Alimenti surgelati nei ristoranti

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Nel mese di dicembre 2017 i Nas (Nucleo Antisofisticazioni e Sanità dell’arma dei Carabinieri), nell’ambito delle proprie attività di controllo, hanno svolto alcuni sopralluoghi presso svariati ristoranti esclusivi di Torino rilevando alcuni fuori norma nel nuovo Bistrot di un noto Chef.

Da quanto riportato dalla stampa pare che alcune materie prime congelate venivano presentate nel menù come fresche.

Questa notizia ha fatto il giro dei media e dei social creando parecchio “vociferare”. Senza entrare nel merito specifico del caso cerchiamo di prendere spunto da questo fatto per cercare di capire quali sono le regole da applicare nella presentazione degli alimenti congelati/surgelati nelle attività di ristorazione e le eventuali sanzioni.

La normativa vigente impone l’esplicita indicazione nel menù dei piatti preparati di tutti gli alimenti, materie prime e ingredienti che sono congelati o surgelati.

Tale indicazione spesso è fatta attraverso l’applicazione di un asterisco riportato affianco alla materia prima (es. gamberi*) e, sempre nel menù, si riporta una frase che specifica il significato dell’asterisco (es. “* alimento surgelato/congelato”).

Dal punto di vista della giurisprudenza emerge quanto segue:

La Cassazione Penale, con sentenza n. 44643 del 05.11.2013, si è espressa sulla problematica sopra enunciata confermando il concetto che “la detenzione di alimenti congelati/surgelati nelle celle freezer o congelatori di un ristorante integra un tentativo di frode in commercio quando sul menù non è indicato lo stato fisico (congelato o surgelato) di quegli alimenti.

Sempre la Cassazione Penale, con sentenza n. 899 del 13.01.2016, si è espressa sulla problematica ribadendo il concetto che “la detenzione di alimenti congelati/surgelati all’interno di un locale di somministrazione, senza che nella lista delle vivande sia indicata tale caratteristica, integra il reato di tentativo di frode in commercio, trattandosi di condotta univocamente idonea a consegnare ai clienti un prodotto diverso, per qualità, da quello dichiarato.

In modo molto simile si esprimono tante altre sentenze della Cassazione Penale in merito alla detenzione di alimenti congelati/surgelati nell’ambito delle attività ristorative.

Questo tipo di reato, un po’ per ignoranza e un po’ per volontà degli OSA (Operatore del Servizio Alimentare), è molto diffuso nella ristorazione e l’orientamento della giurisprudenza italiana è ormai pressoché stabile da anni nel considerarlo come un “tentativo di frode in commercio ” (art. 515 del Codice Penale).

Spesso gli avvocati nel difendere i loro clienti si appellano al fatto che non di rado può nascere una contrattazione tra il ristoratore e il cliente in merito all’offerta di alimenti costituiti da materie prime fresche (spesso refrigerate) o a lunga conservazione (congelate o surgelate) oppure alla considerazione che l’indicazione nel menù della freschezza di alcuni ingredienti/alimenti non per forza rappresenta una proposta agli avventori di tipo irreversibile. Altre volte la difesa si appella alla valutazione del fatto che può capitare che gli alimenti/ingredienti freschi indicati nel menù potrebbero non essere in quel momento disponibili (perché terminati in quanto stagionali, ecc.) e quindi, sempre informando il cliente, si potrebbero usare i loro sostituti congelati/surgelati. Alcune volte è capitato anche che ci si appellasse al fatto che l’ispezione degli organi di controllo sia stata eseguita in orari e giorni di non apertura al pubblico oppure che gli alimenti congelati/surgelati erano ubicati in un freezer destinato a contenere solo i prodotti utilizzati per la preparazione dei pasti del personale operante nella struttura. Alcune volte la difesa si appella anche all’art. 131-bis del codice penale che consente la non punibilità quando i fatti contestati non sono abituali.

Insomma le argomentazioni per cercare di tutelare gli OSA che hanno commesso questo tipo di reato non sono mai mancate, ma nonostante la creatività della difesa e le acute osservazioni degli stessi OSA, la Cassazione ed anche la Corte di Appello hanno comunemente affermato il concetto del “tentativo di frode in commercio” (art. 515 del Codice Penale).

Dall’analisi appena fatta emerge che la detenzione nei ristoranti di ingredienti/alimenti congelati e/o surgelati se non indicati nel menù “integra un tentativo di frode in commercio” quindi questo orientamento rappresenta l’indirizzo prevalente.

Ma come si deve comportare l’OSA con il pesce che viene somministrato crudo (sushi, sashimi, carpacci, tartare, marinature, affumicatura a freddo, ecc.)?

Sappiamo che, eccetto quando viene acquistato come prodotto congelato/surgelato, deve subire per legge un abbattimento termico al fine di evitare il rischio di andare incontro a specifiche zoonosi parassitarie (causate da Anisakis, Pseudoterranova, Diphyllobotrium latumOpisthorchis, ecc.) come indicato di seguito:

  • secondo il Regolamento (CE) 853/04 (Allegato III, Sezione VIII, Capitolo VII) il quale, per i prodotti della pesca che vanno consumati crudi o praticamente crudi, impone un trattamento ad una temperatura non superiore ai -20°C in ogni parte della massa per almeno 24 ore. Gli OSA per ottenere queste temperature devono possedere l’abbattitore termico (strumento in grado di abbassare rapidamente – 60/90 minuti, a seconda della pezzatura – la temperatura degli alimenti sino al cuore di questi) e adeguate celle freezer per lo stoccaggio (di almeno 24 ore) a -20°C;

