Food law en aansprakelijkheid: wie draait op voor een recall? Gesprek met topadvocate Katia Merten-Lentz

Introduction

Alexander Platteeuw, A+ Quality:

The following interview is in English. I am Alexander Platteeuw from A+ Quality and I am your host for today. If you want to listen or watch in your own language, please note that this interview is fully subtitled on YouTube.

My guest today has a degree in law and has been a partner with various law firms. Today she is a partner and food lawyer with Food Law Science & Partners, based in Brussels, where she assists clients throughout the food chain with issues ranging from food labelling, health and nutrition claims to innovation. She also helps clients in the food and feed sector to obtain European authorisation for new additives, enzymes and novel foods.

For that, she works regularly with institutions, European and national professional bodies and commercial organisations. Not only that, she is a frequent speaker at international conferences and is one of only four attorneys ranked by Chambers and Partners in the EU-wide agri-food regulatory category. She is also recognised by The Legal 500 in both Belgium and France as a leading individual in the EU regulatory category.

Wow! With such a curriculum vitae, I hope never to have her as an opponent in court. I can’t wait to start this interview.

Welcome, Katia Merten-Lentz.

Katia Merten-Lentz, Food Law Science & Partners:

Thank you, Alexander. After such an introduction, I can leave. Everything has been said.

Thank you.

Alexander Platteeuw, A+ Quality:

Anyway, I still have questions.

Katia Merten-Lentz, Food Law Science & Partners:

It's very flattering.

How she got into food law

Alexander Platteeuw, A+ Quality:

Katia, let’s go back to the start. What attracted you specifically to food and to food safety?

Katia Merten-Lentz, Food Law Science & Partners:

Coincidence, and life. It all started 31 years ago. My background at university was European law, which at the time was something highly specific.

And my first job in a law firm in Brussels was to join a former agent of the European Commission who, after retiring, decided to create and develop a department dedicated to agri- and agro-law, which was so new, so innovative. So I cannot say that we literally created this area of expertise, but we were not far from it.

Alexander Platteeuw, A+ Quality:

More or less.

Katia Merten-Lentz, Food Law Science & Partners:

We really were pioneers, we really pushed and we were at the top. I just followed, because when I started we were in the middle of the cow crisis, the mad cow crisis. And so food safety was at the centre of everybody’s attention, of everyone in Europe.

And so, very naturally I would say, I followed the adoption of all the rules that now form the basis of food law.

What a consumer can do against unsafe food

Alexander Platteeuw, A+ Quality:

That’s the beginning of my story. Okay. So today in Belgium we have the federal authority, the FAVV, whose mission is to protect the consumer against any health issue caused by the consumption of food.

But let’s say a consumer is confronted with unsafe food. We now have the Nestlé story in the news. What can he or she do legally?

Katia Merten-Lentz, Food Law Science & Partners:

Okay. I am not the best placed to answer your question, because, just between you and me, I can tell you everything.

I am usually on the side of the company. But of course I can give you a legal answer, an official answer. Yeah, definitely.

AFSCA, FAVV are at the disposal of consumers and consumer associations to gather and receive any kind of complaint, to investigate, to open an investigation, to sue companies, to ask for analyses, for anything and everything. So any unsafe, or even unfit, product that is already on the Belgian market can be reported to the AFSCA, FAVV in order to be withdrawn or recalled. Yeah.

Alexander Platteeuw, A+ Quality:

But imagine I am a consumer and I say, okay, my baby became ill after eating this product. Can I bring a company to court?

Katia Merten-Lentz, Food Law Science & Partners:

Can I sue a company? Of course. All of this is based, regardless of the fact that we are facing a food safety case, on a very straightforward legal basis.

We are back to the principle that there is a fault, there is damage, and you need to prove the causality.

Alexander Platteeuw, A+ Quality:

Yeah.

Katia Merten-Lentz, Food Law Science & Partners:

Okay. So once you have the justification and a robust demonstration of these three elements, if a consumer feels strong enough to sue a company himself, fair enough, go ahead. But usually it is better to ask an association, or to go to – I think, no, I don’t think, I am sure – the FAVV and AFSCA, which have a central point for any kind of complaint.

But again, please, next question. Okay.

Who is liable in the food chain?

Alexander Platteeuw, A+ Quality:

So from the other side, let’s take the example of placing a product contaminated with salmonella on the market, resulting in illness and deaths. Who is responsible? I know there is personal liability for people on the organisational chart of the company that is the source of the problem.

