Food Safety Notification on Indonesian Food Export
Nugroho Indrotristanto
1,2
and
Nuri Andarwulan
1,3
1
Directorate of Food Processed Standardization, National Agency for Drug and Food Control,
Jalan Percetakan Negara No 23, Jakarta, Indonesia
2
Department of Food Science and Technology, IPB University, Gedung Fateta, Kampus IPB University,
Dramaga, Bogor, West Java, Indonesia
3
Southeast Asian Food and Agricultural Science and Technology Centre, IPB University, LPPM-IPB University,
Jalan Ulin No 1, Kampus IPB University, Dramaga, Bogor, West Java, Indonesia
Keywords: Food Safety Notifications, Export Refusals, Risk Profile.
Abstract: Notifications due to food safety by importing countries may pose a significant economic burden for exporting
countries, including Indonesia. This review was conducted systematically to list and to identify Indonesian
food commodities notifications, as discussed by published literatures. The study was conducted using a
systematic approach, as recommended by the Preferred Reporting Items for Systematic Reviews and Meta-
Analyses. Eight of 7,210 research papers were selected due to information on Indonesian exported food
notifications. However, only four papers were included in analysis, due to the availability of quantitative data
on the notifications. There were 17 reports from these institutions included in the analysis. Fishery based fresh
food seems to be the major sources of notification, followed by plant or animal based fresh food, processed
food and minimally processed fresh food. This study result indicates that comprehensive risk profiles may be
developed for foods from fishery and plant or animal based fresh food products. The profiles may aid to
discuss about risk factors contributing food notifications as well as identifying gaps for necessary scientific
researches and/or risk assessments.
1 INTRODUCTION
Food export is an important source of revenue for a
country. However, importing countries may issue
notification to exporting countries if the traded foods
do not meet food safety requirement in importing
countries. The notification may differ in location
where food safety authorities found exported food
which does not meet food safety standards or high-
risk food. The European Union Rapid Alert System
for Food and Feed (EU-RASFF) classified
notifications into several categories. Border rejection
is activated when food safety officials determine
high-risk food in point of entry (EURASFF, 2018).
While, Alert and Information are issued when food
safety officials found the high-risk food in the market
(EURASFF, 2018). News is considered when there is
information on the availability of high-risk food
however it does not fall under Border rejection, Alert
and Information status (EURASFF, 2018).
The United States government has a different type
of notifications. The United Stated Food and Drug
Administration (US-FDA) has authorities to check
food of their concern, not only for food safety
requirements but also indication of food fraud
(Bovay, 2016). Import alert status is given to food
shipments which violate US food safety standards
therefore food authorities may carry out Detention
without Physical Examination for the shipment
(Bovay, 2016; USFDA, 2019a, 2019b). US-FDA
commonly follow up import alert status with rejection
of imported foods eventhough rejection can be
performed without having the status (Bovay, 2016).
The detention is then recorded in a database called
Operational and Administrative System for Import
System or OASIS (Bovay, 2016). Exporting countries
may look for their food refusals from this database,
since US government make it available on-line.
Therefore, stakeholders in exporting countries may
take necessary follow-up actions.
Food safety notifications likely affect
international food trade for both importing countries
and exporting countries. Both producers and
government bear the burden due to notification of
their exported food commodities. Notification, such
Indrotristanto, N. and Andarwulan, N.
Food Safety Notification on Indonesian Food Export.
DOI: 10.5220/0009978800002833
In Proceedings of the 2nd SEAFAST International Seminar (2nd SIS 2019) - Facing Future Challenges: Sustainable Food Safety, Quality and Nutrition, pages 151-165
ISBN: 978-989-758-466-4
Copyright
c
2022 by SCITEPRESS – Science and Technology Publications, Lda. All rights reserved
151
Figure 1: Summary of Literature Selection Processes.
as rejection, would likely have an enormous impact
for the export value which is supposed to be earned
by exported countries. These burdens may arise due
several factors, such as export value loss, handling
cost, liability risk and brand equity losses (GMA,
2011). Jongwanich (2009) studied food detention
cases by US-FDA on 2002, 2003, and 2004 for
determining export value losses divided by detention
numbers. Value exports per detention cases of Asia
countries varied between 0.25 Million (Pakistan) until
6.94 Million (Thailand) USD per year. While, the
burden bear by Indonesia due to detention of food
product was reported over 2 Million USD per case per
year for export value losses only (Jongwanich, 2009).
Therefore, strategic steps should be taken to minimize
the loss due to food notification by importing
countries.
Food safety policy development requires risk
profiling. This profile provides information on
combination of food and its associated hazards
(Cressey, 2014). Risk profiling is one of steps in food
safety risk management. Codex Alimentarius
Comission (CAC) recommends risk management in
establishing food safety policies, which consists of a
preliminary risk management activities, the
evaluation of options for risk management, decision
implementations, and monitoring for the impacts of
the implemented policies (FAO/WHO, 2007). The
development a risk profile is one of several activities
in preliminary risk management activities. By
providing relevant information regarding food and its
associated hazards, a risk profil may assisst policy
makers to formulate such efficient and effective food
safety policies (Cressey, 2014). Risk profiling may
also provide information on immediate actions as
well as gaps for necessary research and risk
assessments (Cressey, 2014).
The objective of this review is to list and to
identify Indonesian food commodities notifications.
Futhermore, the associated hazards, which cause food
notification are also identified. This study uses a
systematic review approach, which includes
determining, selecting, and analyzing data of related
literature (Moher et al., 2009). The identified food
and its associated hazards may be a valuable source
of information in selecting food commodities for risk
profiling.
