International Food Safety Issues EU positions papers for Codex Alimentarius CCFFV – Codex Committee on Fresh Fruit and Vegetables

EC comments CODEX committee on fresh fruit and vegetables - Ninth session, Mexico, 9 - 13 October 2000

Proposed draft Codex standard for tomatoes (CX FFV 00/16)

The European Community wishes that the proposed draft concerned be amended on numerous points, in order to be harmonised with the existing international standards for this product: standard recommended by the UN/ECE Working Party on standardisation of perishable goods, OECD standard. These standards have existed for several decades and it is important that a possible new Codex standard for the same product is similar to them, if not identical, in order to avoid any confusion on the markets and to minimise overlapping between the work of the Codex Committee for fresh fruit and vegetables and the work of other international organisations. In these comments, account was taken of the draft revised standard for tomatoes, as approved by the last session of the UN/ECE specialised section of the standardisation of fresh fruit and vegetables, which proceeded in May 2000.

Paragraph 1: Definition of produce:

It is desirable to define, at this stage of the Codex standard, the principal commercial types of tomatoes on the market, because, according to the types, the provisions of the standard will vary. The European Community proposes distinguishing four commercial types of tomatoes: round tomatoes, ribbed tomatoes, oblong tomatoes and cherry tomatoes. The following paragraph could be added following the first subparagraph of part 1:

"Tomatoes may be classified into four commercial types:

- "round" or spherical type,

- "ribbed",

- "oblong" or "elongated",

- "cherry" tomatoes (including "cocktail" tomatoes). "

Paragraph 2.1 : Minimum requirements :

- At item 2.1, the third indent mentions that tomatoes must be of characteristic appearance and development of the variety. The European Community considers that these criteria must be according to the class in which tomatoes will be classified. For example, development defects such as light bumps have to be acceptable in class I. The Community proposes therefore suppressing this indent and tackling the question of the defects of appearance and of development in paragraph 2.2 (Classification), rather than in this paragraph which should concern minimum characteristics only.

- The fifth indent stipulates that tomatoes must be free of damage caused by exposure to the sun. The Community considers that certain defects due to exposure to the sun (light sunburns of the skin for example) are acceptable in the classes I and II. It does not wish therefore this indent to be included to the minimum characteristics. When this type of defect reaches an unacceptable level, even in class II, tomatoes have reached "deterioration such as to make it unfit for consumption": the fourth indent applies therefore. Accordingly, the European Community proposes suppressing the fifth indent of paragraph 2.1.

- The sixth indent mentions that tomatoes must be free of damage caused by frost or freezing. The European Community considers that these defects are also covered by the fourth indent (see OECD interpretative booklet, page 21). The Community proposes therefore suppressing this indent.

- The ninth indent mentions that tomatoes must be "practically free of pests and disease". The European Community believes "diseases" are included in "pests". Accordingly, the European Community proposes replacing the ninth and the tenth indents by the two following indents:

"practically free from pests,

- practically free damage caused by pests, "

- Increasingly tomatoes are presented in trusses, i.e. in whole inflorescence or part of inflorescence. In this case, it is necessary to envisage minimum requirements for the quality of stalks, in addition to the requirements, which apply to tomatoes. The European Community proposes adding the following subparagraph at the end of paragraph 2.1:

"In the case of trusses of tomatoes, the stalks must be fresh, healthy, clean and free from all leaves and any visible foreign matter."

Paragraph 2.2. : Classification :

- Paragraph 2.2.1 stipulates that the shape of tomatoes must be typical of the variety. The European Community is in agreement with this requirement, but in the Extra Class, it wishes tomatoes to be characteristic of the variety in all points (shape, aspect, development). That makes it possible to suppress the indent dealing with the shape, because a tomato characteristic of the variety is inevitably "properly shaped".

With regard to the uniformity of size and colouring, mentioned in the second subparagraph of paragraph 2.2.1, the European Community considers that this consideration has its place rather in paragraph 5.1 (Uniformity). The proposed draft Codex standard stipulates moreover that tomatoes shall be uniform in size in all Classes, and uniform in colouring in Extra Class. It is not therefore necessary to mention the requirement of uniformity of size and colouring in this paragraph.

On the other hand, it is necessary to specify, with regard to colouring, that tomatoes can be not characteristic of the variety. When tomatoes reached the degree of development and maturity mentioned as in point 2.1.1, they can, according to the envisaged duration of transport and its nature (chilled or not), present a range of colouring going from the green to the red. What is important is not therefore that colouring is typical of the variety, but that colouring is such that tomatoes will arrive at destination in a satisfactory condition. The Community proposes therefore mentioning this idea specifically.

The Community also is in agreement with the fact that tomatoes have to be firm in this class. It proposes however that this adjective applies to the flesh of tomatoes.

