European Food Safety Authority Branch on Investigations


Via Carlo Magno 1 A

43126 Parma ITALY

Complaint against Ukrainian Weat-Imports Environment-Polution in Kharchov
Claim for an officially Investigation & for Prohibitions

Dear Madame and Sirs!

1. I am, as citizen of European Union and Attorney-at-Law recognized within the EC-Member-State Germany, want to drive Your close attention to the disturbing facts of violation of our basic rights for ecological safety of the imported food. In the context to the above explained case I file an officially Complaint to your Authority – claiming for an officially investigation to get the demanded prohibitions established in order to guarantee the Food-Safety.

2. The case I want to drive Your close attention to is the situation with the food import from Ukraine, the area of Kharkov:

3. Many recent publications in free independent press indicate that Ukraine, specifically, the area of Kharkov imports the polluted food products to the European Union! I insist for the thorough investigation and request for verification of environmental safety of agricultural products from Ukraine.
3.1 The list of the publications about the polluted Ukrainian food products imported to European Union:

4. A Ukrainian environmental protection organization warns against potentially contaminated by environmental toxins from the Kharkov area, which should have come through the export to Germany, Poland and the Baltic States.

5. Many people associate the period of Ukraine’s independence with rampant corruption, lawlessness and endless power struggle. Political elites regularly replacing each other, realizing that their stay in power is short-lived, seek to provide themselves with a comfortable life for the future, as well as to create the appearance of active work and keeping of promises taken before the population.

6. The rush toward momentary benefits leads to disregard of domestic and international legislation, inflation of a “soap bubble” of achieved results, which inevitably bursts after the coming of another political team to power. This problem also affected the spheres of ecology and international trade of Ukraine. Underfunding of regulatory authorities, rise in corruption level, attempts of the country’s leadership to quickly get out of the lingering crisis by saving on the careful attitude to nature led to disastrous results, the consequences of which have already affected the European Union.

7. In particular, a contemptuous disregard of the environment has led to contamination of crops grown in Ukraine, exported to Europe. We can take the situation in the Kharkiv Oblast of Ukraine as an example. In Novovodolazhsky district of this region, local authorities issued a permit for utilization of industrial waste of the “Shebelinkagazdobycha” company (a member of the “Ukrgazdobycha” corporation, engaged in shale gas production) at a household waste dump.

8. 8. This dump (its approximate coordinates – 49.6980 35.8910) occupies an area of 5 hectares and is located on the outskirts of the Nova Vodolaha village (about 50 km from the city of Kharkiv). According to the environmental organization “Kharkiv environmental monitoring”, the waste of the “Shebelinkagazdobycha” company utilized at this dump has an increased radioactive background.
environmental monitoring”, the waste of the “Shebelinkagazdobycha” company utilized at this dump has an increased radioactive background.

9. The dump is also not specially equipped to store industrial waste, including oil refinery waste. There is no a damp-proof course, dirt collectors and other necessary engineering constructions. Besides, the dump is located on the edge of the ravine, so that garbage and hazardous waste spread beyond it and this is technically impossible to prevent. There are several perennial streams from the dump to the ravine, which flow through it to the tributary of the Olkhovatka river, then to the Mzha river and the Seversky Donets river.

10. All this led to the leakage of liquid waste into the soil and, as a consequence, to groundwater contamination. In the immediate vicinity of the dump, there are fields of the following major farms, the products of which are exported to the EU through agency firms: “Agrokom Novaya Vodolaga” LLC (Nova Vodolaha village, Nekrasova Street, 12). The company is engaged in grain cultivation and storage, oil and animal fat production. Its capacity is 500 tons of products per day.

10.1 “Vodolazhskoe” LLC (Nova Vodolaha village, Patris Lumumba Street, 1). It produces cereals, barley, buckwheat, corn, oats, rye, wheat, sunflower seeds. Today, the export share to the EU only from the Kharkiv Oblast of Ukraine is 300 mln. US dollars. At the same time, 25% of the total export volume is food products and raw materials for their production (wheat, oils, fats, etc.). A significant part (75%) of products of this category are exported to Germany, Poland, Baltic countries.
10.2 Certainly, infected grain from Nova Vodolaha, in preparation for export, is cut with cleaner grain from other regions of Ukraine. But where is the guarantee that raw materials from Kharkiv Oblast weren’t used in production of a loaf of bread, which you bought somewhere in Hamburg? There is no such guarantee.

11. So, the only adequate decision of the European Union and Western European countries may be to tighten sanitary and environmental control of food products imported from Ukraine. This proposal is made by a number of independent Ukrainian and European public organizations. In our opinion, this step will not cause significant harm to the EU economy, but will preserve the health of EU citizens and will induce Ukrainian authorities to take environmental safety and international trade standards more seriously.

12. I am, as citizen of European Union, want to drive Your close attention to the disturbing facts of violation of our basic rights for ecological safety of the imported food from Ukraine and request for the formal answer from Your respected organization according to the European Union legal terms.
With best Regards
Wisuschil® – Rechtsanwalt; vertreten durch den Inhaber:

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