The Food Safety Modernization Act (FSMA) – a new food safety law, recently implemented in the US – introduced Hazard Analysis and Risk-Based Preventive Control (HARPC) as a new standard for assessing food products compliance to the health requirements set by the new US regulations. For the Food and Drug Administration (FDA), which has been driving the innovation of global control in the agribusiness sector for more than a century, the HARPC now takes precedence over the “classic” HACCP (Hazard Analysis and Critical Control Points). Recall, following the implementation of HACCP by the Codex Alimentarius in the nineties of the last century, the lexicon “Françeafrique” had quickly found equivalent wording « Analyse des Dangers – Points Critiques pour leur Maîtrise ». But this kind of anagram unfortunately found no taker and fell into oblivion. By persevering, the Franco-European logic had found an alternative formulation by launching the ISO 22000, which represents a sort of city dress of the HACCP, and they hastened to declare it as an innovative instrument of European origin. It is unclear whether at the moment Prestige Europe is preparing to wrap the HARPC with any “ISO 22000 bis” to claim the instrument as its own.
The type of appropriation mentioned above – by reformulation or “copy / paste” or other form – of creations made elsewhere and then claimed by the EU trade bloc, is made possible thanks, in particular, to a Franco-German complicity well structured. In this context, the careful observation shows that France and Germany complement each other, and are cooperating, so far, in the spirit of partnership and mutual understanding in many areas. Thus, the Germans, who represent one and a half times the French population, but who live on an area barely above 50% of the French territory, have long shown a deep appeal for everything related to French agri-food, relatively less industrialized than at home and therefore supposed to be closer to nature. For this reason, and others of a political and commercial nature, and given the weight of Germany in Europe, France is playing a leading role in EU policy for the agri-food sector. Also, considering the French colonial past on our Continent, this role is particularly preponderant for the EU’s relationship with Africa. In these conditions, if Europe remains unquestionably the first partner of our continent to buy us agricultural raw materials and sell us the finished products that result, the lion’s share on this very asymmetrical trade go to France for what concern North and West Africa. This partly explains the relentlessness of France, as the EU’s leading figure in the agri-food sector, to treat HACCP as a mere teaching of work and to consider ISO 22000 as a regulatory standard in Europe, made unavoidable for the export of any product from the African agri-food sector to the EU. Moreover, this standard imposed on us, instead of HACCP, is administered more than 95% by European structures. In the end, a lot of money and valuable information are going from Africa into the pockets and drawers of European organizations themselves imposed on the Continent by the EU trade group.
However, this dominance of the EU Consortium on African agri-food trade with the outside, which has lasted for centuries, has never been closer to its decline than it is now. Indeed, John Bolton’s statements from Thursday before the Heritage Foundation in Washington, DC, where he hammered out “Africa is incredibly important to the United States….If we didn’t understand it before, the competition posed by China and Russia and others should highlight it for us, which is why I do think this is a potential turning point in American understanding of what’s at stake for us — not just for Africa — but for the United States in African affairs.”, constitute an unpublished first. The latter, US National Security Advisor and close associate of President Donald Trump, has solemnly confirmed a historic turning point in the relationship that the Americans have maintained so far with our Continent. Indeed, since the end of the last Great War, American interests over Africa, including the policy of containment of Soviet influence on the continent, were co-managed or simply delegated to European countries, France part of it. But, following the saying, “Well-ordered Charity begins with oneself“, and after seventy years, the result is there in the form, for example, of a French omnipresence in the affairs of that region of Africa then that the USA shines by their absence. As a corollary of this aspect of things, most of the innovations and other types of progress, appearing elsewhere in the world, are quickly reformulated and / or reconditioned at the level of EU countries before being presented francophonically to us as creations “made in EU “. The case of HACCP dressed in ISO 22000 is eloquent in this respect (see here).
On this subject, while the HACCP – a repository that has cost the Americans tens of years of research and refinement and that the FDA has distributed to everyone free of charge – has become in the last decades the stallion of choice to measure the quality of work in the agri-food sector around the world, it is largely snubbed in the EU for the benefit of ISO 22000. And, above all, this “duplicate” of HACCP that does not say its name, which remains a for-profit instrument above all, imposed in spite of them on African exporters to the EU to the detriment of HACCP, reveals the degree of laziness (synonymous with income economy) that the EU trade group has chosen for depriving Africans of their modest gains on raw agricultural resources. The icing on the cake for Europeans, ISO 22000 served at the same time to lock the markets of our African agricultural raw materials for the benefit of the EU Consortium. So, in this context, the temptation may be strong for the Prestigious Europe to redo the same type of scenario with the HARPC and initiate a Bis Repetita. Except that this time, the US will to approach Africa is crystalline and US officials are determined to build a direct relationship of cooperation with us African without a European intermediary. First of all, as the Americans have repeatedly said so without success with the European agri-food authorities, standards underlying trade must be based on scientific criteria. If Europe of Prestige refuses this approach by taking shelter behind the leitmotiv “Principle of precaution“, it is interesting to realize that the message was understood on this side of the Mediterranean and American white and red meat has already been given the green light by our authorities to be distributed locally while waiting to progressively reach other African markets. Nice competition in perspective with the meat products of the EU and the best wins.
That said, there is no need to dramatize because the reputation of products of the French agri-food sector, built on generations of know-how, should suffer no hazard. The products in question, many of which are in niche markets, have strong advocates and protectors. But the problem takes another dimension when France plays the flag-bearer of the EU to get in the way of the progress of US agri-food know-how around the world, starting with Africa. Recall that this savoir-faire, which was lacking to the Third Reich, was a major element for the victory of the Allies in the Second World War by feeding millions of soldiers around the world. Also after the war, the US savoir-faire helped, in particular, a good part of the European population who in this way escaped the famine. So, by getting in the way of US interests in the agri-food sector, all in all legitimate, France runs the risk of a backlash. Indeed, its unconditional alignment on the positions of countries of Germanic obedience, while these latters stay themselves behind on the subject, can give it unpleasant surprises. As in the past, it is likely that when choosing between US practices and those of France, the neighbors of the Gauls opt for the American know-how which would be a disappointment doubled punishment. Germany and the other German-speaking countries will surely choose America and, with regard to punishment, Trump has given a glimpse of his reaction by reminding the French recently that without the intervention of Uncle Sam during the Second World War, France would be speaking German instead of surfing the “Françeafrique”.
But let the EU and the US do their job and let us ask ourselves if, as Africans, we have any chance to improve our foreign trade thanks to the FSMA. The answer, in our opinion, is affirmative. The FDA has largely facilitated the administrative procedures for the access of our goods to the US market. For example, there is no intermediary to pay (for exporting) if you can introduce your own manufacturing process on the dedicated FDA portal. But it remains true that most of our operators are not aware of the merit of these facilities for access to the US market. It is therefore up to our association AEFS (African Experts of Food Safety) to make the necessary effort to sensitize African operators on these possibilities. Much wok ahead.