The proposed draft standard mentions that tomatoes must be free from damages (bruises). The Community considers that this is also envisaged by the last subparagraph of paragraph 2.2.1 which stipulates that tomatoes can present only very slight superficial defects.

Lastly, "green backs" type defects (yellow or green aureole located around the stem cavity and which corresponds to a non-edible callous part) have to be avoided in the Extra class. The European Community proposes making explicit indication of it, because such defects are not always easily visible especially when fruits are still at a colouring stage close to green.

Accordingly, the European Community proposes writing paragraph 2.2.1 in the following way:

"Tomatoes in this class must be of superior quality. They must have firm flesh and must be characteristic of the variety as regards shape, appearance and development.

Their colouring, according to their state of ripeness, must be such as to satisfy the requirements set out in paragraph 2.1.1 above.

They must be free from greenbacks and other defects, with the exception of very slight superficial defects, provided these do not affect the general aspect of the produce, the quality, the keeping quality and presentation in the package. "

In paragraph 2.2.2, the proposed draft stipulates that Class I tomatoes are those which do not qualify in Extra Class but satisfy the minimum requirements. Traditionally, Class I products are defined in the Codex standards as "high quality" and characteristic of the variety (including in terms of shape) products. The European Community considers that the proposed drafting no longer describes the gradation which shall exist between classes Extra, I and II products. It proposes therefore taking up again the usual formulation of other Codex standards to define Class I products.

In Class I, the Community is in agreement that tomatoes have to present neither visible "greenbacks", nor cracks. These defects are sufficiently important to be acceptable only in Class II.

With regard to skin defects, the Community is of the opinion that the general rule must be the absence of cracks, healed or not. Skin defects must be limited to slight defects. It does not seem necessary to specify the higher limit of size for these defects. In addition, the higher limit of size proposed for skin defects in Class I seems too important for round tomatoes, oblong tomatoes and cherry tomatoes. Cracks and stem cork-like scars (of umbilical or linear shape) are rather specific to ribbed tomatoes. For this type of tomatoes, specific tolerances can be worked out: healed cracks of 1 cm at most, non excessive protuberances, small umbilicus without suberisation, as well as the defects envisaged by the last indent of paragraph 2.2.2 of the proposed draft.

Lastly, internal discoloration (coffee stain) may be acceptable as a colouring defect provided it is slight. A dimension of 25 mm in diameter (4.9 cm²) is well too important to be described as "slight".

The European Community proposes therefore replacing the second subparagraph of paragraph 2.2.2 by the following text:

"Tomatoes in this Class must be of good quality. They must be reasonably firm and characteristic of the variety.

They must be free of cracks and visible greenback. The following slight defects, however, may be allowed provided these do not affect the general appearance of the produce, the quality, the keeping quality and presentation in the package:

- a slight defect in shape and development,

-a slight defect in colouring,

- slight skin defects,

- very slight bruises.

Furthermore, ribbed tomatoes may show :

- healed cracks not more than 1 cm long

- no excessive protuberances

- small umbilicus, but no suberisation,

- suberisation of the stigma up to 1 cm²,

- fine blossom scar in elongated shape (like a seam), but not longer than two-thirds of the greatest diameter of the fruit. "

- In paragraph 2.2.3 (Class II), no indication is provided with regard to firmness of the tomatoes. The European Community considers that one has to fix a limit and proposes speaking about tomatoes at least "reasonably firm (but slightly less firm than in class I)".

The Community considers that tomatoes presenting unhealed cracks cannot be admitted even in class II, the product being insufficiently conservable.

Allowable defects in class II are numerous and rather important. A number of these defects are not mentioned by the proposed draft such as colouring, development and bruising defects.

With regard to skin defects, one can admit in Class II any defect which does not damage seriously the fruit. But with regard to healed cracks, the European Community proposes fixing the limit at 3 cm rather than 73 mm, because the latter value is well too important with respect to the size of the fruit.

Specific defects for ribbed tomatoes can be the subject in addition of additional tolerance: protuberances, umbilicus, cork-like scars of umbilical shape or of elongated shape.

Accordingly, the European Community proposes replacing the second subparagraph of paragraph 2.2.3 by the following text:

"They must be reasonably firm (but may be slightly less firm than in class I) and must not show unhealed cracks.

The following defects may be allowed provided the tomatoes retain their essential characteristics as regards the quality, the keeping quality and presentation :

- defects in shape, development and colouring,

- skin defects or bruises, provided the fruit is not seriously affected,

- healed cracks not more than 3 cm in length for round, ribbed or oblong tomatoes.

