Article | REF: TR880 V1

Traceability of food and non-food products: the scope of constraints

Author: Henri TEMPLE

Publication date: November 10, 2008

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2. Prolepses and axiomatic refutation of contra legem opinions

There are interpretations of the 2001 directive and 2002 regulation that run counter to what most legal experts would expect. However, this is the interpretation set out in the first paragraph.

These opposing interpretations relate to :

  • on the scope of the traceability obligation;

  • how long traceability data is kept.

However, this last question has already been explained, as has the refutation of contrary opinions on this point.

Three divergent interpretations from three different organizations have been identified:

  • the report of the Conseil national de l'alimentation CNA (France) of July 5, 2004;

  • two memos from the Direction Générale de l'Alimentation...

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Prolepses and axiomatic refutation of contra legem opinions