Food Safety Shanghai: Tips for Expats in China
When I talk about China food safety, I don't want to be overly cynical. I live here and I eat here and with the proficiency of Chinese chefs there is a lot I can forgive.
Based on the hype surrounding Chinese food safety I should either be dead, have grown an extra arm or at the very least have been hospitalized a few times.
I eat in local restaurants and purchase from street vendors (although I don't recommend this to China expats). I shop in local markets and cook using produce sourced from local farms. I'm still alive and I'm rarely ever sick (touch wood).
That said, I'm not a parent of a baby that drank melamine tainted infant formula, I've personally never eaten clenbuterol tainted pork, and to my knowledge never eaten rat, mink or fox or been the victim of the regular scandals that plague China's food industry.
I have, however an extensive background in food safety and in particular food safety in China. I currently work at a food safety consulting company in China, helping foreign companies understand the complex web of Chinese food safety regulations and ultimately gain access to China's food market.
My academic background in biochemistry, molecular nutrition and food technology and my extensive experience analyzing and reviewing Chinese food, agrochemical and chemical regulations probably makes me more keenly aware than most of the issues facing China's food supply Chain.
As a fellow expat in China, therefore, I would like to offer some of my knowledge of China's food safety system, regulations and recent developments.
As well, I would like to offer expats some
advice on how to stay safe when it comes to food and eating during your
stay in China. To go directly to my safe eating in China tips click here.
We have a list of healthy food restaurants in Shanghai at the end of this article.
It's a shame that China's food industry has become globally synonymous with scandal. Historically the Chinese have a deeply entrenched cultural ethos that prioritizes diet and nutritional status as the key predicator of future and current health.
Underpinning an overall cultural appreciation for the prophylactic and therapeutic properties of foods is the extraordinarily complex system of traditional Chinese medicine, which is based on accumulated anecdotal evidence, clinical observations and millennia of practice.
We also have to give the Chinese a lot of credit for feeding 20 percent of the world's population using just nine percent of earth's arable land.
However, with so many food safety scandals occurring in China, as an expat it is hard to ignore food safety issues. Keeping things positive at the start, I'd like to begin my presentation by outlining the most important changes that have affected China food safety in recent years.
Institutional Reformation Targeting the Health and Food Safety Industry in China
The Chinese government has certainly been actively responding and tackling the many food safety issues here. The first major regulatory change of recent years came last year.
On March 10th, 2013, during the 12th National People's Congress, state councilor Ma Kai detailed major reform of China's health and food safety institutions.
The former State Food and Drug Administration (SFDA) became China's CFDA (China Food and Drug Administration) and China's former Ministry of Health was dissolved and replaced by the China National Health and Family Planning Commission (NHFPC ).
Under the change, the CFDA became China's chief food safety administrative bureau with greater regulatory responsibilities and powers; finally giving China's food safety watchdog the bite it previously lacked.
Under the consolidated regulatory and administrative power of the CFDA, food safety responsibility is centralized allowing greater oversight throughout the supply chain. The old and fragmented regulatory framework was completely overhauled, and responsibilities previously divided between the General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ), and the State Administration for Industry and Commerce (SAIC) now fall under the individual remit of the China Food and Drug Administration (CFDA).
The move will help to close the regulatory loop holes which have plagued China's food industry, thereby creating a regulatory agency with hallmarks similar to that of the US Food and Drug Administration (FDA) and Europe's Food Safety Authority (EFSA).
Regulatory System for China's Food Supply Chain
The regulatory system for China's food supply chain is better understood by dividing it into two broad categories.
The first is food production defined by farming (crop cultivation), animal husbandry and fishing which is primarily managed by the Ministry of Agriculture (MoA).
The second is the subsequent processing of agricultural outputs broadly managed by the CFDA.
There are key legislative pillars that separate these basic links of China's food supply chain, namely the Agricultural Law ( food production) and the Food Safety Law ( food processing encompassing use of food additives, food packaging, use of fortification agents, functional foods, new foods).