Furthermore, ribbed tomatoes may show :

- more pronounced protuberances than allowed under class I, but without being misshapen,

- an umbilicus,

- suberisation of the stigma up to 2 cm²,

- fine blossom scar in elongated form (like a seam). "

Paragraph 3. : Calibration :

- The proposed draft Codex standard for tomatoes fixes a different sizing rule according to whether tomatoes are round or oblong. The European Community understands the proposal as following: for round tomatoes, sizing is by the maximum diameter of the equatorial section; for oblong tomatoes, it is by a double measure (minimum value of the maximum diameter of the equatorial section; maximum value of the length of the axis joining the stalk at the pistillar end.

This proposal does not specify the sizing rule applicable to ribbed tomatoes. It does not specify size uniformity rules for round tomatoes. They do not specify if sizing has to be applied to trusses of tomatoes. In addition, the sizing scales for oblong tomatoes seem inapplicable: one does not understand how an oblong tomato can be, for example, at the same time of a diameter over 40 mm and of a length less than 46 mm. This sizing scale seems to be made for round tomatoes rather than for oblong tomatoes, since it limits the difference between the diameter and the length of the fruit. Lastly, the proposed size codes do not correspond to any existing commercial practice to the knowledge of the European Community.

- The European Community proposes therefore adopting the following principles for the sizing of tomatoes: size determination by means of the diameter of the equatorial section for all types of tomatoes, minimum size for oblong, ribbed and round tomatoes, size scale applicable to tomatoes in classes Extra and I (other than trusses of tomatoes) without size code indication.

The proposals of the European Community could read in the following way:

"size is determined by the maximum diameter of the equatorial section. The following provisions shall not apply to "cherry" tomatoes.

3.1 Minimum size

For tomatoes classified in the Extra class and classes I and II, the minimum size is set at:

- 35 mm for round and ribbed tomatoes,

- 30 mm for oblong tomatoes.

3.2. Sizing scale

The tomatoes are graded according to the following sizing scale :

- 30 mm and over but under 35 mm (only for oblong tomatoes)

- 35 mm and over but under 40 mm

- 40 mm and over but under 47 mm

- 47 mm and over but under 57 mm

- 57 mm and over but under 67 mm

- 67 mm and over but under 82 mm

- 82 mm and over but under 102 mm

- 102 mm and over

Observance of the sizing scale is compulsory for Extra class and class I tomatoes.

This sizing scale shall not apply to trusses of tomatoes. "

Paragraph 4. : Tolerances :

- Part 4 is different from the general presentation of other Codex standards in two ways:

- on the one hand, the first subparagraph is written in a more complex way without the brought details being necessary since they are included in the traditional drafting of this first subparagraph.

-in addition, paragraphs 4.1.1.2, 4.1.2.2 and 4.1.3.2 envisage tolerances at the transit or point of arrival, tolerances not envisaged in the other Codex standards.

The Community proposes therefore suppressing paragraphs 4.1.1.2, 4.1.2.2. and 4.1.3.2, and writing the first subparagraph according to the following traditional formula:

"Tolerances in respect of quality and size shall be allowed in each package for produce not satisfying the requirements of the class indicated."

- Tolerances proposed in paragraphs 4.1.1.1, 4.1.2.1 and 4.1.3.1 are 10%. It seems more suitable to the European Community to fix less high tolerance for the Extra class in which only tomatoes of superior quality shall be classified. In addition, in each class, only produce of the category immediately below are usually tolerated. Tolerances are provided for avoiding that small mistakes of classification involve the downgrading of the whole lot in its integrality. The European Community fears that, enlarging tolerances too much, it becomes a pretext to systematically include out of grade fruits, even in Extra class or Class I. Lastly, it is necessary to avoid any product not fit for consumption, in particular those affected of rot at a point where consumption is impossible.

In addition, since an increasing share of the trade is done in the form of trusses of tomatoes, it is appropriate to envisage specific tolerances for these products.

Accordingly, the Community proposes writing paragraphs 4.1.1, 4.1.2 and 4.1.3 in the following way:

"4.1.1 Extra class :

5% by number or weight of tomatoes not satisfying the requirements of the class but meeting those of Class I or, exceptionally, coming within the tolerances of that class.

4.1.2 Class I :

10% by number or weight of tomatoes not satisfying the requirements of the class but meeting those of Class II or, exceptionally, coming within the tolerances of that class. In the case of trusses of tomatoes, 5% by number or weight of tomatoes detached from the stalk.

4.1.3 Class II :

10% by number or weight of tomatoes satisfying neither the requirements of the class nor the minimum requirements, with the exception of produce affected by rotting, marked bruising or any other deterioration rendering ot unfit for consumption. In the case of trusses of tomatoes, 10% by number or weight of tomatoes detached from the stalk.

- With regard to size tolerances, the European Community proposes that one limit tolerance for tomatoes smaller than the minimum size, by adding the following sentence:

"... with a minimum of 33 mm for round and ribbed tomatoes, and 28 mm for oblong tomatoes"."

