Global food trade is expanding, providing consumers with access
to a wider year-round variety of foods at lower prices. Expanding
trade has brought into sharper focus the divergence among countries’ food
safety regulations and standards. These variations may reflect
differences among their populations’ tastes and preferences,
ability to produce safe food, and willingness to pay for risk-reducing
technology. Building common ground for food safety regulation through
public and private initiatives is helping to achieve the simultaneous
goal of improving food safety and enhancing trade.
Differences in food safety regulations and standards among importing
and exporting countries can cause friction and even disputes that
impede international food trade. Countries are, however, tackling
food safety and trade issues by learning from each other’s
successes in managing food safety to narrow regulatory differences,
collaborating to adopt common or international standards set by
a third party, or reaching compromises on conflicting standards.
Private food safety initiatives, such as voluntary quality assurance
schemes, are also contributing to the resolution of differences
across borders.
Countries Have Good
Reasons for Different Food Safety Regulations
National tastes and preferences reflect a unique set of experiences
and cultural traditions. Some countries may perceive a certain
food safety risk as totally unacceptable, while others may place
a low priority on addressing that same risk. Imports acceptable
to one country may not be acceptable to another. For example, many
European countries are willing to accept the risks of Listeria in
cheese made from unpasteurized milk and select processing standards
to minimize these risks. Other countries restrict such imports
and even ban the sale of most of these cheeses.
Countries have different food safety experiences and food safety
risks in domestic food supplies. Risk levels vary internationally
due to differences in available technology (such as refrigeration),
plant and livestock host factors (plants with different levels
of contamination or herds with varying infection rates), food production
practices (such as the use of veterinary drugs), cultural differences
(for example, routine consumption of raw seafood), and geographic
or climatic conditions (for example, colder climates may reduce
some pathogens, and Aflatoxin contamination is most common in countries
with warm and humid climates).
Countries differ both in their ability and willingness to pay
for state-of-the-art technology to reduce food safety risks as
well as in the optimal ways to reduce these risks. For example,
national perceptions about Salmonella risks in poultry
vary tremendously as do commitments and preferred choices for its
control. As a result, standards for Salmonella in poultry
imports vary tremendously across countries. For example, only poultry
product imports that are fully cooked and canned—processes
that effectively kill Salmonella—are allowed in
Chile, meaning that Chile has a zero-tolerance for Salmonella risks
in imported raw poultry products. Other countries, such as Japan,
reserve the right to test poultry shipments for Salmonella and
to reject any shipments testing positive. Others might require
testing for ready-to-eat but not raw products. Many other countries
do not specifically mention or target Salmonella in their
import requirements.
In addition to conflicts resulting from country differences mentioned
above, there is some concern that as trade expands, some countries
may use food safety regulations as a means to limit imports or
to require more regulatory steps than needed to ensure a particular
level of food safety risk. Some countries might also apply different
standards to imports than to domestic products.
Some disagreements will take considerable time and continued efforts
to overcome. One example concerns poultry exports from the United
States to Russia. Russia periodically has raised concerns that
U.S. poultry exports do not meet Russia’s stringent zero-tolerance
for Salmonella. Russia also claims that some antibiotics
are used which are not approved for use in Russia. In 2002, Russia
briefly banned imports of U.S. poultry, disrupting U.S. poultry
exports to Russia for several months and reducing prices for some
U.S. poultry products.
Countries
vary in their import requirements for poultry—particularly
when it comes to Salmonella
Importing
country
U.S. products eligible for
import
Salmonella-specific
regulations/requirements
Hong Kong
Fresh/frozen poultry and poultry products
Products may be subjected to laboratory examinationf or microbiological
contamination and positive-testing shipments refused entry
Russia
Poultry and poultry products, excluding consumer-size packages
of ground poultry, mechanically deboned poultry, and giblets
Negative Salmonella test results must be presented
to a Food Safety and Inspection Service (FSIS) veterinarian
before export certification can be issued; consignments are
ineligible if there are more than 1 (in 5 minimum) positive
samples
Latvia
Poultry and poultry products, except mechanically separated
and ground
products; must be certified as not having
been fed material originating from sheep
No separate Salmonella-specific requirements
Japan
All domestic poultry, except duckling giblets, coloring
agents in raw products, and poultry
and poultry products from or passing through
Pennsylvania
Japanese Ministry of Health reserves the right to test shipments
of ground and mechanically deboned poultry for Salmonella and
to reject positive-testing shipments
China
Fresh/frozen poultry products
No separate Salmonella-specific requirements
Canada
Federally inspected poultry and poultry products are eligible
for export to Canada, except carcasses, parts, or mechanically
separated poultry parts containing kidneys
or sex organs
No separate Salmonella-specific requirements for
raw products
Korea
Poultry and poultry products, except those imported into
the U.S. from a third country
No separate Salmonella-specific requirements
Estonia
Poultry and poultry products
Mechanically deboned poultry product is tested for Salmonella at
the port of entry; positive testing
shipments will be denied entry
Chile
Fully cooked and canned products
Cooking and canning requirement effectively means no Salmonella
Note: Some
countries without specific Salmonella standards for raw products
do have such standards and sampling procedures for ready-to-eat
products Source: FSIS, 2002.