There is also key administrative, enforcement and supervisory support provided by a number of other government authorities, primarily the National Health and Family Planning Commission (NHFPC) and the AQSIQ.
The CFDA is tasked with supervising all foods circulating domestically in the Chinese market, while AQSIQ is tasked with premarket inspection of all imported foodstuffs.
CFDA and AQSIQ head offices in Beijing provide primary oversight duties throughout the supply chain, and delegate enforcement and supervisory responsibilities to their regional FDAs and CIQs (China Inspection and Quarantine) respectively, such as the Shanghai Food and Drug Administration (SFDA).
Shanghai, as one of China's food importation hubs and home of the China (Shanghai) Pilot Free Trade Zone (sure to become a key base for food import companies in China), has one of the country's most stringent food supervision and regulatory environments.
With the key links in China's food supply chain defined, we can further divide China's food supply Chain into imported foods and domestically produced foods.
These supply chains are vastly different. A useful analogy to compare the complexity of the domestic supply chain (figure 1) to the relative simplicity of the import supply chain (figure 2) can be illustrated like this.
Figure 1: China's Domestic Food Supply Chain
Imagine the import supply chain as a simple linear chain, and the domestic supply chain as a chain link fence with multiple directions and mutually dependent interactions.
From just a quick comparison of the two, we can see that imported foods in China have an inherently more controllable supply chain, with clearly designated entry points that lends itself to full regulatory oversight.
Figure 2: China's Imported Food Supply Chain
The government has earmarked imported foods for increased regulatory
supervision and enforcement, not as a means to increase technical
barriers to trade, but rather to guarantee at least one safe food supply
chain for Chinese consumers.
On the other side, lack of adequate supervision of the domestic food supply chain in China has left this key link open to numerous food safety issues, particularly exploitation by unethical food criminals.
from bringing in a new overarching framework to improve food safety in
China, the government has also focused its regulatory work on specific
areas of the food industry which have led to many of China's food safety
issues in recent years.
China is adopting a modernization strategy I like to call the "natural selection by regulation policy." This basically means that the government institutes stringent regulatory reforms designed to pressurize weaker substandard manufacturers to increase their standards, close operations or merge.
consolidates manufacturing into a smaller number of higher standard,
financially stable manufacturers. The dairy industry is a prime example
of this strategy.
China's dairy industry has undergone a massive overhaul (specifically control over quality of both domestic and imported milk products).
Under new regulatory reforms, all domestic manufacturers must have a dedicated milk supply source with far stricter regulations on raw milk quality standards (particularly bacterial content and protein requirements).
OEM manufacturing has been banned for domestic dairy manufacturers. All imported dairy in China including infant formula requires the dairy manufacturer to undergo a stringent audit by the relevant Chinese government authorities prior to import. Traceability is also a major requirement for infant formula, in addition to clear country of origin labeling and manufacturer information.
Health Food Industry in China: Commonly referred to as food supplements in other countries
Currently the regulatory system for health food supplements in China is out of touch with the state of the art and far behind European, American and Japanese regulatory frameworks.
In terms of RDI (recommended daily intake), China's primary food fortification standard GB 14880 (where most of China's RDI standards are listed) is hugely out of touch with global developments in molecular nutrition, nutrigenomics etc.
If a product has nutrients outside the scope of China's national standards, or offers nutrients not appearing on China's positive list of regulated nutrients, it is simply illegal and cannot be certified under China regulations.
For this reason, the Chinese people can not easily benefit from many supplements that have been proven effective and are legally available overseas. However, the good news is that China is currently in the process of reforming this industry, and in the next five years we can expect some significant positive steps towards a better health food supplement market in China.
It is common knowledge that Chinese farmers use much higher amounts of chemical pesticides than European or American farmers, and also use some pesticides that have been banned overseas.
Fortunately there is help on the way. Biopesticides or biocides are biological agents used as a replacement to traditional chemical pesticides. Biopesticides are inherently safer for humans and don't pose the same risks as conventional chemical pesticides.
They are also more environmentally friendly.
The Chinese government is attempting to facilitate manufacturing of these products by easing regulatory requirements.
