Noon International: Food Trading Import Export

The FDA (Food and Drug Administration) took the unusual steps of detaining certain food products from China without physical examination. Taking action against a country is not the norm, generally it is confined to a specific factory or region. In this case, due to the ubiquitous use of melamine in milk they have elected to detain all food products from China containing milk.

In order to have the product come into the country, each shipment will have to be inspected by an outside lab (third party) to prove that it is free of melamine, or the melamine analog. This testing will be an added cost of up to $1000 per shipment.

The FDA has given the written criteria for other methods of clearance by individual factories as outlined in their Alert (click here for FDA Import Alert).

My question is how will China retaliate???

http://www.latimes.com/business/la-fi-china14-2008nov14,0,1796913.story
http://www.timesonline.co.uk/tol/news/world/asia/article5152668.ece

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A bill is in congress to amend the Food, Drug, and Cosmetic Act with respect to safety for food and drugs imported into the United States (H.R. 3610 introduced by John D. Dingell D - Mich.).

Of key interest to U.S. importers of frozen vegetables are:

If passed it would go into effect not later than 2 years from enactment of this section.
Persons importing would voluntarily agree to abide by the new standards.
 
Guidelines:

  Develop guidelines for food safety programs
  Documentation of processing (in essence mirror of a HACCP program).
  Certification of facilities
  User fees for imported product
  Restrict FDA regulated products to only enter ports with FDA labs

These are a few of the main points of the proposed bill.  (See The Library Of Congress THOMAS for the bill introduced in September 2007 and search for - hr 3610)

Developing guidelines for food safety should be easy because it would most likely replicate a HACCP program.  Certification of facilities will be a cumbersome task.  Who will do it?  Will it be outsourced?  How long would this take?  Just looking at China their would be over 1.5 million facilities for food and drug.  User fees are just another form of taxation on importers and will be viewed as a barrier to free trade.  Restricting the ports will be another difficult task, of the 300 ports only 13 have FDA labs which only 4 of those are equipped to process food.  This too will be considered a barrier to trade.  How much will this cost you and I the consumer?

Is this a step in the right direction?  Yes and no.  Food safety is of critical importance for us and all people of the world.  If the importers are working with facilities that have programs in place and have 3rd party audits performed, then is it necessary to pass legislation?  We have always stated, that as importers you must know your supplier. 

Will the same restrictions apply to domestic facilities?

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As an importer of frozen vegetables it is our responsibility to help the exporting country with the regulatory laws and in particular the pesticide tolerances for vegetables.  Pesticides is the number one problem for frozen vegetable imports.  As a general rule pathogens and bacteria are not of concern because the vegetables are blanched for several seconds killing bacteria.  However the pesticides are another issue all together. 

The EPA (Environmental Protection Agency) is responsible for testing and determining the tolerance levels for pesticides.  In 1996 congress passed  the FQPA (Food Quality and Protection Act) which changed the guidelines for developing tolerances for pesticides.  Now they not only look at the pesticide used on the agriculture products in isolation but they also consider the pesticide that may be in the drinking water supply and residential usage of pesticide.  Thus they are looking at the total cumulative effect of the pesticide based on their “Risk Cup”.  The risk cup is equal to the full amount of pesticide that a person could receive every day for 70 years without significant health risk reduced by some factor to make it child safe. 

All this is great and makes me happy that they are looking at the whole picture (or more of  the picture) to evaluate risk. This is definitely a step in the right direction.

What I am confused about is that it is based on science and if it is based on science why do some countries have different levels of tolerance or maximum residue limits (MRL).  We need to work on the MRL’s on a global basis so that we all win regardless of country that we may live in.

What is more frustrating for me as an importer is the inability to give information to our suppliers abroad.  How can we tell them that the product must meet EPA (FDA) guidelines for pesticides if we can’t find the information ourselves?  I have spent several hours looking and trying to find the data but without success.  If we are going to live in an international society we have to be open and transparent with such basic information.  Perhaps the EPA and/or FDA will come to the 21st century and post this information on their websites.  Let’s make our world better by working together to provide the safest food possible.

