Gli operatori che acquistano da pescherecci prodotti di pesca in prima vendita sono tenuti ad effettuare la registrazione presso il portale del MIPAAF e gli ulteriori adempimenti di seguito indicati.
Stante l’entrata in vigore del D.Lgs 231/17 relativo alle informazioni sugli alimenti, con i probabili control che ne conseguiranno, si coglie l’occasione per segnalare la vigenza degli adempimenti inerenti la commercializzazione dei prodotti ittici previsti dai Regolamenti (CE) 1224/09 e 404/11 del Consiglio.
In merito, le disposizioni di maggiore interesse per le imprese rappresentate concernono:
– l’art. 59 par. 2 del Reg.(CE) 1224/09 che stabilisce: “L’acquirente di prodotti della pesca messi in prima vendita da un peschereccio è registrato presso le autorità competenti dello Stato membro in cui ha luogo la prima vendita”;
– l’art. 2 del Decreto del MIPAAF del 10 novembre 2011, finalizzato a dare attuazione alle disposizioni di cui al Titolo V del Reg. (CE) 1224/09, che include tra i soggetti destinatari di tali obblighi anche gli operatori che svolgono attività di vendita al dettaglio ivi compresi gli esercizi di ristorazione;
– l’art. 5 del Decreto citato in forza del quale la registrazione deve effettuarsi al portale (link) con le modalità descritte nell’allegato A del Decreto Direttoriale n. 155 del 28 dicembre 2011.
In sostanza, al fine di assicurare la tracciabilità, gli operatori che acquistano i prodotti della pesca messi in prima vendita – vale a dire direttamente dal peschereccio – sono tenuti ad effettuare la registrazione secondo le indicazioni prima riportate.
Preme segnalare che l’esclusione da tale obbligo, prevista dall’art. 59 par. 3 del Reg. 1224/09, non può in alcun caso riferirsi alle imprese rappresentate in quanto riguarda esclusivamente la destinazione dell’acquisto al consumo privato.
Inoltre, la circolare del MIPAAF n. 25798/2014, in attuazione della normativa europea e al fine di assicurare un adeguato sistema di tracciabilità, ribadisce ulteriori obblighi a carico degli acquirenti registrati, quali:
– la pesatura del prodotto (art. 2 co.2 circolare MIPAAF – art. 60 Reg 1224/09);
– la compilazione e la conservazione per tre anni di un registro contenente i dati previsti dall’art. 70
par. 1 Reg. (CE) 404/2011 (art. 2 co.2 circolare MIPAAF);
– la compilazione e la presentazione della nota di vendita (art. 4 co.2 circolare MIPAAF – art. 62 Reg. 1224/09).
In merito a quest’ultimo adempimento occorre precisare che la trasmissione della nota di vendita deve avvenire entro 24 ore a decorrere dal momento del completamento della prima vendita. Tuttavia, agli acquirenti registrati che, per le prime vendite di prodotti della pesca, realizzano un fatturato annuo inferiore a 200.000 euro è riservata la facoltà di compilare il modello in formato cartaceo (allegato al D.D. n. 155/2011), da presentare entro 48 ore alle Autorità Marittime competenti per luogo di sbarco.
Infine, per ragioni di completezza, si fa presente che il MIPAAF ha precisato che la violazione dell’obbligo di registrazione è punita, salvo che il fatto costituisca reato, con il pagamento della sanzione amministrativa pecuniaria da 750 euro a 4.500 euro (art. 11 comma 4 del D.Lgs n. 4/2012).
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