Divergent regulatory standards can lead to food shipment delays
at the border while shipments of imported food are tested for pathogens
or can shut down trade altogether between countries. Food safety
regulations and any resulting trade interruptions can be costly
to countries and affected industries or firms. Despite the periodic
disruptions and friction over food safety issues, international
trade is expanding, and the amount of trade affected by regulations
is small in relation to global trade flows. Disruptions are relatively
small, considering the magnitude of global food and agricultural
trade ($436 billion in 2001), the thousands of food categories
and products traded, the roughly 200 countries participating in
food trade, and the range of food safety challenges. Additionally,
not having food safety regulations could result in even higher
costs to society than trade delays do if unsafe food is imported
and causes human illness and death.
Food
Safety Challenges
The globalization of the food supply
could potentially mean that new food safety risks can
be introduced into countries, previously controlled risks
can be re-introduced into countries, and contaminated
food can be spread across greater geographical areas.
However, there is no evidence that food imported into
the United States is riskier, per se, than domestically
produced food. There are many well-established food safety
challenges, as well as issues perceived to be food safety
concerns, such
as:
microbial pathogens (that is, illness-causing
bacteria, viruses, parasites,
fungi, and their toxins),
pesticide residues,
food additives,
environmental toxins, such as heavy metals (for
example, lead
and mercury),
persistent organic pollutants (for example, dioxin),
unconventional agents, such as prions associated
with "mad cow disease" in cattle,
zoonotic diseases that can be transmitted through
food from animals to
humans (for example, tuberculosis), and
foods produced with certain practices, such as
irradiation, or animal
products produced with growth hormones or antibiotics.
Countries Tackle Food Safety Risks Both Individually
and Collectively
Both the private and public sectors work within countries to establish good
food safety practices. The private sector has strong financial incentives to
protect its markets and the reputation of products or industries. In theory,
producers worldwide who see the benefits of enhancing food safety and take
risk-reducing measures for their products can protect or even expand their
export market share. They can also position themselves to take advantage of
new markets for products with higher levels of food safety. However, government
regulation is needed to ensure food safety because market transactions do not
take into account the social costs of food safety—such as medical costs
and lost work time—and consumers generally cannot discern the safety
of food before buying it.
Countries address food safety and trade issues both as individual
nations and collectively through international organizations. Individually,
countries learn from each other’s successes and adopt common
regulatory approaches. Food safety regulatory agencies worldwide
are increasingly adopting the
Hazard Analysis and Critical Control Point (HACCP) system as
a foundation for new regulations to control microbial pathogens
in food. HACCP is a system of identifying, monitoring, and controlling
hazards at critical control points in the food production and processing
chain. The public sector in many industrialized countries mandates
HACCP for some foods, while the private sector voluntarily implements
it for other foods.
Seven Food Safety Regulatory Trends Commonly
Found in Industrialized Nations
(1) Forming one agency to focus on food safety,
(2) Using risk analysis to design
regulation,
(3) Recognizing that a farm-to-table approach is
often desirable for addressing food safety hazards,
(4) Adopting the HACCP system as a basis for new
regulation of microbial pathogens in food,
(5) Adopting more stringent standards for many food
safety hazards,
(6) Adding new and more extensive regulation to
handle newly identified hazards, and,
(7) Improving market performance in food safety
through provision of information.
Audiovisual Library European Commission
Many countries are involved in collaborative efforts to address
food safety and trade issues. In some cases, countries will simply
adopt the standards of their trading partners. As many industrialized
countries with major food import and export markets adopt new regulations,
there are financial incentives for other countries to follow suit.
Alternatively, countries can recognize and accept each others’ regulations,
adopt common or international standards set by a third party (for
example, the Codex Alimentarius Commission (Codex) suggests standards
for human health measures), or hammer out a compromise. For instance,
Australia and New Zealand decided in 1996 to formulate many of
their food safety regulations jointly in order to reduce regulatory
trade barriers and transaction costs for industry. In 1998, the
United States and Canada signed a “Record of Understanding” under
which they proposed to try to facilitate agricultural trade in
a number of different areas, including harmonizing some food safety
testing procedures.
New food safety outbreaks, isolated events (for example, the 1999
Belgian dioxin crisis from contaminated animal feed), and emerging
crises (e.g., mad cow disease) will arise from time to time and
shock international food markets. When a new food safety hazard
or event is first identified, countries take steps to gather information
and limit the extent of the crisis. Later, as the event is resolved,
countries may develop new protocols and regulations to prevent
recurrence. These crises can initially be a source of friction
but ultimately they offer opportunities for international collaboration.
During a food safety crisis, producers of the suspect foods may
stop production of the foods or seek other markets, retailers must
find other sources of supply, and consumers must find substitutes.
