By Linden Ellis and Jennifer Turner

Sparked by a number of Chinese food export scandals in early 2007, international attention on China's food safety intensified throughout the year. While the international news media has focused on the problem of Chinese exports, within China food safety problems have been a serious concern for the Chinese public for many years. Pressures domestically and internationally have catalyzed some progressive changes in food regulation in China, which was the focus of discussion at a December 18 China Environment Forum (CEF) meeting. At this meeting, CEF hosted a delegation from China's Ministry of Science and Technology (MOST) to discuss the Chinese government's policies and new research agenda to ensure food safety. The meeting opened with An Daochang—vice director of MOST's National Center for Biotechnology Development, which is responsible for the development and management of research projects in the fields of biotechnology and food safety. An Daochang highlighted the institutional challenges to China's food safety, such as overlap between the 13 ministries in charge of domestic food safety and the challenges of monitoring products from a huge number of small-scale agricultural producers in a cash-based agricultural market. Wu Yongning from China's Centers for Disease Control discussed new regulations, research, and projects currently underway to strengthen food safety regulation. Fred Gale of the U.S.Department of Agriculture's Economic Research Service focused his comments on certification and industry efforts to promote safer food products in China. Many of these certified products are considerably more expensive than uncertified foods, creating a two-tiered system in which poorer citizens have less access to safer food. This meeting was timely, for the United States and China just concluded their third Strategic Economic Dialogue (SED) meetings in Beijing, which produced a number of food and product safety agreements.

The Real Problem
Since China joined the WTO in 2001, imports to the United States have increased dramatically, as have incidents of unsafe food. According to Dr. Wu, much of the news media attention on food safety has misinformed the public. For example, although news stories often highlight chemical contamination, the main food safety threat in China remains microorganisms. Wu believed one of the main institutional shortcomings behind food safety scares and export rejections is that the development of food safety standards continues to lag behind the volume of production. The numerous small farms combined with poor handling practices are particularly tough regulatory challenges. Notably, Chinese urban consumers, for whom basic food security needs have been met, are beginning to demand safer foods, and they are increasingly willing to pay more for them, which is pushing better regulation.

In order to ensure that science and actual circumstances are taken into account when designing food regulations, the Chinese government has made serious efforts to collect reliable data on food safety in the country. In 2002, China conducted its first health census, the National Survey on Diet and Health Status, which will be conducted every 10 years. Samples were taken from 132 sites in 31 provinces and consisted of four parts: (1) questionnaires, (2) physical examination, (3) laboratory tests, and (4) and household dietary surveys. This census identified microorganisms as the major threat to food safety.

There are two ways that China monitors trends in food safety, the Nationwide Food Contamination Monitoring Network and the Total Diet Study (TDS). The network operates in 17 provinces and focuses on monitoring concentrations of contaminants for the purpose of early detection for emergency response. Four rounds of the TDS have been conducted since 2000 in 12 provinces with the goal of monitoring and analyzing trends in food safety. The TDS has a smaller sample size than National Survey on Diet and Health Status and focuses on assessing exposure to contaminants, including specific emerging contaminants such as chloropropanol and acrylamide.

Tracing the source of the contamination is a major part of the TDS initiative, which highlights its utility for regulating and monitoring agencies in China. For example, the 2000 study showed that between 1990 and 2000 cadmium contamination in vegetables, grains and roots fell dramatically, but rose considerably in meat sources, especially seafood. During the survey, scientists were able to trace the contamination to a specific species of crab in Liaoning Province. Seafood, in fact, emerged frequently in the survey as a major source of contamination including HCH, Dioxins/PCBs, and organic tin. These findings, combined with repeatedly rejected exports, have lead regulators to target the seafood industry. (See the CEF Aquaculture research brief and China Environment Series 9 article "Surf and Turf" for more information on fish and meat safety in China).

