Checks work, but only after things have gone wrong
The recent discovery of Brazilian beef contaminated with oestradiol that reached the European market via the Netherlands has once again raised a fundamental question: just how watertight is the European import control system really?
Six consignments. A hormone banned in the EU. A notification via the Rapid Alert System for Food and Feed (RASFF). And then seizures by the Netherlands Food and Consumer Product Safety Authority (NVWA).
The system came into operation. But only after the product was already on its way. And had already been partially distributed.
A banned substance; zero tolerance but not zero risk
17β-estradiol is in the Prohibited by the European Union for use in food-producing animals because it is a hormone that can affect growth and reproductive processes. Its use is not permitted in the food chain for animal products, and the EU applies a zero-tolerance policy for this type of residue.
Nevertheless, it was found in beef from Brazil.
Where is the vulnerability?
The incident highlights a weakness in the import system.
- Reliance on export certification
When importing meat from third countries, the EU largely relies on health and origin certificates issued by the authorities of the exporting country.
In other words: Brussels is relying on Brasília to ensure that the consignment meets EU standards.
That model is enshrined in law. And it is a practical necessity given the millions of tonnes of trade flows.
But it creates dependency.
If the internal control system in the exporting country is inadequate, this only comes to light during spot checks or audits. Not with every shipment.
- Random physical checks
Documents are systematically checked at the external border. However, physical and laboratory checks are carried out on the basis of risk analysis. That makes sense. Testing 100% is logistically and financially unfeasible.
But it also means that a party not selected for in-depth analysis can, in principle, proceed on the basis of written assurances. The system is risk-based. It is not entirely watertight.
- The time factor in reports
In this case, the notification was received via RASFF after some of the meat had already entered the distribution chain. Formally, the system worked. Operationally, however, the meat was already on its way.
In retail and food service chains where customer turnover is high, any delay in issuing a warning poses a real commercial and reputational risk.
- Audit frequency in third countries
EU audits in exporting countries take place periodically. There is a time lag between inspections, findings and the implementation of corrective measures. This leaves room for manoeuvre.
Is this a system failure?
That depends on how you define it. The monitoring system detected the problem. That speaks in favour of its effectiveness. But it did not prevent it entirely. That points to a structural vulnerability.
For the meat sector and the retail industry, it is the second element that is particularly relevant. After all, prevention is more cost-effective than rectification.
Trade tensions
Furthermore, the incident is taking place against the backdrop of discussions regarding trade agreements with South American countries. Critics argue that the EU imposes strict requirements on its own producers — in terms of animal welfare, residues and sustainability — whilst imports remain subject to external controls.
That reinforces the sense that the playing field is uneven.
What does this mean for trade?
There are three key takeaways for buyers:
- Traceability is more than just compliance on paper.
It seems that simply checking certificates isn’t enough. - Country risk profiles are in need of review.
Not all third countries have the same level of supervisory capacity; see also the EUDR. - Reputational risk is a major risk.
Consumers do not distinguish between the Brazilian authority and a European importer.
A chain is only as strong as its weakest link. And when it comes to imports, that link lies outside the EU’s jurisdiction.
Conclusion
This incident demonstrates that the system operates on the basis of trust, spot checks and periodic audits. For a sector that operates on minimal margins and is highly reputation-sensitive, this is clearly not good enough. Is the current import model robust enough?