The NVWA is strongly committed to risk-based, data-driven and system-oriented supervision in the run-up to 2026. This is understandable given the complexity of the regulations, limited capacity and increasing pressure on businesses. At the same time, experience shows that this approach is not without its challenges. When supervision relies too heavily on figures and files, there is a risk that technical nuances and process knowledge will be overlooked. Efficiency must not come at the expense of the substantive accuracy of enforcement.
The nitrite checks demonstrate how system monitoring can go wrong if the technical context is ignored. In some cases, for artisanal sausage products, the amount of nitrite originally added was divided by the lower final weight after drying, and then assessed as if this were the actual amount added. This is methodologically incorrect, as drying increases the concentration per kilogram without any additional nitrite being added. The same applies to the conversion between NO₂ and NaNO₂; a misinterpretation can lead to an apparent exceedance whilst the standard is actually met. These examples demonstrate that technical expertise and process knowledge are at least as important as calculation models.
In 2026, the NVWA will be focusing extra attention on the supervision of fertilisers. With the expiry of the derogation and the designation of nutrient-contaminated areas, pressure on the fertiliser market is increasing, thereby raising the risk of non-compliance. The NVWA is allocating nearly 200,000 hours to fertiliser supervision and is focusing on area-specific enforcement, with inspections and interventions coordinated with local stakeholders, sectors and civil society organisations. At the same time, the NVWA uses data-driven analyses and innovative detection methods to track down illegal manure flows and fraud. The challenge is that system monitoring and data use are only effective when the quality of the underlying data and the assumptions are correct, and when local practical knowledge is taken into account in the assessment.
From 1 January 2026, the NVWA will be enforcing stricter checks on allergen labelling for pre-packaged products. Businesses must demonstrate that they are doing everything possible to prevent cross-contamination and that they carry out risk assessments. A warning on the label is only mandatory if an allergen reference value may be exceeded, for example “May contain peanuts” or “Not suitable for people with a peanut allergy”. For the NVWA, this means that inspections look not only at the label itself, but also at the underlying production steps and control measures. In practice, this requires careful consideration: a correct administrative procedure may be technically sound, but if the actual production method poses risks that are not properly controlled, a compliance gap remains.
The NVWA is modernising its regulatory oversight by making greater use of data, prioritising risks and strengthening system-based oversight. At the same time, examples such as the nitrite checks show that blind reliance on figures can lead to misinterpretations and incorrect findings. In all areas — from manure and nitrite to allergens — it is essential that specialist knowledge, an understanding of processes and chemical or technical expertise remain integral to supervision. Only in this way can supervision be carried out in a legally correct, technically sound and socially credible manner.
Source: nvwa.nl