Certification and Standardization
According to speaker Fred Gale, the food certification "system in Beijing is amazingly up-to-date." Even more striking than a fairly extensive food certification system has been the growing trend of international and Chinese food exporting companies creating their own "islands of safety" by strictly overseeing growers who supply their products. These farming operations can range in size from village wide to whole provinces and usually involve the company paying farmers to grow their products under a central supervisor who monitors for safe practice and transparency. Another feature of these "islands" is reliable field laboratories where food is tested for contamination before being shipped to consumers, usually internationally.

Dr. Wu, drawing on his work serving on a committee at the World Health Organization (WHO), noted that the WHO believes China is doing well on the food safety issue when compared with other developing countries. However, broad public concern about the safety of China's food supply domestically and globally led the Chinese government to take a number of initiatives to safeguard food safety from farm to table, particularly in policies aimed at encouraging farm consolidation and standardization. For example:

• A recent major farm consolidation was launched in new regulations that require all poultry to be kept indoors, attempting to eliminate commercial backyard poultry.

• Traceability, a major issue in a cash-based economy, is being targeted with farm record keeping requirements. Moreover, third party certifiers are encouraged, both by the government and industry, to ensure that proper records are kept.

• The biggest public sector push has been with end-product testing for residues and contamination. However, there are obvious shortfalls of this method, such as sheer volume and the limited traceability of end products.

• In terms of reducing toxic chemical residues in food, the government has eliminated the use of the 5 most toxic pesticides in 2004 and encouraged organic production by greatly expanding the scope and reliability of organic food certification.

Beyond new regulations and campaigns to promote better standardization in China's food production, Wu emphasized the importance of three new laws: The newly drafted Food Safety Law; the Food Hygiene Law (overseen by the Ministry of Health); and the Law of Quality and Safety for Agri-Product (led by the Ministry of Agriculture). The latter law requires that all food safety emergencies must be reported immediately.

The new food safety law, which was submitted to the People's Congress at the end of 2007 is distinctive from its previous version in that it: (1) outlines the specific responsibilities of government bureaus at all levels, (2) places the Ministry of Health as the government entity primarily responsible for food safety, (3) requires all findings be available on the web for feedback, and (4) mandates higher fines for violators and punishments for officials who do not enforce the law.

Structural Challenges
Although it is believed that the new food safety law will alleviate some of current institutional problems, the structure of the regulatory system remains an obstacle to an otherwise improving situation. Currently, food safety is regulated by 13 ministries resulting in finger-pointing and turf-battles when problems arise. Some of the responsibilities of the key ministries overseeing food safety are:

Agricultural production control: Ministry of Agriculture
Food products production control: State Administration of Quality Supervision, Inspection and Quarantine (AQSIQ)
Market control of food products: State Administration of Industry and Commerce
Inspection of food service, crisis management and food recalls: Ministry of Health

Another structural challenge for China is the danger of becoming a dual-standard country. AQSIQ is the only ministry in control of food safety exports from farm to ship. Third party certifiers and large company exporters ensure export food safety, while exports that do not meet international standards are often then sold in the domestic market. Yet another developing dual-system is the divergence in quality between the goods consumed in urban markets and rural markets. Dr. Gale pointed out that safe food comes at a high price in China, with grocery brands selling for as much as 500 percent more than traditional wet-market goods. In order to avoid social instability over this inequity of safety, China's government will have to alleviate some of these dualities.

Areas for Collaboration with the United States
The reforms of China's food safety infrastructure and efforts to regulate the huge food production sector offer many areas for collaboration with other nations. Dr. Wu highlighted the need for international assistance with risk assessment and monitoring to bolster the nation's data quantity and quality, which are the foundations of MOST's food safety work. With regards to chemical contamination, data sharing on the affects of specific contaminants on the human body would be helpful for proving causation and influencing policy changes. Technology sharing through relaxed patent regulations would also help China gather information more accurately and quickly. An area that the United States in particular could offer assistance is industry self-regulation, as that is the keystone of U.S. food safety regulation. In terms of grassroots institutions, the MOST delegation expressed interest in encouraging and developing farmer's associations to improve standardization and information dissemination among food producers.