But how does this work in practice? I mean, can multiple actors in the food chain be held responsible? Is the food safety manager in a company also liable?

Katia Merten-Lentz, Food Law Science & Partners:

Okay. Here you are asking me one question, with a sub-question inside another question, I would say. Just give me two more minutes.

First of all, a consumer, primarily, can and has to sue the food business operator in whose name the product was placed on the market. Exactly.

Alexander Platteeuw, A+ Quality:

The one who is on the label.

Katia Merten-Lentz, Food Law Science & Partners:

I would say Danone; I do not mean a person’s name, but the brand, the brand plus the name. And that is it for the consumers.

Alexander Platteeuw, A+ Quality:

Okay.

Katia Merten-Lentz, Food Law Science & Partners:

Now, I mean, in the back office, along the food chain – and we have known since the whole Horsegate scandal, you remember, it was like a discovery of the entire trading chain along the food chain. Yes, definitely. It is not just Danone plus a farmer, no, there are suppliers.

There are so many suppliers of ingredients, processors, and suppliers of suppliers, until a product, a final product, is placed on the market. But again, the consumer will sue the brand, the manufacturer who placed the product on the market. Then, if this manufacturer is not liable, is not accountable, is not the one responsible for, how can I say, the compliance of the product,

it is up to this company, this food business operator, to sue in its turn its suppliers, and the suppliers of its suppliers, the one who is responsible for the contamination or for the wrong delivery of information. Maybe I should have started with this reminder: along the food chain, the most important principle is solidarity. From post-harvest, the very first raw material, until the placement on the shelves of a retailer.

We could have thousands of traders and so on. That does not matter. The point is that each step, each operator along the food chain, plays its role fully, conscientiously and seriously.

Normally the famous zero risk should then be guaranteed at the end. Okay. So it is a question of solidarity, of transparency, of the full delivery of complete information, and of an accurate and compliant product until the end of the food chain.

So, back to your question. Now, Nestlé or another company, they in turn sue, but on a contractual basis. Okay.

So that is one part of your question. The second part is now the internal side. And I think you mentioned it is a question of a chart, the internal chart, the structure, the organisation, the internal organisation of each company.

It depends. More generally, when it comes to something very serious, it goes up to the CEO. To the top.

Alexander Platteeuw, A+ Quality:

Yeah.

Katia Merten-Lentz, Food Law Science & Partners:

Because the other people involved usually have just, I mean, have just done their job. Okay. But there is one person at the end who has to be responsible.

And I do not say that this person did not do his job, but in the end someone has to be responsible, and that comes with the job.

Alexander Platteeuw, A+ Quality:

But he has personal liability. I mean, he can be sued in person.

Katia Merten-Lentz, Food Law Science & Partners:

He can be. Normally, no, normally, first of all, he is liable and accountable because he acts on behalf of his company, his or her company. But if there is something, a negligence, something we can blame him for, then he could be personally liable.

And when it comes to jail, to criminal sanctions, it could be on behalf of his company, but a company cannot go to jail. So somebody has to go to jail.

Alexander Platteeuw, A+ Quality:

So they will pick him.

Katia Merten-Lentz, Food Law Science & Partners:

They say: please, who would like to?

Alexander Platteeuw, A+ Quality:

Yeah. But then on the other hand, I am just thinking of the worst case now. This CEO says: yeah, okay, but I asked my food safety manager to do this and that.

She did not do it. So can the food safety manager then be held liable?

Katia Merten-Lentz, Food Law Science & Partners:

Theoretically yes, but it is on a case-by-case basis. And based on my experience it is generally very difficult to demonstrate a very serious negligence or fault behind it.

Alexander Platteeuw, A+ Quality:

If it were falsification or fraud, then you could say: okay, it is you.

Katia Merten-Lentz, Food Law Science & Partners:

If it is just a quality manager who thought he was following the rules but missed something, that is still human. So it is not strong enough to sue him personally. And look at other precedents and case law.

Very often the CEO was dismissed after a scandal.

Alexander Platteeuw, A+ Quality:

Or, in the West, Stewart Parnell, who was sentenced to 27 years.

Katia Merten-Lentz, Food Law Science & Partners:

We always need to cut off one head.

Alexander Platteeuw, A+ Quality:

And that will be the top head. Now, we started from the principle that the consumer sues a company. It can also be the AFSCA that sues the company, of course.

