Entry-Exit Alerts for Chinese Market

Today I introduce you with great pleasure a guest writer which hopefully will be a fixed presence on foodlawlatest.com: Quinn Hulk, Food and Drug Administration of Beijing – Food Law Advisor.

With his solid background in food safety and his role in the competent authority, he will be in future Foodlawlatest country contributor for China and will offer us incredibly useful oversights on the Chinese food safety issues. The following analysis of the recent Chinese import alerts speaks for him.

You can contact Quinn Hulk directly via e-mail at hulkquinn@163.com.

China has become the largest food and farm produce importer all over the world. With the total value of imported food and farm produce rising to 121, 48 billion dollar in 2014 from 37, 57 billion dollar in 2001, it seems that Chinese consumers have more assurance in imported food. Great news for the food and farm produce traders. Risks, however, are an indispensable part of chances. Things can still be done nonetheless. Here are some alerts.

a) According to the data released by Import & Export Food Safety Bureau affiliated to General Administration of Quality Supervision, Inspection and Quarantine of PRC, the leading three among the areas from which the unqualified food come are Chinese Taiwan, European union countries and Southeast Asia.

The top ten factors for not being successfully penetrating into Chinese market are listed as below,

1) Defective labeling→Please refer to detailed provisions of Chinese national food safety standard GB7718-2011and GB28050-2011

2) Aerobic plate count→Please refer to detailed provisions of Chinese national food safety standard GB4789.2-2010

3) Enumeration of coliforms→Please refer to detailed provisions of Chinese national food safety standard GB4789.2-2010

4) Quality guarantee period→Please refer to detailed provisions of Chinese Food Safety Law

5) Wrong way in submission of relevant documents and materials→Please refer to detailed provisions of 35 provincial entry-exit inspection and quarantine bureaus of China and Import & Export Food Safety Bureau affiliated to General Administration of Quality Supervision, Inspection and Quarantine of PRC

6) Moisture→Please refer to detailed provisions of Chinese national food safety standard GB5009.3-2010

7) Lack of credentials→Please refer to detailed provisions of 35 provincial entry-exit inspection and quarantine bureaus of China and Import & Export Food Safety Bureau affiliated to General Administration of Quality Supervision, Inspection and Quarantine of PRC

8) Mould→Please refer to detailed provisions of Chinese national food safety standard GB478915-2010

9) Quality defects

10) Unauthorized admittance→Please refer to detailed provisions of 35 provincial entry-exit inspection and quarantine bureaus of China and Import & Export Food Safety Bureau affiliated to General Administration of Quality Supervision, Inspection and Quarantine of PRC.

b) The top three types of food that failed in inspections conducted by Chinese customs are biscuits, beverages and alcohol.

For the biscuits, the main reasons that led to the failure are as follows,

1) Usage of food additives that fall out the legal range of Chinese regulations on food additives, mainly GB2760-2014.

2) Aerobic plate count goes beyond of GB4789.2-2010

3) Enumeration of coliforms is not in conformity with GB4789.2-2010.

4) The labeling is not in accordance with GB7718-2011 and GB28050-2011.

For beverages, the main reason of over 230 failures is that the products are detected of over used food additives, such as azorubin which is regulated by GB28309-2012.

For alcohol especially wines and beers, many brands from France, Greece, Germany, Spain and other European countries failed in food additives such as Iron oxide red, acesulfame potassium, Vitamin C. Other reasons included labeling, inconsistencies between documents and letter of credit, and failure in providing required documents and credentials.

FVO Report – Sweden official controls over meat traceability and food frauds

The audit to Sweden was carried out from 14 to 24 April 2015. The main objective of the audit was to evaluate the operation of official controls over the traceability of meat (meat of domestic ungulates, poultry, lagomorphs and game meat), minced meat, mechanically separated meat (MSM), meat preparations, meat products (hereafter referred to as meat and products thereof), and composite products containing meat and products thereof and other ingredients.

Particular attention was paid to the traceability, labelling and identification systems of meat and products thereof, and to composite products containing meat and products thereof and traceability of quantities of each ingredient used. The official control procedures require all establishments to be controlled, at least every five years, in all areas of applicable legislation. Risk based controls are split between the different inspections/audits that take place during the five year period. In the current five year official control plan traceability is scheduled to be covered twice.

The CCA is currently implementing actions in relation to traceability following the horse meat scandal and the discovery of certain food fraud in Sweden. These actions aim to increase the awareness of FBOs and officials in charge of controls. They concern the following areas:

  • creation of a food fraud unit;
  • specific training for staff to new control methods (180 inspectors on training);
  • identification of non-registered FBOs;
  • revision of the Swedish food act to re-enforce its efficiency, particularly concerning penal sanctions;
  • joint NFA-Stockholm municipality project to improve traceability controls and avoid overlapping (to be carried out between May and September 2015).

The Swedish CCA has already drawn certain lessons from the recent meat scandals and is undertaking specific actions to increase the efficiency of the control system. Significant work remains to be done.

In all the establishments visited, the food business operators stated that a traceability system was in place. However, the evaluation of these systems revealed a less positive picture concerning traceability in general and quantitative traceability in particular. In one cold store a robust traceability system was already in place. Two establishments were making good progress towards implementing a good system but the others still had significant progress to make. Two establishments had yet to start work on implementing a traceability system.

At the start of the audit, the FVO audit team chose 14 different food (meat based) samples at retail level. The CCA was asked to carry out a quantitative traceability of these samples in co-operation with the FBOs concerned. These exercises were far from successful: out of 14 samples, the CAs and the FBOs concerned could only establish 4 complete chains of traceability supported by the documented evidence. In the other cases significant documents relating to traceability were missing.

The FVO audit team also paid attention to the traceability and the use of additives in meat preparations and meat products. In general the situation was satisfactory but certain misuses were noted in some establishments. Nitrites and phosphates are allowed in “traditional products” which, in the absence of specific national rules/guidance, has the potential to include any pork or beef meat injected with curing solution (including in the initial phase of the maturing process).

The report makes a number of recommendations to the Swedish CA with a view to addressing the deficiencies identified during this audit.