2 MATERIALS AND METHODS
2.1 Search Strategies
Literature searching was conducted systematically
using an approach recommended by Preferred
Reporting Items for Systematic Reviews and Meta-
Analyses (PRISMA) (Moher et al., 2009). The
searching was conducted in ScienceDirect, Proquest,
Emerald Insight dan JSTOR. Keywords used in the
searching were (food OR agricultur* OR fish*) AND
(import OR export) AND (reject* OR refus* OR
9
Identification
Identification through database searching:
PROQUEST:4037articles;SCIENCEDIRECT:
2448articles;JSTOR:97articles;EMERALD
INSIGHT:628articles
(n =7210articles)
Selection through other
sources
Organization report:17articles
(n =17articles)
Afterduplicates
removed
(n =6996articles)
Screening
Literature excluded
(n =231articles)
Literature screened
(n =45articles)
Literature excluded
(n =6951articles)
Eligibility
Literature assessed for
eligibility
(n =18articles)
Included
Literature included in
analysis
(n =18articles)
Literature excluded (n =27articles):
• Full‐text unavailable (1articles)
• Notrelated to safety of Indonesian
food (5articles)
• Quantitative notification notfound
(17articles)
• Contain notification dataprior to
2009(4articles)
2nd SIS 2019 - SEAFAST International Seminar
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notif*) AND Indonesia for Proquest, Emerald Insight
and JSTOR whereas (food OR agriculture OR
fisheries) AND (export OR import) AND (reject OR
refusal OR notification) AND Indonesia were
keywords for ScienceDirect.
The literature selection processes included
duplication checking, screening for abstract and titles,
as well as assessing for eligibility of full-text (Figure
1). Several criteria were applied in the searching.
Inclusion criteria for selection in screening process
included peer-reviewed articles, titles and abstracts
related to food exportation and food safety issue,
articles are in English or Bahasa Indonesia. While,
inclusion criteria for assessing eligibility of a study
included the availability of full-text, the availability
of quantitative data on food notification, and the data
were issued during 2009 – 2019. Besides scientific
literature, searching was carried out for reports
related to food safety notifications in Search Engine.
The criteria for reports were related to food
exportation and food safety issue, articles are in
English or Bahasa Indonesia, the availability of
quantitative data on food notification, and the data
were issued during 2009 – 2019
2.2 Data Extraction and Grouping
Number of notifications were identified from selected
literature. The notifications were grouped under
several classifications, based on food and hazard
associated with the notification. Food was grouped
into four major categories, including fishery based
fresh food, plant or animal based fresh food,
minimally processed foods and processed foods. Each
major group was divided into several sub-groups,
which is called commodities (Table 1). While,
hazards associated with notification were also divided
into several major groups. These major groups were
chemical hazards, microbiological hazards, and non-
chemical and microbiological hazards (Table 2).
2.3 Information Presentation
Notification data were presented in a form of bar
charts. The charts consist of notification numbers and
references (expressed as first author and year of
publication). Notification type was divided into two
categories, which was due to refusals and due to other
reasons. Refusals were mostly reported as the cause
of notification whereas alert, information, and news
were less reported by references. There were two
types of bar charts presented in each major food
group. First chart reported notification number based
on commodities and related references. While another
chart presented the number of notifications based on
hazard types and related references.
Table 1: The classification of notified foods.
Group Commodities Examples as Reported
in References
Fishery
Based
Fresh
Food
Fish Fish, frozen catfish,
red tail gobi, todak,
tuna, frozen tuna
steak, trout
Crustacea Crab, Shrimp
Chephalophod Frozen squid, frozen
octopus, chepalophod
Plant or
Animal
Based
Fresh
Food
Stimulants Coffee
Herbs and
Spices
Cooked spices,
nutmegs, cinnamon
Frog legs Frozen frog legs
Rice Rice
Minimally
Processed
Foods
Dessicated
coconut
Dessicated coconut
Processed
Foods
Instant noodle Instant noodle
Canned Food Canned Food
Sauces Chilli sauce
Chips and
Snacks
Chips, ceriping pedas,
potato chips, cassava
chips, shrimp chips,
fruit chips
Processed
peanut
Medan peanut
Biscuit/Wafer Biscuit, chocolate
wafer
Chocholate
product
Chocolate, chocolate
bar
Beverages Ginger beverages
Food
contact
materials
Gloves Gloves
3 RESULTS
3.1 Literature Included in Systematic
Review
3.1.1 Research Papers
The search strategy resulted in as many as 7,210
articles from scientific databases (Proquest,
ScienceDirect, JSTOR dan Emerald Science) (Figure
1). As many as 231 articles were exluded due to
duplication. Selection process reduced the number of
articles, from 6,951 into 28 articlesOne article was
not available for full-text (Moazami and Jinap, 2009).
Publications from Kok and Radzi (2017), FitzSimons
Food Safety Notification on Indonesian Food Export
153
Table 2: The classification of hazard causing notification.