Katia Merten-Lentz, Food Law Science & Partners:

Generally it is AFSCA. I know AFSCA very well.

Alexander Platteeuw, A+ Quality:

I imagine.

Katia Merten-Lentz, Food Law Science & Partners:

We are in contact on a very regular basis.

Alexander Platteeuw, A+ Quality:

I can imagine. What are the possibilities if a food processor does not agree with the findings made by the AFSCA? The AFSCA says: I am taking you to court.

The food company says: excuse me, but the mistake is not mine, it is a Chinese supplier’s.

Katia Merten-Lentz, Food Law Science & Partners:

Alexander, is that a real question? Do you not know the answer? They come to me immediately: helpdesk, 9-1-1.

To me, or to my firm, or to somebody else. But I mean, it is their full right to contest, to challenge an AFSCA, FAVV decision. And I am used to challenging FAVV positions, because it happens more and more often that the FAVV considers itself better placed to assess the situation than the business operators themselves.

And that when the AFSCA says something, it is better than the operator’s own assessment, for instance of the scope of a recall. The AFSCA says: no, no, you have decided to recall, I do not know, 5,000 products. Okay, well noted.

But after a very quick analysis, we consider that you should recall 10 or 20 times that number. So it is sometimes very brutal. Okay, and generally our answer is built on a threefold approach.

First of all, you absolutely need to assure and reassure the AFSCA, FAVV that you have identified the origin of the crisis. Okay, it seems logical, but it is essential. Yes: hello AFSCA, FAVV, something has just happened.

We have investigated immediately. Yes, we are on it. We know precisely what happened and why.

Okay, that is the first point. The second point is to say: based on what happened and why, we immediately stopped. Yes, we blocked the goods.

Yes, we put on a patch, like when you repair the wheel of your bike, the rustine, as we say in French. But never forget the third element, which is to tell the AFSCA, FAVV: and it will not happen again in the future. And if my understanding of your background is correct, that is something related to HACCP, to all of food safety, but on the technical and scientific side.

That is to say: this is the situation now.

Alexander Platteeuw, A+ Quality:

We have taken preventive measures, and…

Katia Merten-Lentz, Food Law Science & Partners:

Critical control point, highly critical control point. And we take very precise and definitive measures. Okay, and normally, if you follow that – and I know there is no normal situation, but fingers crossed – so far it works pretty well.

And when you are strong enough, based on this structure for challenging the FAVV decisions, plus a very detailed scientific risk assessment, they will let you manage the situation.

Mutual recognition and national rules

Alexander Platteeuw, A+ Quality:

Yeah, touch wood. One other topic that a lot of my clients struggle with is the jungle of EU legislation. Jungle?

And the link, or let’s say the absence of a link, with national legislation. Let me give you an example. A Belgian food producer has to comply with the EU and Belgian legislation, of course.

Now he also wants to sell his product in the Netherlands. But in the Netherlands, since 1 January, you now have PAL, precautionary allergen labelling. And so, yeah, I mean, I am producing here in Belgium, so I do not have to deal with Dutch legislation.

Now I want to export to the Netherlands. But yeah, there is the European principle of, how do you call it? Mutual recognition.

Mutual recognition. Explain to our listeners how a company has to deal with that in such a situation.

Katia Merten-Lentz, Food Law Science & Partners:

It is a very interesting question. I would need more time, but in a nutshell, the principle of mutual recognition is a very important one. Its purpose is to guarantee proper trade and the circulation of goods all over Europe, to harmonise and to make sure that everything is fine within the market.

But on top of that, it is to make sure that one member state respects the other member states. There is normally no hierarchy among the member states. You cannot say that French rules are better than Italian, Dutch or Belgian ones.

That is the principle. But where there is a principle, there is quite often, not to say generally and always, an exception. The principle of mutual recognition means that a product which has been lawfully and properly placed on another market is legal and compliant.

Automatically.

Alexander Platteeuw, A+ Quality:

Automatically.

Katia Merten-Lentz, Food Law Science & Partners:

There is a presumption of legality, of compliance. Of compliance. So, based on this presumption, it is supposed to be lawfully placed on any other market as well.

That was your question: what about a fully compliant Belgian product that you would like to place on the Dutch market? As I have just mentioned, the exception, or the limit, to this principle is safety.

One member state is always, in theory, able and allowed to deny access to its market on safety grounds. It sounds a bit crazy. What do you mean?