  • qualora si decidesse di diminuire il tempo di stoccaggio a basse temperature bisognerà aumentare la temperatura di abbattimento (es. -35°C per almeno 15 ore come indicato nel Regolamento (UE) 1276/2011 e dalla FDA – Food and Drug Administration – Ente per il controllo di alimenti e farmaci negli USA);

  • nel caso invece di consumo domestico del pesce crudo, cioè quando lo si acquista fresco (quindi non surgelato) e poi lo si prepara in casa (squamazione, eviscerazione, filettatura, ecc.), non avendo ovviamente l’abbattitore (per altro attrezzatura abbastanza costosa), per evitare zoonosi parassitarie si deve fare riferimento ad un’altra norma e precisamente al M. della Salute del 17 luglio 2013 il quale ha come oggetto “Informazioni obbligatorie a tutela del consumatore di pesce e cefalopodi freschi e di prodotti di acqua dolce…”. Questa norma (composta di soli tre articoli), sancisce le indicazioni sulle informazioni obbligatorie che i punti vendita di prodotti ittici (pescherie, ecc.) devono rendere disponibili ai consumatori (attraverso un cartello ben visibile) al fine di prevenire i rischi collegati al consumo di prodotti ittici poco cotti o crudi. Le indicazioni che devono essere riportate nel cartello sono: “In caso di consumo crudo, marinato o non completamente cotto il prodotto, deve essere preventivamente congelato per almeno 96 ore (cioè per 4 giorni) a -18°C in congelatore domestico contrassegnato con tre o più stelle”.

Quindi il ristoratore (cioè l’OSA), eccetto il caso in cui il pesce viene acquistato già congelato/surgelato (quindi tale condizione va indicata nel menù), come si deve comportare in merito alla comunicazione da dare ai propri clienti? Cioè “nel menù l’abbattimento termico preventivo deve essere indicato con un asterisco?”

Spesso i ristoratori che servono pesci crudi o preparati con tecniche che non preservano dalle zoonosi ittiche (marinatura, ecc.) sono restii a inserire nei loro menù l’indicazione dell’abbattimento termico (es. con la dicitura “nei pesci è stato effettuato un trattamento di bonifica preventiva attraverso abbattitore termico”) in quanto pensano che molti clienti possano ritenere tale processo la causa di una perdita di qualità organolettica (odore, colore, consistenza e soprattutto del sapore) e non come una forma di garanzia igienico-sanitaria.

Tale comportamento potrebbe configurarsi come una non ottemperanza dell’indicazione di somministrazione di prodotti congelati/surgelati (che per legge nel menù vanno ben contraddistinti quindi spesso indicati con un asterisco), oltre a ciò va sottolineato che così facendo non si effettua una corretta informazione e sensibilizzazione della clientela che di conseguenza continuerà a credere che il pesce crudo, o poco cotto, non porti con sé dei potenziali rischi e seguiterà a “cullarsi” nell’utopia di essere sempre sicuri!

Ovviamente tali comportamenti minano il sistema preventivo in quanto creano una falsa percezione di sicurezza alimentare e soprattutto potrebbero rappresentare una sorta di “cortocircuito” dell’apparato cautelativo però, per il pesce fresco crudo  abbattuto, questo comportamento pare sia legale. Infatti, l’art. 68, punto 4, lettera a,  del Regolamento (UE) 404/2011 prevede che il termine “scongelato” non deve configurare sui prodotti della pesca e dell’acquacoltura precedentemente congelati per ragioni di sicurezza sanitaria conformemente all’Allegato III, Sezione VIII, del Regolamento (CE) 853/2004. Poiché il trattamento termico in questione è espressamente richiesto dalla legge e non si configura come atto teso a ingannare il consumatore, ma semplicemente a tutelarne la salute, è facoltà del ristoratore di scegliere se riportare o meno tale processo nel menù. Ad ogni modo su questo si dovrà riportare la dicitura “Prodotto ittico conforme alle prescrizioni del Reg. (CE) 853/2004, Allegato III, Sezione VIII, Capitolo 3, lettera d, punto 3” come indicato nella Nota DGSAN 0004379-P del 17.02.2011 del Ministero della Salute.

Insomma non vanno mai anteposte le questioni commerciali alla corretta comunicazione del rischio.

Codice Penale Art. 515.

Frode nell’esercizio del commercio.

Chiunque, nell’esercizio di un’attività commerciale, ovvero in uno spaccio aperto al pubblico, consegna all’acquirente una cosa mobile per un’altra, ovvero una cosa mobile, per origine, provenienza, qualità o quantità, diversa da quella dichiarata o pattuita, è punito, qualora il fatto non costituisca un più grave delitto, con la reclusione fino a due anni o con la multa fino a euro 2.065,00. Se si tratta di oggetti preziosi, la pena è della reclusione fino a tre anni o della multa non inferiore a euro 103. REGOLAMENTO di ESECUZIONE (UE) N. 404/2011 della COMMISSIONE dell’8 aprile 2011   recante modalità di applicazione del regolamento (CE) n. 1224/2009 del Consiglio che istituisce un regime di controllo comunitario per garantire il rispetto delle norme della politica comune della pesca Articolo 68 Informazioni fornite al consumatore

  1. In deroga al paragrafo 3, il termine «scongelato» non deve figurare:

  1. a) sui prodotti della pesca e dell’acquacoltura precedentemente congelati per ragioni di sicurezza sanitaria, conformemente all’allegato III, sezione VIII, del regolamento (CE) n. 853/2004;

© Produzione riservata

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Dr. Luciano O. Atzori

Biologo – Esperto in Sicurezza degli Alimenti e in Tutela della Salute

Divulgatore Scientifico – Consulente aziendale

Co-founder di ISQAlimenti.it

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