Hazard
group
Hazard types Examples as Reported
in References
Chemical Allergen Allergen
Hazardous
Substances
Leucocrystal violet,
Leucomalachite green,
Unsafe add
Food
Additives
Cyclamate, sulphite,
azorubine
Heavy metals Cadmium, mercury,
heavy metals
Total
migration
Packaging material total
migration
Mycotoxin Aflatoxin, ochratoxin
Processing
contaminants
Benzopyrene, PAH
Pesticide
residues
Carbaryl
Histamine Histamine
Chlorampheni
col
and
Veterinary
Drug
Residues
Chloramphenicol,
nitrofurans, veterinary
drugs
Microbio-
logical
Pathogenic
Bacteria
Bacillus, Salmonella,
Streptococcus faecali,
Vibrio
Fungi/Yeast Fungi
Bugs
infestation
Bugs
Non-
chemical
and
microbio-
logical
Filth Filth
Improper
process
Lacks Firm,
Inappropriate
temperature control,
Unregistered Low Acid
Canned Food Company
Improper
labelling
Undeclared coloring
and sulphite and GMO
Improper
Certification
Improper Health
Certificate, No Health
Certificate
Poisonous Poisonous
(2010), Wan Norhana et al. (2010), Majumder and
Banik (2019), and Quested et al. (2010) were
focusing on aspects which are irrelevant to the safety
of Indonesian food products. As many as 14
references have already mentioned the safety of
Indonesian food products, however no information
about the quantity of notification were found
(Anggrahini et al., 2015; Bachev and Ito, 2013; Bhat
and Reddy, 2017; Hassan et al., 2018; Imperato et al.,
2011; Kleter et al., 2009; Manning, 2016; Marroquín-
Cardona et al., 2014; McLauchlin et al., 2019;
Paterson et al., 2014; Reiter et al., 2010; Robertson et
al., 2014; Skretteberg et al., 2015; Wang et al., 2013).
While, four scientific publications have reported
notification number on Indonesian exported food
products, however the notification were received
before 2009 (Banach et al., 2016; Bouzembrak et al.,
2018; Jongwanich, 2009; Kuchler et al., 2010).
Therefore, the assessment of eligibility resulted in
four articles for further analysis (Table 3).
Four articles analyzed information from refusal
database published by institutions who have
authorities to notify high-risk imported foods.
Wahidin and Purnhagen (2018) as well as D.’Amico
et al. (2018) studied the information from the
database published in EU-RASFF website. Dataset of
food refusal by US-FDA was used as materials for
analysis by Fahmi et al. (2015). While, Nugroho
(2014) studied imported food rejection by Japanese
food authority.
3.1.2 Other Sources
There were 17 articles obtained in search by search
engine in internet. Sixteen of these sources were
annual reports from EU-RASFF and The National
Agency of Drug and Food Control, The Republic of
Indonesia (NADFC). EU-RASFF is an institution
who has the authority of notifying imported food
which do not meet the food safety requirements in
Europe, according to EC Regulation No 178/2002
related to General Principle of Food Law (EURASFF,
2018). The foundation of EU-RASFF is stated in the
article number 50 of The Law. The purpose of the
founding is to build information sharing system
among EU member countries to take actions
accordingly wherever imported high-risk imported
food are found (EURASFF, 2018).
EU-RASFF publishes annual report which
contain information on the number of notifications
from EU-member countries. The structures of annual
reports begin with the organization legal aspects and
then notification types. Then, there are parts which
discuss the most often hazards causing the
notifications (EURASFF, 2018, 2017, 2016, 2015,
2014, 2013, 2012, 2011, 2010). One of the important
parts of the report is the data on the number
notification, which is presented based on notifying
countries as well as country of origin for the imported
food. There are nine EU-RASFF annual reports as the
source of information in this study.
2nd SIS 2019 - SEAFAST International Seminar
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Table 3: Main characteristics of selected scientific literature.
References Nugroho
(2015)
Fahmi et al. (2018) D.’Amico et al.
(2018)
Wahidin and Purnhagen
(2018)
Title The Impact of Food
Safety Standard on
Indonesia's Coffee
Exports
USFDA Import
Refusal and Export
Competitiveness of
Indonesian Crab in
US Market
Seafood products
notifications in the EU
Rapid Alert System
for Food and Feed
(RASFF) database:
Data analysis during
the period 2011–2015
Improving the level of
food safety and market
access in developing
countries
Objectives Presenting how a
regulation may affect
the global trade of
coffee from
Indonesia. Analysis
was performed using
Gravity Model
Analyze impor
refusal by US-FDA
on Indonesia crab
competitiveness in
The US market
To determine the
profile of notification
for seafood product
carried out by EU-
RASFF in 2011 –
2015
To investigate the risk
management of two case
studies: shrimp and
nutmeg, to formulate
policies to comply with
EU regulation as well as
to make Indonesian food
commodity competitive
Source of
notification
data
Secondary Secondary Secondary Secondary
Notifying
Country or
Institutions
Japan US-FDA EU-RASFF EU-RASFF
Notification
time
2008-2012
(notification data are
available per year)
2002-2013
(notification data are
available per year)
2011-2015
(accumulative)
2000-2017 (notification
data are available per
year)
Food type Coffee Crab Seafood Shrimp and Nutmeg
Hazard Type Several hazards, as
case studies
All related hazards All related hazards Several hazards, as case
studies
Conclusions Regulation on
ochratoxin affect
Indonesian coffee
commodities
compared to specific
country regulation,
for example carbaryl.
Furthermore, bilateral
negotiation may settle
issues related to
specific country
regulation.
Indonesia
experienced numbers
of crab refusal in
2002 – 2013, with
381 cases.
Chloramphenicol was
the most reason for
refusals, with 171
cases.
The highly
competitive
commodities were
unfrozen and
processed crab
whereas frozen crabs
were considered
fairly competitive.
RASFF database
provides useful
information to know
the recent food safety
issues.
Analyisis results
indicates that attention
should be paid not
only to imported
product but also
produced in EU
Furthermore, the
information is useful
for hazard
identification
FSO/ALOP analysis
showed that “top-down”
approach is more suitable
to settle chloramphenicol
in shrimp issue. Whereas
“bottom-up” approach is
necessary to overcome
the issue of aflatoxin in
nutmeg
Food Safety Notification on Indonesian Food Export
155
(a) (b)
(c)
Figure 2: Notifications of exported food from Indonesia 2009 – 2019 as reported in annual reports (a) and scientific literature
(b) as well as their hazards of concern (c).
