Division 9.2.2.1 Occurrence of non-compliance

The purpose of this section is to provide some guidance as to how an analysis of the frequency and type of non-compliances may be performed. The analysis may be broken down by sectors and/or competent authorities, as appropriate. The analysis may, where appropriate, provide answers to questions such as:

1. (a)

   what was the frequency of non-compliances in various sectors? This is particularly relevant in cases where significant deviations from the overall compliance are evident in some sectors or in official controls carried out by certain competent authorities;

2. (b)

   were the non-compliances randomly distributed in time and space or was there some clustering at particular points or production stages and were there indications of emerging trends?

3. (c)

   the type of non-compliances, that is whether they were related to structural, operational or end-product related requirements? Other types may include non-compliances related to self-controls, administrative aspects or documentation (for example traceability). Non-compliances may also be categorised as major/minor, systematic/sporadic etc.;

4. (d)

   were the non-compliances scattered all along the feed and food chain or concentrated at primary production or further down the chain?

5. (e)

   were there possibly multiple clusters of non-compliances along certain chains?

6. (f)

   does the pattern of non-compliances indicate that there are critical control stages along the production chain(s)?

7. (g)

   are there any patterns indicating that different (types) of food and feed business operators and other relevant producers and business operators or production chains were more compliant than others?