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I have just received an email suggesting that we avoid all processed food from China and then it goes on to show some pictures that supposedly illustrate how dead chickens are collected and then processed to a completed roasted chicken, all done in very unhygienic conditions. Yes it is true that locally some of these things may happen particularly in the hinterland. However being in the frozen food business and buying from China I can state that all facilities that we import from would meet USA standards. They are all inspected by the Chinese government as well as 3rd party audits by credible companies such as AIB.

To suggest that we ban all food from China is ludicrous in my mind.  If the importers are doing their due diligence and know the factories they are buying from then food safety and quality are not an issue. 

I would suggest to those so inclined to close our doors to China food to look at the FDA recalls and see how many are from China and how many from our own USA food processors.  Why is it that we don’t ban all USA processed food as well??

Please check the following sites:  http://www.fda.gov/opacom/7alerts.html, and http://www.fda.gov/oc/po/firmrecalls/archive.html

How safe is our own food supply?  Could we not say the same of our own food that is not fit to eat?

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How safe is our imported frozen vegetables from China, Thailand, Viet Nam, India etc.?

Frozen vegetables are probably the safest food we can eat from a Food Safety point of view.  When we deal with a China supplier we ensure that they have HACCP in place and have been certified by their government authority.  In addition many of the suppliers have ISO9001:2000 as well as the HACCP.  Many of our customers also require that the factory have a 3rd party audit such as BRC, AIB, SGS, SAFE or one of the other auditing agencies.  In addition each shipment is accompanied by a Certificate Of Analysis (COA), microbiological testing for Standard Plate Count, E. Coli, Coliform just to name a few. 

The same is true if we are exporting food to Japan, China, Australia.  Our frozen vegetables shipments are all accompanied with the COA.

The problem may arise when a price buyer imports or exports product from a marginal factory, with out doing due diligence, and then their is the potential for problems.  When this happens it makes the country or industry look bad as we are now witnessing from the “Made in China” syndrome. 

In the end all food has some risk factor and we all should share in the responsibility to educate food safety.  In frozen vegetables with the care taken to blanch the vegetables, which kill the bacteria, we have minimal risk compared to other segments of the food chain.

The key of course is to know you supplier, regardless of country, and ensure that they are following the proper procedures to provide as close as possible to a risk free vegetable to the consumer. 

Technorati Tags: Noon International, food safety, vegetables, import, export, China

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Where is the Frozen Food Industry headed? 

I have just read a great book “The Dip” by Seth Godin which is about being remarkable and teaching you when to quit.  In the book he talks about three potential outcomes, The Dip were real success comes from, Cul-De-Sac - working towards a dead end (nothing changes), and the Cliff were the whole business falls apart.  I am sure Seth Godin doesn’t need another plug but get the book, it’s worth the read.

Why do I mention the book?  Because I had a dream that we in the frozen food industry were headed for the Cliff.  Let me explain using the 3 outcomes:

Is the Dip a possible outcome?  Are we at the point where we are about to throw in the towel before the market takes off?  There are many food products from around the world that we in the frozen food industry could introduce to the consumer.  How many people have even heard of a mangosteen, the Queen of Fruits?  Many of these exotics could be introduce but it is hard and takes time.  Corporate America wants profits today they don’t want to count on maybe.

Is the Cul-De-Sac where we are today?  The frozen food industry has been stagnant and by that I mean the shelf space hasn’t grown in years.  All we do is take old products and wrap them up to try and reinvent ourselves.  We take a single vegetable and mix with multiple vegetables and come up with a new item. Or we add protein or a new sauce and sadly try to duplicate  ” Asian Fusion”. But the unfortunate part is that we are just playing musical chairs because the freezer shelf space is not growing.

