New guidelines regarding the correction of the notification
The Chief Sanitary Inspector (GIS) has already published new guidelines for the correction of notifications submitted in the electronic notification system.
Any changes of the product that have impact on its nutritional or physiological properties, as well as changes in the distribution chain require a new notification.
In the light of the above, according to the new position of GIS, a new notification is required if:
- the active substances of the product have been changed,
- the form of the product has been changed,
- the product name has been changed,
- the producer of the foodstuff has been changed,
- the food business operator who place the product on the market has been changed,
- the qualification of a foodstuff notified to the Chief Sanitary Inspector (e.g. from food for special medical purposes to a food supplement) has been changed,
- other changes of the product which may change its physiological, nutritional or purpose properties.
Changes in the notification in the way of a so-called ‘correction’ are not possible if:
- the notification has been accepted by the Chief Sanitary Inspector;
- the company has previously resigned from placing the product on the market,
- the Chief Sanitary Inspector conducts proceedings pursuant to Art. 30 para. 1 of the Act on food and nutrition safety of 25 August 2006 (Journal of Laws of 2018 item 1541, as amended) and in situations indicated in the provisions of Art. 31 of this Act.
An important aspect from the perspective of food business operators is official information on the GIS website indicating that if the product’s changes concern substances that do not affect the nutritional value, the product’s function and its qualification (e.g. food additives, flavours), then there is no need to notify them to the Chief Sanitary Inspector. The same applies to the changes in the label, for example, the change of a colour or information order.
The full content of information published by the Chief Sanitary Inspector is available at: https://gis.gov.pl/zywnosc-i-woda/korekta-i-uzupelnienie-dokumentacji-dotyczacej-skladanych-powiadomien/