To get an idea of the extent the Chinese government is reforming its food industry just take a look at what has happened over the last year.
The most recent reform, currently a work in progress (number 1 on the list above) will be China food industry's most significant change in recent years.
The drafting of China's new food safety law has had and will have significant impact on a number of sectors of the food industry. This new China Food Safety law went into effect on October 1st, 2015.
The revised food safety law has been expanded from 104 articles to 159 articles with the purpose of building the most stringent legislative and regulatory system ever.
Beyond some of the more obvious changes like mandatory use of Chinese labels for imported foods (Food Safety Law Article 92) and clauses regarding infant formula manufacturing (Food Safety Law Article 69), I pick some of the more interesting pending changes to describe here.
Old Law: Health Foods imported for the first time to China should be registered with CFDA.
New Law: Once all the ingredients are regulated under Chinese national Standards, imported health food products in China will only require filing and no longer require registration.
In addition, in the past it was necessary to provide documentation proving that the product had a history of at least one year safe market circulation in the country of origin.
Under the new law, it will be sufficient to provide documentation proving that the sale of the product is sanctioned by the competent food authority in the country of origin.
Industry Impact: Market access requirements for non-novel health foods will be greatly reduced. Using Chinese national standards such as GB14880 as a reference, it will be possible to develop new supplements that will be facilitated with greatly expedited China market access.
It is also highly likely the government will publish a positive list of health food ingredients.
Old Law: The only major regulatory barrier for imported foods was CIQ (China Inspection and Quarantine) inspection at port.
New Law: There will be regulatory supervision throughout all stages of the imported food supply chain. It is also likely that traceability systems (Article 45) currently being piloted for domestically produced foods will be expanded to include imported foods
Industry impact: Post market supervision and enforcement for imported foods in China is likely to increase.
Old Law: All imported foodstuffs must conform to Chinese national standards. Foods that are not regulated under Chinese national standards and have no history of consumption in China require new food material registration. Under the old law only domestic agents could submit this application.
New Law: Foreign food importers and manufacturers will now be able to file safety assessment dossiers with NHFPC for approval.
Impact for Industry: Facilitates China market access for imported foods, especially for new food material health foods.
Old Law: No Precedent.
New Law: A corporate credit record system is to be implemented over domestic infant formula manufacturers whereby the CFDA will record quality and safety histories assessed under specific criteria and accordingly assign a manufacturer rating which will be the basis for future regulatory supervision.
Impact for Industry: China's Domestic Infant formula industry will be given a major tool to help boost consumer confidence and faith in the quality of domestically produced infant formula.
Old Law: No practical precedent.
New Law: A comprehensive recall system controlling all relevant parts of the food supply chain will be implemented. It will be broadly divided into a general recall system and an emergency rapid response recall system. The system will offer a platform to record relevant information and clearly outline the requirements for recall, halting or ceasing production of foods, traceability etc.
Impact for Industry: The new recall system will govern all aspects of China's food industry.
In this section, I will address the elephant in the room, the serious and unavoidable food safety scandals that continue to mar the reputation of China's food industry.
The primary issues facing China's food supply chain include:
As I have already outlined most of the regulatory and food safety standards issues above, in this section I will primarily focus on food crimes and environmental issues.
Food Crime and Pricing Pressures: China's Cyclical Food Safety Scandals
Chinese food industry scandals are hallmarked by an accompanying media firestorm, and usually a knee jerk government response resulting in legislative and regulatory changes.
With history repeating itself cyclically, you could be forgiven for believing that these reforms were nothing more than tokenistic policies, designed to paper over the gaping cracks in China's food industry legislative and supervisory framework.
Although in the wake of China's most publicized food scandal, namely the Sanlu infant milk formula melamine scandal, two chief culprits were sentenced to death, China food safety violation penalties have proven to be a weak deterrent against offenders.
With the financial stakes set so high and pricing pressure so extreme (everyone demanding the cheapest prices), food adulteration, counterfeiting, falsifying labels, false health claims etc. have continued to proliferate despite concerted legislative reforms.