Are we headed for the Cliff?  In the food chain the frozen food industry is the most enviornmentally unfriendly in terms of energy and pollutants.  It takes tons of energy to freeze, it takes more to hold product in cold storage, and more for transportation especially for the import and export business where containers are moved thousands of miles from continent to continent.  Everyday we pick up the paper and read about eating local.  We read books, like Jane Goodall’s “Harvest For Hope: A Guide To Mindful Eating“, which talks about the food industry and how it is force feeding the consumer with unhealthy products and  that it is time for change.

All this makes me wonder (and wake up in the middle of the night with nightmares), are we just at the tipping point of eating local ly supplied foods and  is the frozen food industry  about to walk off the cliff? or are we at the dip where innovation is about to launch us into a new era? or are we on the train to nowhere, cul-de-sac next stop please?

My hope of course is we are just in the dip and I continue to dream about all the healthy and wonderful aspects of frozen veggies and fruits, but is it enough?

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I want to thank PaiPai in our Noon International office for translating this speech concerning the new laws, violations and punishments concerning China Food Safety.
Mr. Cao’s Speech at China’s Food Quality and Safety Improvement Action TV/Tele Communication Conference.
August 23, 2007

(A Brief Translation of his Speech)

In addition of “ China’s Food Quality and Safety” published by Information Office of the State Council, I would like to add the following suggestions.

A.  CFQS is the must followed principle Our country established law and regulation in different areas:
Product quality and safety
Food sanitary law
Agricultural products/production safety law
Products Quality and standard law
Medicine management law
Importer / Exporter and their goods inspection law

There are total 11 laws.

There are also 22 other regulations for production permits, cosmetic, medical equipment management, industry production and products, etc.

These laws and regulations are the protections for people’s safety and health. They also provided the clearly defined responsibilities of  producers, enterprises, corporations and any individual who engages in these business. They provided the guide lines to punish the violated parties.

I think the problems we are facing right now are caused by these laws were not carried out correctly. The violators were not punished properly. Some of the management and inspection control department are not working properly.

1.To clarify, emphases and supplementing the current regulations and laws
2.To clarify the legal responsibilities of  producers, enterprises and management with quality control personals. To increase the punishment to the violators of these laws and regulations.
3.To give power to the people who are in charge of inspection, quality control and law/regulation reinforce department to check, stop any violations.
4.To prevent the problems to happen. Strictly to check the whole production process, distribution process. To start from raw materials, farm fields, food addictives, animal feed, etc.

CFQS main ideas:

1. Punishment in 6 areas:
a). Everyone should follow the law and regulations. The punishment for violators are:
For the producers and traders who are the violators
To confiscate the products which violated the quality and safety law and regulations.
To confiscate the income and profits which are from selling of the unlawful products
To confiscate the equipment, tools, raw materials
If there are any serious consequences caused by the producer or their products, they will be fined severely and revoke their business licenses

b). The same punishment are for anyone who uses unsafe and poor quality of  raw materials, addictives, animal feed.

c). To establish purchasing inspection procedures. To record, to check the suppliers’ qualifications and products quality certifications. The sales department should have products records to record products names, specifications, quantities, suppliers names, purchasing time, etc. to provide  products testing reports. If the products have no testing report, we should forbid to sell this product. Any violations will have the same punishments as we listed above.

d). To establish recall system to reinforce the quality and safety control.
To recall any product which violate the quality and safety regulations and law to ensure to protect people’s lives and health.
To publicly announce the harmful products, to volunteer recall the products immediately. Anyone who violates the laws and regulations will have  the same punishment.

e). To establish the record system to record any violations. To record every department:  Agriculture department, Senitary department, pharmaceutical, etc

f). To bring violators to the justice. To take them to the court.