That Dutch people are more sensitive, more fragile than Belgians? In your example, for instance. And my answer would be: I am sorry, but yes, because when it comes to safety a member state is still allowed to put legal obstacles in place, extra technical obstacles, which officially are supposed to protect the safety of its citizens.

Remember a completely different example, the French one, just so that we do not seem to have something against the Dutch, our Dutch compatriots. You will remember, I am sure, that in France, when it came to BPA, bisphenol A, France decided out of the blue that there was no way, that everything had to stop. You stop placing it on the market, you stop producing, you even stop exporting. But our Conseil d’État decided that they had gone too far, that this was not possible. So we went back.

But France still kept a ban on producing and on placing on the French market. And what happened afterwards is that the whole of Europe followed. Yeah, in that case, yes.

And this PAL may well become a similar case, I mean.

Alexander Platteeuw, A+ Quality:

Yeah, but they will go in the same direction, I think.

Katia Merten-Lentz, Food Law Science & Partners:

Yeah, yeah, because it makes sense. Honestly, it makes sense. It is pretty smart.

I work, I am used to working a lot on allergen questions and umbrella claims, and there were too many issues around these umbrella claims, hence their position.

Alexander Platteeuw, A+ Quality:

I know, but in the meantime we have this period where, yeah, I have to make an extra label for the Dutch market. But so, in summary, the Netherlands can say: we refuse these goods on our market because they do not comply with our national legislation. Unfortunately.

Katia Merten-Lentz, Food Law Science & Partners:

Belgian food business operators can always try, because there are many systems and legal avenues to challenge a member state’s no-go, so we can try. It is too early to see the consequences and to assess the situation, but off the cuff, this is my answer.

The ethylene oxide crisis

Alexander Platteeuw, A+ Quality:

Another case, from 2020, was the ethylene oxide case, ETO. I personally remember that quite well, with the sesame coming from India, where they had disinfected their containers, yeah, which was…

Katia Merten-Lentz, Food Law Science & Partners:

…with a strictly prohibited pesticide, yeah.

Alexander Platteeuw, A+ Quality:

Exactly, exactly. And then it was first sesame, then guar gum, and then Pakistan as well, and what a chaos. We were faced with huge recalls, although at that time there were no legal grounds for them, at first.

Can you guide us through this principle of authorities forcing a product recall, even if there is no legal limit for a certain substance?

Katia Merten-Lentz, Food Law Science & Partners:

Be careful with your wording; you said legal rationale, or legal basis. I do not agree. First of all, first comment: yes, of course I remember, and I am still working on those cases.

Alexander Platteeuw, A+ Quality:

Oh my God.

Katia Merten-Lentz, Food Law Science & Partners:

Yeah, on cases, on ETO cases. First comment: it was chaos, yes. Why?

Simply because those sesame seeds were processed into so many products. We were just talking about the long chain of trade and intermediaries; this is a perfect illustration.

And at first you could say: I do not care, I never eat sesame seeds. You would be surprised, you eat a lot of sesame seeds. So the reason for this chaos is that almost the whole food chain was basically…

Alexander Platteeuw, A+ Quality:

…involved.

Katia Merten-Lentz, Food Law Science & Partners:

Involved. So that is the first point. Secondly, when you say there was no legal basis, the matter became very delicate when it came to highly processed foods.

And then, despite the fact that the food business operator knew that he had bought ingredients coming from India, because you have a fully transparent chain, so they knew for sure, they made a risk assessment, and the result of that risk assessment, in other words the result of the analysis, did not show any traces of these pesticide residues. So in a normal, in a more common situation – back to, I do not remember your question.

How does it work when you want to challenge a FAVV decision? Normally, based on: I knew, I identified the crisis, I stopped, I made my risk analysis, and it is fine because the level is far below the limit of detection, or something like that.

And for the future, I will never, ever buy anything from India again. That being said. Bye-bye.

Thank you for coming. Okay. Usually that works, but this is a typical example where it did not work.

Why? Because it was so big. And the most cautious among the member states, you know, the syndrome of the best pupil in the class.

I am French, so if I criticise my own country, it is objective. We generally suffer from the syndrome of the best pupil in the class.

And you always want to show that yes, we were the first and we are the strictest. Yes, we have the highest safety standards, and things like that. So among the member states France was particularly cautious, and the DGCCRF decided out of the blue that from then on, from day one, as soon as a business operator knew that, as I said, a supplier of a supplier had bought something from India, they were officially and firmly told to recall, to recall, to destroy, everything.