Lucrative financial returns, combined with patchy domestic regulatory supervision, are breeding grounds for unethical practices, and until China implements full supervision throughout the supply chain, we can expect scandals to continue.
One critical system that China needs to develop in order to better fight food crime is a comprehensive national Traceability system.
Traceability, also known as the "farm to fork", or "from farmland to table", means the ability to track any food, feed, food-producing animal or substance that will be used for consumption, through all stages of production, processing and distribution.
Small scale traceability systems that allow food to be tracked throughout the entire supply chain from source to distributor all the way down to final consumers are being implemented in China.
However, mandatory use of these systems is still not a reality, and with the exception of the above mentioned provisions in China's new food safety law, there is unlikely to be widespread implementation of government-accredited traceability systems.
China's food industry has been extremely resistant to such initiatives, as evidenced by China AQSIQs attempt to pass a law requiring the PIATS (Product Identification, Authentication and Tracking System), a bar-coding system, to be used for the entire food industry.
Due to heavy lobbying against this law, it was never ratified and ended up in the bin. The PIATS system was championed by the AQSIQ, however, as shown, since last year it is the CFDA that is calling the shots with regard to domestic food traceability.
At the moment, the only national government traceability system being developed is currently in the early pilot stage, running on an internally developed system under the auspices of China's MIIT (Ministry of Industry and Information Technology).
Shanghai has been developing its own local traceability systems for certain food products since 2008, and says it will implement a comprehensive system covering 90 percent of the city's produce by 2015.
The future integrity of Chinese food safety will be achieved only when a country-wide open access traceability system exists, where individual consumers can guarantee the authenticity of the products circulating on the market.
In terms of environmental issues, particularly soil quality issues, China is reaping the rewards of the rapid and largely unregulated expansion of many seriously polluting industries from the 80s onwards.
If we consider the food supply chain as a pyramid, the bottom foundation block would be soil. Good quality soil and well managed crop cultivation grow healthy nutrient dense crops, with healthy immune systems, much better equipped to deal with pests and disease.
Pollution and unsound farming practices lead to problems with soil health, requiring higher agricultural inputs such as fertilizers and pesticides.
Unsustainable chemical farming methods, heavy metals and agricultural pollutants, such as pesticides and fertilizers, have over the recent decades severely damaged China's most important agricultural requirement, namely its soil.
In a report issued by the Ministry of Environmental Protection and the Ministry of Land and Resources, it was revealed that the soil covering almost 20 percent of China's arable land has pollutant levels exceeding national standards.
"Pollutants included 13 types of inorganic pollutants, mainly heavy metals, and three types of organic pollutants. All may affect the production and quality of crops and are hazardous to human health."
In regard to China water quality, a report released by the Ministry of Environmental Protection in June 2013 revealed that "The quality of underground water in 57.3 percent of the 4,929 monitoring points in 198 cities around the country is 'relatively poor' or 'extremely poor'. In addition, the resources in about 30 percent of water monitoring points in major rivers was of poor quality."
Finally, coming to air pollution in China, in another study by He Dongxian, an associate professor at China Agricultural University College of Water Resources and Civil Engineering, it was shown that air pollution in China causes crops to grow slower and thus require more inputs to retain normal growth.
China's immense food supply chain is comparable to an ecosystem. Changes at any level of this chain have a ripple effect, that radiates from the epicenter to all downstream and upstream links in the food chain, affecting the safety and quality of food at all levels.
As a basic explanation, we can consider how soil quality dictates the levels of fertilizer and pesticides needed, which in turn dictates the quality and safety of crops.
China's polluted environment in many cases results in poor soil quality, which requires farmers to use larger amounts of pesticides and fertilizers to grow their crops, and increased amounts of veterinary drugs to keep the animals that rely on these crops healthy.
As we move through the different trophic levels from the soil to crops, to the animals that rely on these crops for feed, there occurs a process called bioaccumulation, which concentrates toxic contaminants in the animals we consume.
