On November 11, 2020, South Korea published the draft of Enforcement Rule of Special Act on Imported Food Safety Control [1] to solicit public opinions. This exposure draft rolled out supporting rules of HACCP (Hazard Analysis and Critical Control Point) Accreditation for FFF. Stakeholders could submit suggestions to fineapril@korea.kr prior to December 22, 2020.
Background Foreign Food Facility (FFF): “Foreign food facility” is defined as “a facility located abroad where the food exported to S. Korea is produced, manufactured, processed, treated, packaged, or stored, etc." To register a FFF is the first step to export food products to S. Korea. On April 7, 2020, MFDS (Ministry of Food and Drug Safety) initially brought out the HACCP accreditation for FFF by amending the Special Act on Imported Food Safety Control [2]. To strengthen the food safety control on imported foods, MFDS abolished the registration system of "Good Foreign Food Facility" and replaced it with a stricter HACCP accreditation mechanism. Following the new requirements, when there is a risk for mixing harmful materials in food, the FFF shall comply with the HACCP criteria [3]. Find more information about HACCP at ChemLinked News: South Korea to Bring in HACCP Accreditation for Foreign Food Facilities [4]. Find more information about FFF registration at ChemLinked Regulation Analysis: Registration of Foreign Food Facilities in South Korea [5]. ChemLinked has helped numerous oversea companies in filling the registration of "Foreign Food Facility". Contact us via food@chemlinked.com if you need assistance in facility registration in South Korea. |
Main Proposals:
1. Facilities Subject to HACCP Accreditation
Following the superordinate law, MFDS could request the overseas facility to comply with the HACCP criteria when the products are at risk of mixing with hazard materials. The competent authority would certificate the FFF as a HACCP facility after the safety assessment.
According to the draft, MFDS designated the FFF manufacturing Kimchi (a traditional Korean dish made by salted cabbages with a mixture of seasoning) as the first batch of food subject to HACCP. All overseas facilities exporting Kimchi should finish a HACCP accreditation before trading with S. Korea once the draft has been implemented.
ChemLinked Comments: The HACCP is a mandatory accreditation for local Korean factories producing livestock foods, health functional foods, etc. Although the draft only proposed Kimchi FFF to comply with HACCP, we expect more overseas facilities will be applicable to HACCP eventually. It’s recommended that enterprise pay attention to the regulation updates. Please stay tuned on ChemLinked for more HACCP-related and S.Korean regulatory news updates. |
2. Application for HACCP Accreditation
The applicant should submit the application letter to Korea Agency of HACCP Accreditation and Services (KAHAS) [6] along with a HACCP plan including the critical limit, monitoring method, and the corrective measure.
The KAHAS would go through the application documents and conduct an on-site inspection if needed. After confirming the facility in compliance with the HACCP criteria [3], KAHAS would issue the certificate of HACCP accreditation to the FFF.
3. Validity Period
The period of validity is three years. The enterprise could apply to prolong the validity period 150 days before their HACCP certificate is invalid.
4. Enforcement Date and Interim Measures
The amendments will be effective on July 1, 2021. Grace periods are given to enterprises according to the export volume to prepare in advance:
Enterprises | Enforcement date |
Enterprises exporting over 10,000 ton kimchi in 2019 | October 1, 2022 |
Enterprises exporting 5,000 to 10,000 ton kimchi to S. Korea in 2019 | October 1, 2023 |
Enterprises exporting 1,000 to 5,000 ton kimchi to S. Korea in 2019 | October 1, 2024 |
Enterprises exporting 100 to 1,000 ton kimchi to S. Korea in 2019 | October 1, 2025 |
Other enterprises | October 1, 2026 |
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