
• Especially in this field there is a close link between legislation and standardisation. Legislation prescribes many strict rules. With the European Commission, DG-Sanco and DG-enterprise we review the new Directives and Guidelines in the stage of writing. And we follow EC mandate activities, The Commission has been very active in this area. In 2005 126 legal documents were issued in the Food area alone. Many of these are in connection to the standards so they provide binding rules for hygiene, traceability and food handling in SMEs. Besides, GMO, food claims, labelling and allergies are important subjects for us. These we handle together with UEAPME that takes care of the more political and legal issues.

Together with UEAPME and the members we operate the NORMAPME/UEAPME Food Working Group. It follows closely the activities of CEN and ISO, and the connected legal documents. With 23 members from 13 countries this group has a strong impact on standardisation work related to SMEs. The group is planning to make proposal to the Commission of a labelling standard to ensure that interests of SMEs in that area are well represented.

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Details on TC standard work

CEN BT – CEN BT TF 158 investigated the possibility to make a standard for drink dispensers. This work was stopped after that Normapme submitted a position paper on the ubject.

ISO TC 34 – ISO 22000 standard (Food safety management systems) is the main standard of this Technical Committee . The NORMAPME Food Working Group is concerned that ISO 22000 from TC 34 is beyond the capability of most small businesses. We submitted a detailed set of amendments . Some, but not enough amendments were incorporated into the final version. Hence we decided that a much simplified approach is still needed.

Similar remarks were made by HOTREC on the standards impact in restaurants and hotels. Discussion in the Food Group meeting showed that we can have common position.It shows how important the adaptation to size is for all regulations and standards. We find it very encouraging that we are regularly asked by the Commission to comment on draft documents before publication and especially happy about the Guideline on HACCP for SMEs that is issued in January 2006.

CEN TC 153 – NORMAPME was concerned about the wording of the draft on cleanability of commercial food processing machinery. Of greatest concern is the ban on traditional methods and equipment. Our expert, Mr Bob Salmon, will continue to defend and promote the SME interests in CEN TC 153.

In addition, numerous normative references to other standards that make it difficult and expensive for small business to fully understand a standard are another matter of our concern. The current revision of standards related with the new Machinery Directive also requires a close investigation as strict timetable and huge workload of standardisation bodies may result in standards not suitable for SMEs. Moreover, the new safety requirements could result in more specialized standards and so possibly unsuited to multiple tasks. Small businesses who can only afford the one machine may need multiple tasking to justify the purchase of machinery. Our expert tries to alert the convenors of the WGs to this issue.

CEN TC 146 - PACKAGING and CEN TC 182 - REFRIGERATION

Our expert has recently started to follow these TC's. So far there have been no actions of NORMAPME required, but a few work items need to be closely followed to assure that SMEs reality is considered in the new standards.

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