And they did not care about any risk assessment, despite the fact that you could demonstrate that there was no risk, that there was no trace, that it was diluted and so on. Belgium took another position. It depends.

We had so many different positions. That is one of the reasons why we still have pending cases, legal actions and things like that. But in the end, although not quickly enough, the European Commission reacted and decided on behalf of all the member states.

Because at the beginning and at the end, we are supposed to be one single market. Okay, so when we face such a situation the European Commission should react without delay, which was not the case here. And the European Commission left some time and some space to the member states.

So unfortunately it is not a question of legal basis or of science; it was more a question of politics.

Alexander Platteeuw, A+ Quality:

Yeah, yeah.

Katia Merten-Lentz, Food Law Science & Partners:

That is my humble…

Alexander Platteeuw, A+ Quality:

With huge consequences for the food processors.

Katia Merten-Lentz, Food Law Science & Partners:

Sure, it was a disaster. You talked about chaos; for some of them it was a knockout.

The precautionary principle today

Alexander Platteeuw, A+ Quality:

Which developments in European food law keep you busiest at this moment?

Katia Merten-Lentz, Food Law Science & Partners:

Food safety, of course. Honestly, because I would say that since Covid – and I do not think Covid really has anything to do with it, but it is, I mean, it is a marker on my timeline.

Alexander Platteeuw, A+ Quality:

Yeah, it is a marker.

Katia Merten-Lentz, Food Law Science & Partners:

It is a marker on my timeline, yeah. More or less since Covid, more and more often, as I have just told you, the AFSCA, the DGCCRF and the national control authorities almost everywhere in Europe tend to decide on behalf of my clients. Even when I think they did everything perfectly.

As perfectly as they could, given the circumstances. In the past, in the same circumstances, the national authority would have said: okay, thanks for informing us. You have complied with the general food law.

You informed us without delay. Thank you. Okay, we will keep an eye on you.

Big brother is watching, but it is fine. Now they come and say: okay, okay, it is fine, but our gut is telling us that no, no, you should withdraw. The precautionary principle, to an extent you cannot imagine.

It is a big, big umbrella.

Alexander Platteeuw, A+ Quality:

And they don't care.

Katia Merten-Lentz, Food Law Science & Partners:

They are not business-oriented. So in our defence we cannot say: do you have any idea how much this costs? But that is an impact as well.

And when it is not justified, I mean, you kill a business simply by applying the precautionary principle. And so I always stand firm on the side of my clients in order to change that position.

EU versus US approach

Alexander Platteeuw, A+ Quality:

Okay, so in the EU we have this precautionary principle. If I am correct, in the US they start from another point of view: a food product is safe until the opposite is proven.

Am I correct there, or am I wrong?

Katia Merten-Lentz, Food Law Science & Partners:

Do you have any bodyguards? You are very brave, Alexander, but I fully share your point of view and your approach. And I do not mind saying so.

Often, even when I give a talk in the US, I mention that we are proud within the EU to have the highest safety standards, because of the solidarity along the food chain. And yes, you are fully correct. Their approach is less strict, it is more ‘who cares’ until the product is placed on the market.

But then it is a disaster. Remember, they have class actions.

Alexander Platteeuw, A+ Quality:

Then they go all the way.

Katia Merten-Lentz, Food Law Science & Partners:

It is such a powerful system. It can totally destroy the reputation and the company, the reputation definitely and the company too, because the result of a class action means billions of dollars to be paid by the company. So the approach, the US philosophy, is a bit different.

But to be honest, they are now moving closer to our system and are becoming more, I would say, more focused on control all along the food chain. They now seem to have realised that the notion, the concept of the food chain, means something. So we cannot say that we have an EU approach and a US approach that are drastically different.

No, not any more. But it is a good point.

Alexander Platteeuw, A+ Quality:

Yeah. Okay. I just wanted to be sure that I am on the right track.

The future of UK legislation

Alexander Platteeuw, A+ Quality:

As the Belgian food industry, what can we expect from UK legislation in the future? They have left the EU. Will they continue to follow the EU approach, or will they move towards their own system, or towards the American approach?

I do not know. What is your view?

Katia Merten-Lentz, Food Law Science & Partners:

I have my perception and I have my experience. All in all, I would say that since Brexit, despite several announcements which to me look like wishful thinking, they said: we will, I mean, move away from Europe. We will be, I mean, a sort of paradise for the food business.