150
281
240
11
16
26
20
63
35
40
17
32
29
38
21
47
26
23
0 100 200 300 400
EURASFF,2010
EURASFF,2011
EURASFF,2012
BPOM,2013
EURASFF,2013
BPOM,2014
EURASFF,2014
BPOM,2015
EURASFF,2015
BPOM,2016
EURASFF,2016
BPOM,2017
EURASFF,2017
EURASFF,2018
2009 2010 2011 2012 2013 2014 2015 2016 2017
Number of notifications
Year of notification /References
Refusal
Others
66
1
2
30
5
2
23
3
2
186
1
2
25
4
10
7
20
4
2
4
5
2
1
1
1
1
23
0 50 100 150 200
Fahmi, 2015
Wahidi n,2018
Nu groho ,2014
Fahmi, 2015
Wahidi n,2018
Nu groho ,2014
Fahmi, 2015
Wahidi n,2018
Nu groho ,2014
Fahmi, 2015
Wahidi n,2018
Nu groho ,2014
Fahmi, 2015
Wahidi n,2018
Wahidi n,2018
Wahidi n,2018
Wahidi n,2018
Wahidi n,2018
D.'Amico,2018
2009 20 10 2011 2012 2013 2014 2015 2016 2017
2011
‐
2015
Number of notifications
Year of notification /References
Refusal
Others
72
8
72
1
51
5
2
199
23 25
12
13
8
29
17
18
14
2
1
20
26
16
15
8
239
3
13
2
1
3
1
1
1
12
5
6
282
2
1
3
2
11
5
10
3
180
2
37
3
59
4
0 50 100 150 200 250 300
Un kno wn
Poisonous
Labelling
Inapproriatecertifi cation
Inappropr iatep rocessing
Filt h
Pathogenbact eria
Insect infestati on
Fungal/yeastcont amination
Unathorized su bsta nc es
Tot almigration
Processingcontaminant
Pesticideresid ue
Mycotoxin
Histamine
Heavymetalcontamination
Excessivefoodadditi ves
Chloramfen ikolandVeterinary DrugResid ue
Alergen
Unkn
own
Nonchemicalsand
mic rob iolo g y Micr obio logy Chemicals
Numberofnotification
Hazards
BP OM ,2013
BP OM ,2014
BP OM ,2015
BP OM ,2016
BP OM ,2017
D.'Amico,2018
EUR A SFF, 2010
EUR A SFF, 2011
EUR A SFF, 2012
EUR A SFF, 2013
EUR A SFF, 2014
EUR A SFF, 2015
EUR A SFF, 2016
EUR A SFF, 2017
EUR A SFF, 2018
Fah mi,2015
Nu groho ,2014
Wahidin,2018
2nd SIS 2019 - SEAFAST International Seminar
156
NADFC is a government agency which serves as
the secretarat of Indonesia Rapid Alert System for
Food and Feed (INRASFF). INRASFF has a function
more or less the same as EU-RASFF, which facilitate
information exchange between contact points of
Indonesian ministries and agencies related to
following up notified exported food or high-risk
imported foods (BPOM, 2018). The numbers of
Indonesian exported food notification are mostly
found in NADFC annual reports (BPOM, 2017, 2016,
2015, 2014, 2013). However, two annual reports do
not provide the number of notifications of Indonesian
exported food (BPOM, 2018, 2012). Nevertheless,
five annual reports provide valuable information for
analysis in this study, despite of the variability of
notification presented.
An analysis report on refusal by The US
government also became the result of literature
searching process in web search engine. Unlike EU-
RASFF and NADFC, US-FDA does not provide the
number of refusals in their annual reports. However,
a study conducted by Bovay (2016) aimed at showing
trends of refusal of imported food by The US. Bovay
(2016) analyzed the data from OASIS and stated that
Indonesian seafood were among the most refused
food commodities by The US government.
Unfortunately, the number of refusals of these
commodities are not available in the report, as well as
the information of hazards causing the notifications.
Therefore, this report was excluded for analysis in
this study
3.2 Notified Foods During 2009 – 2019
The number of notifications and refusals reported in
NADFC annual reports is more than that of EU-
RASFF (Figure 2a). The number of notifications for
Indonesian exported food was around 16 – 27 in 2009
– 2019 as reported in EU-RASFF annual reports
(EURASFF, 2018, 2017, 2016, 2015, 2014, 2013,
2012, 2011, 2010). Only one annual report published
the number of border rejections, as many as 11
rejections in 2016. NADFC collected Indonesian
exported food notifications from many sources,
including EU-RASFF, The US, Malaysia, and South
Korea (BPOM, 2017, 2016). Besides that, NADFC
also shows the refusals as reported in OASIS. The
number of notifications for Indonesian exported food
was around 63 and 40 in 2012 – 2013, respectively
(BPOM, 2014, 2013). Then, the number rose in the
range of 182 – 319 during 2014 – 2016 (BPOM, 2017,
2016, 2015). Starting 2014, NADFC included refusal
data from OASIS, which made the number of
notifications more than that as reported by EU-
RASFF.
Research papers commonly discuss the refusals of
specific food commodities. Therefore, the reported
numbers of notifications from scientific papers are
less than that from organization annual reports
(Figure 2b). The highest number of notified foods are
reported by Fahmi et al. (2015). Fahmi et al. (2015)
used crab refusal data from OASIS for analysis.
Notifications without knowing the hazards were
commonly found in selected references (Figure 2c).