- The European Community considers that setting colour tolerances is not necessary in paragraph 4. Colouring defects are included within quality tolerances. With regard to the absence of uniformity in colouring for a lot or for a package, the question has to be addressed within paragraph 5.1 (uniformity) and not within paragraph 4 which deals with defects one can tolerate for each individual fruit. The European Community proposes therefore suppressing paragraph 4.3.

Paragraph 5. : Presentation :

- According to the proposals of the European Community made in paragraph 3, sizing of tomatoes would be compulsory only for the Extra class and class I. Size uniformity is therefore due only for these two classes and not for the class II. The European Community proposes therefore adding the following bracket to the end of the first sentence of paragraph 5.1:

"(if sized)"

- For class I tomatoes, which are of good quality, certain colour and maturity uniformity has to be satisfied according to the European Community. If the trader who orders class I tomatoes (good quality, but not superior quality) receives tomatoes of all colours and state of ripeness mixed in the package, he will have to, without any doubt, carry out a new sorting, which appears contradictory with the concept of good quality. In addition, in the case of oblong tomatoes, it is appropriate to fix certain length uniformity for the two higher classes. The European Community proposes therefore the following text to replace the second sentence of paragraph 5.1:

"The ripeness and colouring of tomatoes in Extra Class and Class I must be practically uniform. In addition, the length of oblong tomatoes must be sufficiently uniform."

- Footnote 4 in paragraph 5.2 (Packaging) stipulates that recycled materials could be used inside the packages. In commercial practice, only packages themselves are recycled, not materials used inside the package (plastic crates for example). The recycling of this type of materials should not be incited or urged, because, in general, these materials are not re-usable. Accordingly, the European Community proposes deleting Footnote (4) in the proposed draft Codex standard for tomatoes.

- The commercial practice which consists in presenting the tomatoes in trusses developed enormously during the last decade. The European Community wishes therefore a new paragraph 5.4, named "Presentation", to be inserted in the proposed draft in order to describe the two methods of presentation of tomatoes. In particular the presentation in trusses shall be described, which, having regard to the better remuneration the market gives for it, could be the subject of fraudulent practices. The European Community proposes the following text for this new paragraph:

"5.4 Presentation

The tomatoes may be presented as follows:

- as individual tomatoes, with or without calyx and short stalk;

- as trusses of tomatoes, in other words, in entire inflorescence or parts of inflorescences, where each inflorescence or part of each inflorescence should comprise at least the following number of tomatoes :

- 3 (2 if prepackaged) or

- in the case of trusses of "cherry" tomatoes, 6 (4 if prepackaged). "

Paragraph 6. : Marking/Labelling :

- At item 6.2. (Non-retail containers), the proposed draft Codex standard for tomatoes stipulates that particulars set out by sections 6.2.1 to 6.2.5 could only be present in documents accompanying the shipment. This possibility is traditionally reserved for bulk (in a transport vehicle or part of a transport vehicle) shipments. Tomatoes are not shipped this way. Accordingly, the European Community proposes deleting the following words : ", or in the documents accompanying the shipment".

- In paragraph 6.2.2, the proposed draft sets out the marking of the nature of produce when the contents of the package are not visible from the outside. The European Community considers that, in the case of trusses of tomatoes, this indication, as well as that of the commercial type (round, ribbed, oblong) has also to be indicated. In addition being given their very different characteristics, cherry tomatoes should be the subject of a compulsory marking. The text of paragraph 6.2.2 could be as follows:

"" tomatoes "or" trusses of tomatoes "and the commercial type if the contents are not visible from the outside. These details must always be provided for "cherry" (or "cocktail") tomatoes, whether in trusses or not.

- name of the variety (optional). "

- Paragraph 6.2.4 stipulates that the size is indicated either by the code (see paragraph 3), either by the average diameter. Since the European Community proposes the removal of the codes referred to in paragraph 3 (the latter not being used in trade) and that the standard fixes no size uniformity rule based on an average size, the European Community proposes rather indicating the size (if tomatoes are sized) by means of the minimum diameter and the maximum diameter in the package.

Paragraph 7 : Contaminants :

- Paragraphs 7.1 and 7.2 refer, as well as all other Codex standards for fruit and vegetables, to the maximum limits fixed by the Commission for heavy metals and pesticides. Without contesting this principle, the European Community wonders however if the Codex standard for tomatoes (as well as other Codex standards for fruit and vegetables) would not gain in legibility and in transparency by incorporating a summary table of these maximum limits fixed by the Commission.

International Food Safety Issues EU positions papers for Codex Alimentarius CCFFV – Codex Committee on Fresh Fruit and Vegetables
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