New electronic system to register labels of products of animal origin
On 18 January 2017 the Ministry of Agriculture, Livestock and Food supply of Brazil (DIPOA/SDA/MAPA) put in place a new electronic system (PGA-SIGSIF) for the registration of labels of products of animal origin, following the publication and entering into force the Normative Instruction No 1of 11 January 2017. The complete text of this Normative Instruction translated into Dutch can be downloaded below, together with the manuals (in Portuguese) for access of the PGA-SIGSIF system and registration of companies and labels.
According to DIPOA/SDA/MAPA :
a) a new electronic system is online and open for new requests for the registration of products;
b) requests from foreign establishments previously entered in paper form will still be processed by DIPOA, as usual;
c) exporters and the competent authorities of exporting countries will be part of the process;
d) for new product approval requests, the system does not differentiate between national and foreign companies;
e) only an ID and a document from an authority are requested to allow the representative of the foreign company to access the new electronic system.
Overall, the new system seems positive, e.g. for new applications/registrations, it does not discriminate between national and foreign companies. Also, in case of non-compliance the company will be given the opportunity to make corrections, which is positive as it was not the case before. However, several aspects of the new normative instruction raise concerns.
First the company will have to register itself to get access to the system, before it can register the label. DIPOA states the following : In order to obtain first access, the user must use the following link:
http://sistemasweb.agricultura.gov.br/pages/PGA-SIGSIF.html.
For non-registered users, the first access to the system will have to be granted/authorized by MAPA upon request by the interested party, and evidence of bond with the production establishment. Such bond must be evidenced by presenting the company’s documentation indicating the users as being its representatives at PGA/SIGSIF and the user’s ID (digitized copy), if applicable accompanied by a vernacular translation.
The new system makes a distinction between products for which technical regulation exists (RTIQ - Regulamento Tecnico de Identidade e Qualidade) and products for which no specific technical regulation applies. The label for products which have a technical regulation are in principle registered from the day the label is registered via the system. However bear in mind that they can audit it at any time. For all other products pre-approval by DIPOA is needed, like it was the case before.
Also under the new system minor changes will again imply the need to update the registration. This will not be a problem for regulated products (those with technical regulation, or RTIQ) but will impact on products without RTIQ, given that any trivial change related to products without RTIQ (e.g. an importers' phone number) will still be subject to DIPOA's approval.