Chemicals were the known hazards causing most
notification as reported in 11 references. The number
of notification due to this type of hazard were
between two and 200 notifications (BPOM, 2017,
2016, 2015, 2013; D.’Amico et al., 2018; EURASFF,
2017, 2016, 2013; Fahmi et al., 2015; Nugroho, 2014;
Wahidin and Purnhagen, 2018). Microbiological
hazards as the causes of notifications were reported
by five references. The numbers of notification
ranged between three until 14 notifications (BPOM,
2017, 2016, 2014; EURASFF, 2013; Fahmi et al.,
2015). In non-chemical and microbiological hazards
category, only three references reported the
notification, ranging from three until 125
notifications.
3.3 Fishery based Fresh Foods
Notification during 2009 – 2019
Food from fishery products received most
notification compare to other major food groups
(Figure 3a). Crustacea was the most notified food,
reaching 330 notifications during 2009 – 2019 as
reported by one reference (Fahmi et al., 2015).
However, there were two foods included in crustacea
group, where crabs were the most notified while
shrimp only received one notification (BPOM, 2017;
Fahmi et al., 2015). Unlike crustacea group,
chepalopod and fish commodities received less than
20 and 10 notifications, respectively, as reported by
four references (BPOM, 2017, 2016; D.’Amico et al.,
2018; EURASFF, 2013). However, there are more
notifications for sub groups which is unknown for the
details of commodities, ranging from 40 until 255
notifications (BPOM, 2017, 2016, 2015, 2014, 2013).
This sub group was reported by most references in
this major groups, with five articles mentioned about
it (BPOM, 2017, 2016, 2015, 2014, 2013).
Hazards causing notification in this major food
group mostly were chloramphenicol and veterinary
drug residue, poisonous, and filth eventhough each of
the hazard mentioned by one article (Figure 3b)
(Fahmi et al., 2015). However, pathogenic bacteria
Food Safety Notification on Indonesian Food Export
157
(a) (b)
Figure 3: Notifications of exported fishery-based fresh foods 2009 – 2019 (a) and their hazards of concern (b).
(a) (b)
Figure 4: Notifications of exported plant and animal-based fresh foods 2009 – 2019 (a) and their hazards of concern (b).
were reported by more references, despite having less
notification with one until 14 notifications reported
(BPOM, 2017, 2016; EURASFF, 2013; Fahmi et al.,
2015). Other hazards, such as heavy metals,
histamine, unauthorized substances, inappropriate
processing, and labelling, reported by two references
each, with less than 10 notifications received (BPOM,
2017, 2016; D.’Amico et al., 2018; EURASFF, 2013;
Fahmi et al., 2015). The notifications without
knowing detail hazards were the most reported by
144
255
217
330
43
20
10
5
6
8
3
1
1
1
15
14
0 50 100 150 200 250 300 350
BPOM,2013
BPOM,2014
BPOM,2015
BPOM,2016
BPOM,2017
BPOM,2016
BPOM,2017
D.'A mic o,2018
EURAS FF,2013
BPOM,2017
Fahmi ,2015
BPOM,2016
BPOM,2017
D.'A mic o,2018
EURAS FF,2013
Unknown Fish Crustacea Chephalopod
Number of notifications
Commodities/References
Refusal
Others
72
1
51
5
2
199
14
2
1
15
8
217
1
1
1
5
255
1
1
4
154
20
43
0 100 200 300
Un kno wn
Poisonous
Labellin g
Inappropriateprocessing
Filth
Pathogenbact eria
Un athorizedsubstance s
His tamine
Heavymetalcon taminat ion
Ch loramfen ikolandVeteri naryDrug
Resi due
Un kno
wn
No nchemicalsan d
microbiology
Microbi
ology Chemicals
Number of notifications
Hazards
BP OM,2013
BP OM,2014
BP OM,2015
BP OM,2016
BP OM,2017
D.'Amico,2018
EUR ASFF,2013
Fah mi,2015
3
5
11
8
11
55
4
14
18
13
18
8
1
17
1
1
0 20406080
BP OM,2013
BP OM,2014
BP OM,2015
BP OM,2016
BP OM,2017
Nu groho ,2 014
BP OM,2016
BP OM,2017
EUR A SF F, 2016
EUR A SF F, 2017
Wahidi n, 2018
BP OM,2016
BP OM,2017
Un kno wn
Stimul
ants Spicesan dHerbs Rice
Frog
foot
Number of notifications
Commodities/References
Refusal
Others
4
14
21
6
2
11
11
13
1
2
1
2
8
12
72
8
0 20406080
Un kno wn
Inapproria tecertification
Filt h
Pathogenbacteria
Insect infestation
Fungal/yeast cont a mination
Pesticideresid ue
Mycotoxin
Un kno wn
No nchemicalsan d
mic robiolo gy Microbio logy Chemicals
Number of notifications
Hazards
Nugroho,2014
Wahidin,20 18
EURASFF,2017
EURASFF,2016
BPOM,20 17
BPOM,20 16
BPOM,20 15
BPOM,20 14
BPOM,20 13
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most references in this major food group, ranging
from 15 to 255 notifications (BPOM, 2017, 2016,
2015, 2014, 2014; D.’Amico et al., 2018).
3.4 Plant or Animal based Fresh Food
Notification During 2009 – 2019
The number of notifications in this major food group
was not as high as that of food from fishery (Figure
4a). Herbs and spices dominated the number of
notified foods as reported in most references. These
commodities received 8 – 72 notifications during
2009 – 2019 as discussed in five references (BPOM,
2017, 2016; EURASFF, 2017, 2016; Wahidin and
Purnhagen, 2018). While other commodities, such as
frog legs, rice, and stimulants only discussed in one
reference each, with less than 10 notifications
(BPOM, 2017, 2016; Nugroho, 2014). The numbers
of notification without the detail of foods were also
reported in five references, ranging from four to 18
notifications (BPOM, 2017, 2016, 2015, 2014, 2013).