2.To give local government and supervisory committee more power to check, stop and punish any violations.

a). if the local government and supervisory committee workers who does not carry on their duty and allowed the violations to happen without punishment, the person will be punished, or fired.

b). If the government official and supervisory committee members do not do their job and let the violators get away, they will be punished as well.

c) To strengthening the communication between different government departments to prevent the problems to fall through the cracks and anyone uses that as the excuses to avoid taking their responsibilities.

d). Each named government agencies have the power to enter the production area to check, inspect, investigate, confiscate, close the violated production facilities, equipment, invoices, and accounting records.

3.Strengthening management and supervision on import/export business

a)Testing records. To record the import/export history ( 2 years at least)

b)To sort out import products in different category and keep the records

c)To put the violators on the black lists.

d)To bring the violators to the law. Anyone who falsifies documents will be bring to justice, to be fined, to revoke business licenses and keep on the records.

e)In order to protect “ Made in China” reputation, we will reinforce the following 4 areas:

The responsibility of suppliers and exporters for the safety of the products
The responsibility of inspectors for export goods
To establish records for all suppliers and exporters. The customs and quality control agencies keep records on every import/export products and announce the violators records to the public.
The customs and boarder control agencies have the power to confiscate anything violated Chinese Laws and Regulations.

How to carry on CFQS:
1. To study it
2. To use media to educate the mass
3. To carry on CFQS from different levels of government agencies to protect people’s health and safety.

 Translated by PaiPai Stoltenberg

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The China CIQ saga continues and we still have yet to come to the official start date of September 1.  I am hearing that the CIQ is already implementing some restrictions on exports as well as imports and some US companies products being blacklisted or banned.  They currently have punished some factories for exporting product that was rejected by the importing  country for pesticide, or microbiology, or other rejections such as foreign material.  Initially, after the first violation they will not allow the factory to export for 3 weeks (or other specified time) and ask for corrective action and it is not clear what will happen if corrective action  can not  be accomplished in the time frame given by the CIQ.  In addition to the factory, they will also restrict all the growing fields vegetables (which had CIQ registration) from being exported.  It is not clear as to how long  the fields would be restricted and what they would have to do to be re-registered by the CIQ.

 Another side of the problem is that because of the pressure from all the foreign countries on quality issues the China government is setting up new regulations daily which is driving all the CIQ staff crazy.  Factories maybe shut down for months if the product is rejected by any foreign country, but it might be restricted from exporting only to that country while still being able to export to other countries.  Everything is still unclear and it may change from region to region as the CIQ implement their own rules.  Some of the CIQ’s staff are trying to make it very difficult for exporting factories because if they have a rejection it not only hurts the factory but also the CIQ staff will be punished with no chance of promotion.  Hence the CIQ would prefer not to have any exports to eliminate their own risk of being punished.

With each province and local CIQ implementing their own regulations, it reminds me very much  of a book I just read, “Will The Boat Sink The Water? The Life Of China’s Peasants” by Chen Guidi and Wu Chuntao.  The book tells several stories about the peasants problmes with the local government and how the local and provincial government dictated their own tax laws that were contrary to the central China government.  It relates sevearl stories and very interesting to read and get a better handle of the  inner workings.  The book was originally published in China but later banned.   Is their a correlation?

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What’s happening with China Food Safety? 

I cannot comment on all aspects of China Food Safety but I do have a little knowledge of what is happening in the frozen fruit and vegetable business.  Being an importer for many years of product I have witnessed many changes in the production facilities in China.  Today with the help of the Japanese, Europeans, US and others the Chinese factories have learned and raised their standards to the highest international level.

 But more importantly what is happening today in light of the petfood recall, toothpaste recall etc?  Today the suppliers that we as a company use most have at minimum an HACCP program in place, certified by the China authoritites.  We do prefer that the suppliers have a third party audit such as AIB, BRC or others along with the full report and recommendations.  The suppliers that have taken the 3rd party audit have all passed, meaning they have controls in place to monitor the products being produced.  They have incorporated traceback systems to trace product,  they all have HACCP in place to monitor for foreign material, metal detection and microbiological counts are maintained.  Most all of the facilities now have their own equipment for testing for pesticides in house.   Others will send their samples to private or public labs for pesticide testing.  

