GUIDELINES FOR TRANSPORT ACTIVITY RECORDS
Article 2 of the Spanish Royal Decree 191/2011, of the 18 February, on General Health Registry for Food Companies and Foods, includes transport activity between those food companies and establishments subject to registration.
1.Justification of the need for registration in the food safety sector
The General Health Registry for Food Companies and Foods (RGSEAA), under the Spanish Agency for Food Safety and Nutrition of the Ministry of Health, Social Policy and Equality, aims to protect public health and interests of consumers through the official control of companies, establishments and products subject to registration.
Transport within the food chain is a service that either:
- is provided by the company that transforms, packages, stores, distributes or imports products subject to registration activities and, as the owners of goods, has the resources to carry out this activity.
- or is provided by a contracted transportation company that at no moment is owner of goods.
The market should offer a various range of companies with health guarantees that are conscious of their responsibilities as a food company.Transportation constitutes a phase of the food chain that is subject to general and specific conditions within food safety provisions. The container/box/tank where the goods are introduced is essential (see appendix) despite this not being considered as an “establishment” in the above mentioned royal decree.
In article 2, this standard establishes the registration of companies carrying out this activity in the RGSEAA, but precise characteristics within such a varied sector are not specified.Therefore, in line with the criteria in place for the remaining companies along the food chain, below are the guidelines for transport activity registration.
2.Characteristics of transport companies subject to registration in theGeneral Health Registry for National Food Companies and Foods:
2.1.Companies subject to registration in the RGSEAA
The following companies are subject to registration in the RGSEAA:
- Companies or freelance workers holding vehicles or containers (either owned or held under any other type of possession – leasing, usufruct, surrender, etc.) being used for another or other companies:
- Companies holding means of transport that includes the box/container/tank (truck with head and box/tank joined or ships with holds that can possibly be used for the bulk transportation of foods).
- Companies holding a container/tank where the goods are inserted for transportation on the body of the truck (by road, train, ship or aeroplane).This involves:
- Airline transport companies, RENFE, road transport companies and shipping companies that hold containers, and
- Logistics companies that hold and use containers.
- Transport companies that work with subcontracted companies (whether they be freelance or any other form of company that subcontracts services), and freelance workers or subcontracted companies (holders of vehicles or containers) that provide a service.
- Companies with their headquarters in Spain.If voluntarily requested by a company with headquarters in any other EU member state, it can also be registered according to the first additional provision of the standard.
- Transport companies that transport food, materials and objects intended to come in contact with foods or processing aidsindependently of whether its vehicles or containers are used to transport a wide variety of goods.The containers or boxes belonging to means of transport are not exclusively for food transportation purposes, with the exception of those destined to transport bulk food products either in granule, powder or liquid form.
2.2.Companies excluded from registration in the RGSEAA
The following shall not be registered in the RGSEAA, without prejudice to registration in other fields:
- Companies that exclusively carry out transport operations at the beginning or end of the food chain.This excludes:
- Transportation of primary products, even if its destination is another establishment within the food chain and after primary production.
- Home delivery transportation contracted by the individual consumer:Either couriers that only provide a service to the end consumer or companies that own establishments that hold their own vehicles, exclusively handle, transform, package, store or provide foods for on site sale or delivery to the end consumer and deliver to homes.It should be clarified that when a retailer does not have its own means of transport for home delivery, the contracted transportation company should be registered in the RGSEAA.
- Companies that are just owners of tractors and semitrailers transporting containers and not any container or tank. These companies do not subcontract transportation services either (which is responsible for end transportation or its invoicing).
- Vehicles or containers.
- Companies that transport, package, store, distribute, import and transport goods to clients in their own vehicles.Such companies should already be registered in the RGSEAA and do not have to register themselves as a transportation company,e.g. a company registered in code 15 as “Distribution of raw milk (cat/activ 303)” does not have to be registered in code 40 as a transportation company.
- Companies that focus on promoting commercial operations or acts on behalf of another transportation company, without assuming the risk or peril of transportation operations carried out by the second company.
3.Procedures for the Registration and Identification of transportation companies in the General Health Registry for Food Companies and Foods catalogue:code 40.
When providing any form of communication to the competent authority of the Spanish Autonomous Region determined according to corporate address, in accordance with article 6 of the above mentioned royal decree and its stipulated provisions, the transportation company shall indicate the type or types of goods transport that it carries out within the classification established depending on the health risk:
- 605 - Transportation of temperature regulated food products (except for bulk food products in granule, liquid or powder form).
- 606 - Transportation of food products without temperature regulations (except for bulk food products in granule, liquid or powder form).
- 607 - Transportation of bulk food products without temperature regulations (in granule, liquid or powder form).
- 608 - Transportation of temperature regulated bulk food products (in granule, liquid or powder form).
The companies shall be assigned a code (code 40) from the nineteen codes defined for these purposes in the catalogue of business activities subject to registration, defined as STORAGE COMPANIES, DISTRIBUTORS, TRANSPORTATION COMPANIES, PACKAGING COMPANIES AND MULTI-PURPOSE IMPORTERS.
In the event that the transportation company has deposit/transit facilities, they shall be registered in the RGSEAA in the following way:
- The headquarters of the transportation company, as every operator carrying out this activity, with transportation activities; and
- The storage installations with corresponding activities 404, 497 and/or 498, with the corporate addresses of all points where they are located.
- If the corporate address is the same as that of any of the “transference storage” addresses, the RGSEAA will only assign a unique code 40 for all transportation and storage activities.
Article 2 of Royal Decree 191/2011, of 18 February, on the General Health Registry for Food Companies and Foods includes transportation between the food businesses and establishments subject to registration.
For this reason, the General Health Registry for Food Companies and Foods (RGSEAA) attached to the Spanish Agency for Food Safety and Nutrition of the Ministry of Health, Social Services and Equality, makes special mention of this activity.
Consult more information at: Guidelines for the registration of transportation
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