Mycotoxin was the most reported hazards of
causing the notifications (Figure 4b). There were six
references discussed and quantified this hazard,
ranging from four to 72 notifications (BPOM, 2017,
2016, 2013; EURASFF, 2017, 2016; Wahidin and
Purnhagen, 2018). Other hazards, such as pesticide
residue, fungi/yeast contamination, insect infestation,
pathogenic bacteria, filth and inappropriate
certification, were reported by one reference each,
with less than 13 notifications (BPOM, 2017, 2016;
Nugroho, 2014). Notifications with no mentioned
hazards were reported in four references, ranging
from six to 21 notifications (BPOM, 2017, 2016,
2015, 2014).
3.5 Minimalized Processed Food
Notification During 2009 – 2019
Notifications received by this major food group were
the least reported notification compare to other major
food groups (Figure 5a). The only commodity
reported in this major food group was dessicated
coconut. There were two references reported this
commodity, receiving one notification each (BPOM,
2017, 2016). Hazards reported in this major food
group were pathogenic bacteria and excessive food
additive (Figure 5b). Pathogenic bacteria were
reported in one notification as reported by BPOM
(2016) and three notifications as reported by BPOM
(2014). While, excessive food additives were
reported as the cause of one notification by BPOM
(2017).
3.6 Processed Food and Food Contact
Material Notification During 2009 –
2019
This major food group was also included as less
notified food, both by refusal other other reasons
(Figure 6a). Chips and snacks were the only food
commodity receiving more notifications compare to
other commodities in this food group. The
notifications reported in BPOM (2016) and BPOM
(2017), with 13 and 3 notifications, respectively.
Other commodities, such as beverages,
biscuit/wafers, canned foods, chocolates, instant
noodles were reported having one notification, with
less than three notifications, and as reported by one
reference for each commodity (BPOM, 2017, 2016).
Beside food, food contact material also had one
notification as reported by one reference (BPOM,
2017).
There were more hazard types reported in
chemicals group compared to other hazard group in
this major food category (Figure 6b). Excessive food
additives was the most cause of notification, with
three references reported 2 – 10 notifications (BPOM,
2017, 2016, 2015). Other hazards, such as allergen,
heavy metal, processing contaminant, total migration
were reported causing one notification each except
for allergen with three notifications (BPOM, 2017,
2016). Inappropriate processing and labelling were
reported by two references each, for causing mostly
one notification (BPOM, 2017, 2016). While,
pathogenic bacteria were reported causing one
notification by one reference (BPOM, 2016).
However, there were many unidentified food
commodities receiving notification as well as
unidentified causing hazards, ranging from 3 – 21
notifications (BPOM, 2017, 2016, 2015, 2014, 2013).
4 DISCUSSION
4.1 The Notification of Indonesian
Exported Food During 2009 – 2019
There seems a wide opportunity to explore the
notification of Indonesian exported food and publish
it in international scientific literature. Of 7,210
articles found, only eight papers contain information
on the quantity of Indonesian exported food
notification (Banach et al., 2016; Bouzembrak et al.,
2018; D.’Amico et al., 2018; Fahmi et al., 2015;
Jongwanich, 2009; Kuchler et al., 2010; Nugroho,
2014; Wahidin and Purnhagen, 2018). However, only
Food Safety Notification on Indonesian Food Export
159
(a) (b)
Figure 5: Notifications of exported minimally processed foods 2009 – 2019 (a) and their hazards of concern (b).
(a) (b)
Figure 6: Notifications of exported processed foods 2009 – 2019 (a) and their hazards of concern (b).
four articles published the notification on 2009 –
2019, which can be included for analysis in this study
(D.’Amico et al., 2018; Fahmi et al., 2015; Nugroho,
2014; Wahidin and Purnhagen, 2018). Those four
articles analyzed refusal data from published dataset
by the authorities. The refusal data may be used for
several purposes, such as studying food refusal
trends, emerging hazards early detection, as well as
prevention of future risks (D.’Amico et al., 2018).
D.’Amico et al. (2018) studied refusal data from EU-
RASFF to determine the trend of refusal for imported
seafood to EU as well as to characterize hazards most
contributing to the refusals. D.’Amico et al. (2018)
also concluded that the refusals may be a valuable
8
3
2
1
1
02468
BPOM,2013
BPOM,2014
BPOM,2015
BPOM,2016
BPOM,2017
Unk n o wn De ssiccat ed Coco nut
Number of notifications
Commodities/References
Others
1
1
2
3
8
02468
Un kno wn
Pathogenbacteria
Excessivefoodadditives
Unkno wn Micr obio log y Ch emicals
Number of notifications)
Hazards
BPOM,2013
BPOM,2014
BPOM,2015
BPOM,2016
BPOM,2017
11
21
3
1
2
3
8
1
1
1
2
3
13
2
2
1
BPOM,2017
BPOM,2016
BPOM,2015
BPOM,2014
BPOM,2013
BPOM,2017
BPOM,2017
BPOM,2016
BPOM,2017
BPOM,2017
BPOM,2017
BPOM,2016
BPOM,2016
BPOM,2017
BPOM,2016
Unknown Sauce
Peanut
produc
ts
Instant
Noodle Gloves
Chocol
ate s Chips/Snacks
Canne
d
foods
Bis cuit
/Wa fer
Be vera
ges
Number of notifications
Co mmo dities /References
Refusal
Others
11
2
1
1
1
5
1
1
1
1
10
3
3
2
3
8
0 5 10 15 20
Unkno wn
Labelling
Inappropriateprocessing
Pathogenbacteria
Totalmigrat ion
Processing contaminant
Heavymetal contamination
Excessivefoodadd itives
Alergen
Un kno wn
No nchemicalsand
microbiolo gy
Microbiol
ogy Chemicals
Number of notifications
Hazards
BPOM,2013
BPOM,2014
BPOM,2015
BPOM,2016
BPOM,2017
2nd SIS 2019 - SEAFAST International Seminar
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information for hazard identification in food safety
risk assessment step.
