New version of NVWA Information Sheet 64

On 17 November 2022, a new version of Information Sheet 64 of the NVWA was published. What has changed and how can you comply with this new version of Information Sheet 64?

Merger of Information Sheet 64 and 65

In the new version of Information Sheet 64, Information Sheets 64 and 65 have been merged. Both sheets were drawn up as guidelines for the control of raw material hazards. The previous version of Information Sheet 64 applied to industrial companies that produce foodstuffs. Information sheet 65 related to companies that trade in consumer products without preparing, processing or treating them. Information sheet 65 was used in practice by distributors, traders and retailers. With the merger of both information sheets, information sheet 65 has been discontinued.

Control measures accepted by the NVWA.

Information sheet 64 states that the NVWA accepts the following control measures, or combinations thereof, for raw materials and products supplied:

1. The supplier of the raw material must provide a valid certificate (CoA) from an independent accredited laboratory with each batch.

2. If the supplier of the raw material does not provide a certificate of analysis, you, as the customer, must carry out an analysis (or have one carried out) for relevant hazards in the delivered batches. The number of analyses to be carried out depends on whether it is an existing reliable supplier or a new supplier (this requirement already existed in the previous version of Information Sheet 64).

3. You can have an audit carried out at the supplier by a demonstrably trained auditor. This requirement already existed in the previous version of the Information Sheet. It has now been added that the audit must be risk-based and carried out at least once every three years. For new suppliers, the audit must be carried out prior to the first delivery.

4. Another option is for the supplier to be certified by a private quality system accepted by ketenborging.nl. In this case, the control of hazards of raw materials/commercial products must be specifically mentioned in the scope or area of application. During such an audit, specific attention is paid to the control of raw material hazards. It is also assessed whether all raw materials are evaluated and the hazards are demonstrably controlled.

In addition, food safety certificates accepted by ketenborging.nl with a general scope (which includes the control of raw material hazards) are also considered sufficient, provided that:

• The control of all raw materials/products has been assessed during the audit and

• The points mentioned in point 3 above are described in the audit report.

In this case, a company must demonstrate in a report that an assessment has been carried out on the raw materials/products in question and that all relevant hazards are demonstrably controlled. In practice, however, this is generally given limited attention during the certification audit. There is therefore no guarantee that all raw materials are actually assessed.

GFSI-recognised certificate no longer sufficient

In short, a GFSI-recognised certificate, such as BRCGS, IFS or FSSC 22000, will no longer be sufficient for the NVWA in practice when it comes to controlling raw material hazards. The NVWA wants to see that all raw materials and products supplied are assessed during the audit, and this is not currently the case during a GFSI-recognised audit. Only random samples are taken during these audits.

Compliant with the new Information Sheet 64?

How you comply with the guidelines of Information Sheet 64 differs per company and situation. Our Quality Assurance advisors will be happy to work with you to assess how you currently control raw material hazards and what adjustments and actions are necessary.

Author: Tamara Kee Expertise in food safety