So now that I have adequately armed you with a solid overview of China's food safety system, its recent and ongoing improvements, along with some of its more glaring inadequacies, I would like to discuss how we as China expats can apply regulatory knowledge to make safer food and eating choices in China.
While there are many obvious smart choices regarding microbiological food safety, such as not eating in places that look overtly dirty, or employ what obviously appear like questionable food safety standards (choose restaurants with a neutral or happy face on their Food Safety Inspection Notification signs), I would like to address some of the more interesting options available to expats.
1. Buy imported foods in China (Jìnkǒu shípǐn 进口食品)
Sounds a little biased, right? However, all food imported through legal channels in China is subjected to China's strictest regulatory supervision.
Imported products must undergo testing and inspection at port which includes random sampling of batches, label review etc. Imported foods are all assessed using Chinese national standards from an ingredient, safety, and labeling perspective using prescribed testing criteria.
Non-compliant imported goods are returned or destroyed at port by China's CIQ. Every month the Chinese customs and quarantine bureau (CIQ) seize thousands of dollars' worth of imported products.
In the coming months the stakes will get even higher for importers with the implementation of a publically available CIQ blacklist of incompliant importers and products in addition to blacklisting countries that are serial offenders.
Several violations will result in mandatory testing for all products every time they arrive at port. As such, buying imported food from safe channels is normally a safe choice for expats in China.
2. Green Foods (Lǜsè shípǐn 绿色食品)
3. Organic Food (Yǒujī shípǐn 有机食品)
4. 'Safe Foods' (Wú gōnghài shípǐn 无公害食品)
5. Health Foods (Bǎojiàn shípǐn 保健食品)
6. Private sector Testing
Numerous agencies are investing in privately funded traceability programs here in China. Many companies specializing in implementing enterprise based traceability programs complete with publically accessible online query interfaces are currently targeting China's markets.
Foreign grocery stores such as Metro and Carrefour have developed their own strict traceability systems.
To ensure the quality of imported food in China even more, Central Testing International, China's largest privately owned product testing organization, is spearheading a ground-breaking new food safety authentication and traceability system, utilizing advanced state-of-the-art stable isotope analysis.
Without getting overly technical, the idea is based on the fact that food from specific geographical locations has unique stable isotope signatures (analogous to human fingerprints).
The basic premise of the system will operate by compiling a database of reference stable isotope signatures of imported foods, that can be used to verify the authenticity of these foods. Such a system will offer Chinese and expat consumers an unprecedented level of confidence in imported foodstuffs, and moreover will serve as the foundation of a scalable food safety certification system founded on scientific principles.
If expanded to domestic food in China, and combined with government regulatory reforms, it should prove an effective solution to China's food supply chain problems.
Although the Chinese government has made significant food safety regulatory reforms in recent years (particularly for imported foodstuffs), I believe it is market forces and not regulatory reforms; specifically demand for quality, authentic and guaranteed safe foods that provides the key impetus to solving the troubles inherent in China's food supply chain.
China's burgeoning middle class are awash with disposable income and place a high priority on safe and healthy food, so much so that they are willing to pay a premium for guaranteed safe foods.
As such, Chinese consumers demand for guaranteed safe foods will push further reform of China's food industry.
The flip side of the issue is that Chinese socioeconomic stratification is such that what we are seeing now is the early stages of an ultra-polarized, two-tier food market.
The middle and upper classes will purchase higher quality and safer certified foods, as witnessed by massive year on year growth in both the value and volume of foods imported into China, while the lower working class will purchase from a supply chain that will always be subject to intermittent food safety scandals.
It is only through the upper mobility of lower classes and overall economic success that China's food safety issue will improve for all.
Paul O'Brien is an Irish expat working as a food regulatory analyst and head editor for Chemlinked. https://food.chemlinked.com/
Chemlinked is a regulatory information and practical compliance service provider based in Hangzhou, Zhejiang province that brings Chinese regulatory affairs to a global audience, in addition to a host of regulatory affair services and tools in multiple languages including English, Korean, Japanese and Chinese.
Paul has a scientific background specializing in genetics and food science. He has lived in China for three years.
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