Another example of a study using EU-RASFF
database was a study conducted by Banach et al.
(2016). The purpose of the study was to determine the
trend of food safety hazards in herbs and spices
commodities during 2004 -2014. Banach et al. (2016)
combined EU-RASFF database with other literatures,
such as annual report of European Food Safety
Authority, World Health Organization Global
Environmental Monitoring System (GEMS)/Food
database, and The Netherland Food and Consumer
Product Safety Authority database. Banach et al.
(2016) showed that several herbs and spices, such as
blackpepper and dried herbs, were dominated by
pathogenic bacteria, such as Salmonella spp. and E.
coli whereas Bacillus spp. was also found in chillies
and curries. Mycotoxin contamination was a major
cause of notification for herbs and spices as shown in
EU-RASFF database, GEMS/Food database and The
Netherland Food and Consumer Product Safety
Authority database. The mycotoxin contamination
caused more than 500 notifications as recorded in
EU-RASFF database and The Netherland Database,
even reaching 30,000 notifications as recorded in
GEMS/Food database (Banach et al., 2016). Banach
et al. (2016) concluded that the most concerned
microbiological hazards for herbs and spices were
Salmonella spp and Bacillus spp whereas most
concerned chemical hazards were aflatoxin B1 and
ochratoxin A. Moreover, Banach et al. (2016) also
recommended the use of notification data collected in
authorized institutions database for hazard
identification as also suggested by D.’Amico et al.
(2018).
Fishery based fresh food is one of the important
export commodities for Indonesia. Besides for
exporting, the high number of fish resources, which
is estimated reaching 12.5 tonnes in 2016, makes this
commodity reliable for domestic consumption as well
(KKP, 2018). However, this food is the most
receiving notification compared to other major food
groups (Figure 3a). Rosabel (2018) conducted a study
related to the refusal of Indonesian exported food by
the US in 2010 – 2017 by using OASIS database. The
average of refusals of Indonesian product was 282
cases per year in 2010 – 2017, dominated by fishery
products with the average of 126 refusal cases per
year (Rosabel, 2018). The refusal number is almost
the same as the difference between notification of
Indonesian food as reported by EU-RASFF and
NADFC (Figure 2a). It suggests that refusal by The
US government dominated the number of
notifications of Indonesian exported foods. Rosabel
(2018) study was in line with study conducted by
Bovay (2016). Indonesia, together with Thailand, was
the most countries receiving notification from US-
FDA for fishery products (Bovay, 2016).
Further exploration is needed for determining the
most commodity receiving notification in food from
fishery group. In this study, the most notified food
from fishery was crabs as reported by Fahmi et al
(2015) (Figure 3a). However, there were numbers of
notifications, which were unable to determine the
details of the commodities as well as the causing
hazards, ranging from 40 until 255 notifications
(BPOM, 2017, 2016, 2015, 2014, 2013). Therefore, it
is likely that there were other commodities which
received notifications at the same amount or even
more than crab commodities. Rosabel (2018) found
that tuna dominated in the number of refusals by US-
FDA, receiving more than 1,000 out of 2,019
notifications of seafood products. The number of
notifications of snapper, shrimp and crab were almost
the same, which were 245, 242 and 232 notifications,
respectively (Rosabel, 2018). On the other hand,
Irawati et al. (2019) reported that tuna was the most
notified food from The European Union on 2011 –
2017, with 27 notifications. Whereas in this study,
fish commodity was reported receiving only 3 – 8
notifications (BPOM, 2017, 2016; D.’Amico et al.,
2018; EURASFF, 2013). Further analysis of
notification using published database by authorized
institutions may be carried out to get better profile of
the notified fishery-based foods.
Chloramphenicol and veterinary drug residue,
poisonous and filth, and pathogenic bacteria
dominated as the cause of notification in fishery
based fresh food. Chloramphenicol is prohibited to be
added in animals as food ingredient in many
countries, because of possibility causing cancer and
aplastic anemia in humans (Berendsen et al., 2010).
Veterinary drugs commonly used to treat and to
prevent animal disease in aquaculture. However,
imprudent used of these drugs may contribute to
antimicrobial resistence of pathogenic
microorganism (Economou and Gousia, 2015). Food
authorities have urged prudent use of veterinary drugs
as a prevention step from antimicrobial resistence.
Food refusals due to chloramphenicols and veterinary
drug residues are also reported in elsewhere. Rosabel
(2018) reported that 202 refusal cases of crab producs
was due to these chemicals during 2010 – 2017.
Rahmawaty et al. (2014) also reported the number of
seafood refusal due to chloramphenicol, as many as
29 cases in 2010 – 2012. Food is considered
adulterated if there are poisonous ingredient,
prohibited colorants and filth, according to The US
Food Safety Notification on Indonesian Food Export
161
Food, Drug, and Cosmetic Act (Bovay, 2016). Filth
is defined as common sense, any materials supposed
not to be in the food, such as bugs, parasites, metal
shards, and glass pieces (USFDA, 2013).
Pathogenic bacteria were another hazard not
many reported as the cause of notifications. In this
study, four references reported notifications due to
these bacteria, ranging from only 1 – 14 notifications
in 2009 – 2019 (BPOM, 2017, 2016; EURASFF,
2013; Fahmi et al., 2015). On the other hands, several
studies reported numbers of notification were caused
by this hazard. Rosabel (2018) reported that the
number of refusals for food from fishery product due
pathogenic microorganisms may reach 706 cases in
2010 – 2017. Rahmawaty et al. (2014) also reported
534 refusal cases of foods from fishery-based food
due to the same hazards in 2010 – 2012. Both of them
mentioned that pathogenic microorganisms were
included as major cause of notification for this fishery
food. The different results may be from different
methodology used in this study. However, this study
also resulted in several notifications with unidentified
food commodities and hazards. Further study may be
needed to reveal those unidentified notifications.
