The Planning and Regulations of Primary Processing Plants for Agricultural Products
Yun-Shan Huang （China Productivity Center Agriculture Innovation Department）
The issue of primary processing plants for agricultural products has received wide attention these past few years. Following the resolutions adopted in the 6th National Agricultural Congress, the Council of Agriculture (COA) promulgated on March 26, 2020 the "Regulations of Primary Processing Plants for Agricultural Products", with the view of building a unified management system from production to primary processing, ensuring the hygiene and safety of processed agricultural products, and increasing the added value of agricultural products.
The Regulations of Primary Processing Plants for Agricultural Products mainly derives from the Agricultural Production and Certification Act, with a newly added Article 18, "Any farmer or any group of farmers under a certain scale may register with municipal/county/city governments as primary processing plant for agricultural products if he uses domestic traceable agricultural products, certified agricultural products, organic agricultural products, in-conversion agricultural products or other agricultural products designated by the Central Competent authority as raw materials to process certain category of products with legal agricultural product processing facilities.” That is, in addition to the current plant registration, the “registration certificate for the primary processing plants for agricultural products” will be issued as the certification of the legal status of the plants. The production information of the plants is recorded, through the certificate number and the link to food safety regulations, for close tracing and monitoring (through required registration on the Registration Platform of Food and Drug Industries). The primary processing plants for agricultural products are of relatively simple scales, compared with factories. However, they still need legal titles of land and buildings for agricultural production and legal right to agricultural processing facilities. Farmers with different consideration of business planning can apply for registration as "agricultural grain processing room," "primary agricultural product processing plant" or "factory" to meet with their operational needs.
Applicants are practitioners from three industries, namely agri-food, aquaculture, and forestry (husbandry not included). They must meet the qualifications of farmers or farmer groups. The facilities used should be on legal sites as provisioned in the “Regulations on the Review of Agricultural Land Allocated for Agricultural Facilities” with the total space of the processing operation area no more than 200 sq. meters (around 60 pings).
To apply for registration of a primary processing plant for agricultural products, the following conditions must be met:
1. Raw material regulations: Domestic traceable agricultural products, certified agricultural products, organic agricultural products, in-conversion agricultural products, or other agricultural products designated by the central competent authority.
2. Processing method: Processing performed in accordance with the regulations in "Processed Products and Processing Method of Special Items Applicable to the Primary Processing Plants for Agricultural Products."
3. Processing facilities: Property owned by the applicant, or the spouse, or direct blood relatives of the applicant, and in compliance with land use control or construction regulations.
4. Land on which the processing facilities are located: Owned by the applicant; and in the case of the forestry, located on the leased state or public land, in compliance with land use control or construction regulations.
5. Water supply: With legal source of water supply.
6. Workplace: The food processing plant in compliance with the "Good Hygiene Practice (GHP)".
7. Education and training regulations:
(1) Farmers: The applicant or at least one of its employees has obtained a certificate of processing technology and food safety education and training. (Once every 3 years, 40 hours in length, in the case of food processing plants, 8 hours of hygiene training every year).
(2) Farmer Groups: At least two employees have obtained a certificate of processing technology and food safety education and training. (Once every 3 years, 40 hours in length, in the case of food processing plants, 8 hours of hygiene training every year).
The primary processing plants for agricultural products do not require a commercial factory registration, but should meet the regulations for food safety, that is, the "Good Hygiene Practice (GHP)", to maintain a certain degree of control over the staff and hygiene and safety of the processing plant. Applicants need to take into consideration the raw materials used for processing, the sources, the annual amount of usage, the processing methods, the items, the production rates and planned production capacity, and provide to the competent authority a list of machinery and equipment required for the processing, the processing flowcharts and descriptions, and the layout of the buildings and the processing operation areas and facilities to help the competent authority, in reviewing the application, clearly understand the processing plant’s future processing operation planning.
Operators must, in the case of processing food items, comply with the Food Administration Act and the Act Governing Food Safety and Sanitation, and in the case of processing non-food items, comply with the Commodity Labeling Act, and all the records must be kept.
In addition, in the "Processed Products and Processing Method of Special Items Applicable to the Primary Processing Plants for Agricultural Products", there are four processing methods listed: drying, grinding, stir-frying, and crushing. Third-party certification is required for the traceability certification or the organic processing certification but does not include high-risk or high-polluting processing methods, such as pickling, fermenting, sugar making, and the extraction and refining of vegetable oil.
In order to increase the competitiveness of agricultural products and enhance the value of agricultural products, primary agricultural products processing plants should follow legal and safe health management methods that comply with food safety and health regulations. At the time of food safety disturbance, this gives consumers more confidence in Taiwan’s agricultural products processing. There are now complete regulations on the facilities and the education and training of the staff. Now, more diverse primary agricultural products on the market can be expected.