Everything will be more flexible, more agile, more open to innovation and things like that. For me, that is just wishful thinking. So where do we stand today?

They cannot tell their citizens that they are moving away entirely from the European food safety standards, which we keep talking about and which are good. Okay. Because that would risk weakening the trust of their citizens in the UK system.

UK citizens are satisfied and are used to having this protection. So it is difficult to convince them that things will change. We are talking about safety.

So that is the first reason.

Alexander Platteeuw, A+ Quality:

Okay.

Katia Merten-Lentz, Food Law Science & Partners:

Second reason: the UK cannot digest, I mean, and ‘anglicise’ – I have just made up the word, the verb – but I mean create from scratch a new system, its own new UK system. Based on what? And they have no time, not enough resources, nothing.

Okay: no time, no money, no resources. And I admit I am pushing it a bit.

But the third reason is very pragmatic. It is basically that if they drastically change their framework and their philosophy of safety, it means the end of import and export with the EU. Because we would say: we want to protect our own safety.

You no longer follow our rules. That is fine. You are then like Chinese products.

So it would really mean the end of fluid and smooth trade between the UK and the EU. And despite their proximity to the US, the UK and Europe are close. The trade is quite important.

So I think we will keep, they will keep following our line.

Alexander Platteeuw, A+ Quality:

That makes sense. That is my opinion too.

Katia Merten-Lentz, Food Law Science & Partners:

That makes sense.

Do judges understand these cases?

Alexander Platteeuw, A+ Quality:

Yeah, yeah, yeah. Exactly. Now, food safety legislation is a very specific subject.

As you mentioned half an hour ago, do judges in court always fully understand the nature of a case?

Katia Merten-Lentz, Food Law Science & Partners:

Difficult to say. It is always a case-by-case interpretation. But I would say yes, not too badly.

Alexander Platteeuw, A+ Quality:

Have you seen it evolve over time?

Katia Merten-Lentz, Food Law Science & Partners:

Yes. And, how can I say, for the judges the legal basis and the reasoning, the rationale, is really straightforward. As I mentioned: fault, damage, causality.

And regarding all the scientific aspects, the highly specific regulatory aspects, they can appoint an expert if needed. And then it is back to the implementation of the rules. And it works pretty well.

They do their job seriously.

One piece of advice

Alexander Platteeuw, A+ Quality:

Good to hear. And if you could give one piece of legal advice to food companies, what would it be?

Katia Merten-Lentz, Food Law Science & Partners:

Seriously? It is so tempting. No, seriously.

So this is the last question.

Alexander Platteeuw, A+ Quality:

That is my last question.

Katia Merten-Lentz, Food Law Science & Partners:

So I need to say something really striking. No, no, no. Something people will never forget.

No, seriously, I would say that zero risk is something consumers have in mind. They are convinced that they are entitled to a zero-risk food product. Okay.

So for a food business operator, as the counterpart of that obligation, of that commitment, they are supposed to have a very, very good understanding of all the food requirements. And when it comes to something new, something very innovative, or when they have doubts: please, please do not place the product on the market before asking an expert, before making sure that your understanding is correct.

In case of doubt, please do not do it. Because it will be, or it could be, so damaging once the product is placed on the market. Because I notice that before a court, or during a hearing with the FAVV or AFSCA, it is always the same reaction.

When I start defending our position with my clients, the reaction is: okay, but at the beginning, who forced you to place it on the market? Okay. You claim to be a food business operator.

So you are supposed to know everything. You want to place something on the market, so you know the first requirement, the very first requirement of the general food law regulation: only one hundred per cent safe food may be placed on the market.

So if you cannot guarantee this zero risk, you do not place it on the market. And that is it. And then we would not be here discussing and trying to challenge their decision.

And so I never forget this approach.

Alexander Platteeuw, A+ Quality:

Excellent. Thank you, Katia.

Katia Merten-Lentz, Food Law Science & Partners:

Thank you, Alexander. It was very, very interesting to talk with you.

Alexander Platteeuw, A+ Quality:

Thanks for this fascinating insight into the world of law. Keep up the good work in defending our food chain operators and in keeping our world a food-safe place. After all, better food safe than sorry.

Yeah, sure, sure. Good. To our listeners: if you liked this interview, please subscribe to my channel and like this video.

Spread the word. See you in the next episode of Better Food Safe Than Sorry. I am Alexander Platteeuw from A+ Quality, and I am here to help you with all of your food safety questions.