Herbs and spices are the most notified
commodities in plant or animal based fresh food, as
reported in both annual reports and research papers
(Figure 4a). Enhancing flavor and bioactive
compounds are the purpose of addition of herbs and
spices in food (Banach et al., 2016). One of popular
foods in this commodity is nutmeg. Nutmeg is
commonly consumed as powder mixed in the food.
This study showed that mycotoxin dominated as the
cause of refusals. Several literature also report that
this food is contaminated with pathogens and
mycotoxins (Banach et al., 2016). Eventough nutmeg
consumption level is low in Indonesia, the presence
of mycotoxin makes this food included as high-risk
food (Wahidin and Purnhagen, 2018).
Several attempts have been made by Indonesian
authorities to minimize contamination of mycotoxin,
starting from improving handling practices until
providing education for exporters (Kemtan, 2018).
Importing countries also implement policy to control
incoming nutmegs, for example EU issued
Commission Implementing Regulation (EU) 2016/24
of 8 January 2016 on imposing special conditions
governing the import of groundnuts from Brazil,
Capsicum annuum from India and nutmeg from
Indonesia and amending Regulations (EC) No.
669/2009 and (EU) No 884/2014. This regulation
requires health certificate on importing nutmegs from
Indonesia and checking for 20% of every
consignment as sample (EU, 2016). Implementation
of good practices in exporting countries and
continuous education for exporters are necessary to
minimize the chance of being notified by importing
countries.
Dessicated coconut is one of the examples of
minimally processed foods with highly competitive
value for global trade. This commodity is considered
as high potency of export, beside other coconut
product, such as nata de coco, brown sugar, and
coconut shell (Probowati et al., 2011). Dessicated
coconut has not only high nutrition value but also
many usages. Fat and oil, carbohydrate and protein
content from this commodity around 60%, 20% and
7% of total weight, respectively (DebMandal and
Mandal, 2011). Therefore, dessicated coconut can be
suitable ingredients for biscuits (Manley, 2000).
However, notifications are also received for this
commodity eventhough the numbers is less (Figure
5a). Salmonella spp., Streptococcus spp., and
Bacillus spp. caused four notifications in 2013 and
2015 (BPOM, 2016, 2014). Whereas, food additives
cause one notification of this food in 2016 (BPOM,
2017). The presence of pathogenic bacteria may be
from contaminated water used for cleaning coconut
prior to drying process whereas shulphur dioxide may
be from fuel impurities (Manley, 2000). National
authorities should pay attention to this commodity
since Indonesia is one of the world suppliers of this
product, together with Sri Lanka and Philipine
(Manley, 2000).
One of the most reasons for notified processed
food is the use of food additives. Chips and snacks are
the commodities mostly notified in 2015 and 2016,
with 13 and 3 notifications, respectively (Figure 6a).
However, the notifications due to difference in food
safety regulation between Indonesia and importing
countries. There are additives, for example cyclamate
and sulphite, which are not permitted to be used in
food in importing countries eventhough those food
additives are permitted with maximum limits in
Indonesia (BPOM, 2017, 2016). Continous education
to food producers and exporters on food safety
regulation in importing countries is required for
reducing the numbers of notification.
4.2 Recommendation for Risk Profiling
Several major notifications in Indonesian food export
may be used as a starting point for the development
of risk profiles. In fishery based fresh food products,
this study results suggest that risk profile may be
developed for crab, because of the number of
notifications. This commodity was reported to
contain chloramphenicol, veterinary drug residues,
2nd SIS 2019 - SEAFAST International Seminar
162
poisonous and filth. However, other hazards may be
present in this food. There is also possibility that other
fishery products needed to be further explored for risk
profiling. Fish, together with cephalopod, are
commodities discussed by more references. Several
other studies also reported fish commodity mostly
received notifications (Rahmawaty et al., 2014;
Rosabel, 2018).
Herbs and spices, including nutmeg, is one of
main topics of notification in plant or animal based
fresh food. Several efforts have been made however
there are re-occured notifications. Profiling of risk
factors in producing chains may be necessary for
mitigating strategies. Eventhough having less
notifications, dessicated coconut may also be
prioritized for profiling. It is due to Indonesia is major
supply for this food for the world (Manley, 2000).
5 CONCLUSION
Fishery based fresh food was the most receiving food
safety notification during 2009 – 2019. Crustacea,
especially crab, was the most notified, whereas fish
and cephalopod were discussed in more references.
The type of hazards most discussed in this food group
were chloramphenicol and veterinary drug residue,
filth, poisonous and pathogenic bacteria. Herbs and
spices dominated in terms of notification in plant or
animal based fresh food, with mycotoxin were the
most reported hazards of concern. The number of
notifications of minimally processed and processed
food were lower than that of fresh food.
Comprehensive risk profiles may be developed for
fishery and plant or animal-based food. The profile
may identify risk factors contributing to food safety
notification as well as gaps for research needed. The
profile may also be developed for minimally
processed and processed food due to their
contribution to Indonesian revenue. This study is
limited to the figures reported in published literatures
from selected scientific database. Expanding the
scope of database and analyzing data directly from
the dataset published by notifying authorities may be
useful for determining unidentified foods and hazards
ACKNOWLEDGEMENT
Puspo Edi Giriwono, PhD. for assisting in a
systematic review methodology as well as reviewing
and proof-reading this article.
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