 All of the above should give some reassurance of the quality of the frozen fruits and vegetables  coming out of China.

 Now after the recalls the CIQ (Inspection and  Quarantine of China) is inspecting all product being shipped to Japan and USA.  This newly enforced  checking is  causing great delays for shipments and how this will work in the long run remains to be seen.  The key is that the China government is taking action and trying to restore confidence to the international community. 

 Lastly, the most important thing is to know whom you are buying from.  I have been to and seen many factories that  we as company would not do business with but the ones we do work with have the quality standards in place and are continually working  to improve there factories.

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Edamame is one of the great snack foods that is taking the US by storm (not only because it is great tasting but also because of its health benefits).

If you haven’t tried them I suggest you do, they are awesome. I personally like to eat them while still in the pod, and still in a semi frozen state. Of course they are great thawed or heated as well. I just take the pod and put it into my mouth and suck out the beans. Yummy and even yummier if slightly salted. Of course you can eat them by just pushing the beans out of the pod and eating the beans but not that much fun. I guess it’s a little like eating peanuts out of the shell, its addicting. Most stores now carry them in there frozen vegetable section or in the fresh produce section (a limited supply).Actually Edamame has been around for years. The Japanese have made it popular here in the states by giving it away as a free Hors d’oeuvre a few years back. From there it has just blossomed. It was the Japanese restaurants that educated the American public and gave us awareness.

Personally I have been eating Edamame for more than 20 years. Because of being in the frozen vegetable business I have traveled extensively to Taiwan and China (the main producers of Edamame) and was exposed to it years before it got to the US. Consequently, I have learned about the different varieties being grown particularly for the Japanese market. In Japan the most popular type is Edamame, with bean in the pod or shell on. The bean itself, called Mukimame, is a by-product of the Edamame. For Japan what is key is the appearance of the Edamame because as they say they Eat With Their Eyes First. It must be a nice green color, no blemishes or defects, and it must have a maximum of 170 pieces per 500 grams of product. If it has more than 170g per 500g then it will catch a lesser price.

At present there are three main varieties grown in China, #75, #2808 (a new variety replacing an older variety #292) and Shanghai Green a local Chinese variety. Of the three the best quality is #75, followed by #2808 and then the China local variety Shanghai green, which is probably the most common here in the States because we just don’t have the sophistication to know the different varieties.

In addition to the variety they also have different processing methods. First is regular blanch, then long blanch and then a salted long blanch. The regular blanch is the cheapest method of processing and is probably the predominate here in the States. The regular blanch would need to have some further cooking by the consumer. The long blanch is a longer cooking time which fully cooks the Edamame and is ready to eat as is (of course you can reheat if you like them warm). And the salted long blanch is just that, it is blanched in slightly salted water and ready to eat.

In addition to the variety they also have different processing methods. First is regular blanch, then long blanch and then a salted long blanch. The regular blanch is the cheapest method of processing and is probably the predominate here in the States. The regular blanch would need to have some further cooking by the consumer. The long blanch is a longer cooking time which fully cooks the Edamame and is ready to eat as is (of course you can reheat if you like them warm). And the salted long blanch is just that, it is blanched in slightly salted water and ready to eat.

The Mukimame being the by product is produced from the Edamame that is sorted out because it had defects or blemishes on the skin or was of poor color or only one pod. It has to go thru a further processing which should make it more expensive but being that it is the by-product it ends up being cheaper. However, in your store you will see them probably selling at a higher price then Edamame.

Maybe in the future if Mukimame becomes more popular and becomes the big seller this relationship at the processing level will change. Not only is it a great snack but it is healthy which makes it all that much better. Check out these sites for some of the health benefits www.fwhc.org/health/soy.htm and http://findarticles.com/p/articles/mi_m0854/is_7_27/ai_n17207358.

Edamame is one of the great snack foods that is taking the US by storm (not only because it is great tasting but also because of its health benefits).

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