As most foods are perishable or have a limited storage life, a
major food safety event can be disastrous for producers, exporters,
and importers. For example, a series of foodborne illness outbreaks
from the Cyclospora parasite began in 1996 in the United
States and Canada. The outbreaks were attributed to Guatemalan
raspberries, leading to a severe reduction in demand across the
Guatemalan raspberry industry and adversely affecting Guatemalan
blackberry producers as well. California strawberry growers also
lost millions in revenue when strawberries were at first mistakenly
implicated.
The U.S. Centers for Disease Control and Prevention, the U.S.
Food and Drug Administration, Health Canada, and the Canadian Food
Inspection Agency took aggressive actions to solve the Cyclospora problem,
protect human health, and restore access to safe raspberry imports.
Meanwhile, the private sector, including the Food Marketing Institute,
a U.S. organization representing food retailers, also pitched in.
Guatemalan growers developed a Model Plan of Excellence program,
which was mandatory for all Guatemalan raspberry exporters. The
plan requires compliance with a detailed list of specific food
safety practices, almost daily field inspections during the harvesting
season, and traceback capability. However, the new safety protocols
are prohibitively expensive for many Guatemalan producers, and
very few remain in business. There have been no new outbreaks since
2000.
Member nations of the World Trade Organization (WTO) have the
option of using the WTO to resolve differences. The WTO establishes
global rules of trade to help producers, importers, and exporters
conduct business. The WTO recognizes each country’s right
to have different preferences for risk reduction and to take different
measures to protect their populations. Based on available and relevant
information, WTO members have the right to set and follow standards
for a higher level of consumer protection than the level set by
international health standards. The WTO, however, requires that
countries base their food safety regulations affecting trade on
a review of scientific research and encourages countries to recognize
regulatory systems that provide an equivalent level of protection.
The number of food safety-related trade disputes worldwide is
unknown. However, since 1995, WTO members have registered in the
meetings of the Sanitary and Phytosanitary (SPS) Committee of the
WTO 108 trade concerns related to food and feed regulations as
well as measures that are designed to protect human health. The
SPS committee deals with measures designed to control animal and
plant pests and diseases. These human, animal, and plant health
measures represent a larger class of technical barriers to trade.
However, only one food safety trade concern has ever advanced all
the way through the SPS Committee dispute process to a WTO dispute
panel. Most disagreements are settled among countries before this
stage. The 1989 growth hormone ban by the European Union (EU) originated
from concerns about the effects of growth hormones on human health.
The scientific basis of the ban was later challenged successfully
by the United States and Canada but the EU has still not lifted
its ban.
BSE, A Prominent Food Safety
Issue
"Mad cow disease" or bovine
spongiform encephalopathy (BSE) is an emerging crisis that
has shocked food safety systems worldwide and presents
an ongoing challenge as more countries identify cases within
their borders. Domestic beef consumption in the EU fell
sharply during the 3 critical years of the mad cow disease
crisis. In 1988, BSE-infected cattle were first discovered
in the United Kingdom (UK); in 1996, infected cattle
were discovered in other EU countries, and it was announced
that BSE was potentially linked to a fatal human illness;
and in 2000, more BSE cases and the first related human
illnesses were discovered outside the UK.
The UK adopted an extensive set of programs to ensure
that cattle used for beef production were BSE-free. These
actions
included the Over Thirty Month Cattle Slaughter Rule, which
as the name implies, mandated that all cattle over 30 months
of age be destroyed (BSE is not believed to affect cattle
below this age) and banned all meat and bone meal (thought
to be a carrier of BSE) in cattle feed. These actions led
to a rather remarkable decline in newly identified BSE cases
in the UK between 1993 and 2001. Many other countries have
adopted similar initiatives, but BSE continues to be found
in small numbers in other countries. For example, in May
2003, Canada identified one BSE case in a domestically
raised cow, and in December 2003, the United States identified
one BSE case in a cow imported from Canada.
A closer look at the trade concerns related to human health measures
provides some insight into the sources of current tensions over
regulations in international agricultural markets. Most striking
is that 46 percent of the SPS trade concerns are related to the
regulation of transmissible spongiform encephalopathies (TSEs),
which include bovine spongiform encephalopathy (BSE) or “mad
cow disease.” In essence, regulations to reduce potential
risks due to BSE appear to have caused more international debate
than any other particular food safety issue. Some of these BSE-related
trade concerns were directed at the initial emergency measures
adopted by countries in 1996 while others followed the implementation
of new, extensive BSE regulations in the EU. Examples include Chile’s
and Peru’s complaints against the EU’s ban on the use
of fish meal in ruminant feed.
Advances in hazard detection technology and greater understanding
of food safety risks will help nations identify new concerns. In
some instances, regulatory differences may cause some countries
to alter and improve their food safety
systems so that they can trade in particular markets. The growing demand worldwide
for food safety suggests that improving food safety and expanding international
trade can be compatible and even mutually reinforcing goals.
This article is drawn from...
International
Trade and Food Safety. AER-828, USDA/ERS,
edited by Jean Buzby with contributions from Jane Allshouse, Jason
Bernstein, Linda Calvin, Ram Chandran, Erik Dohlman, David Harvey,
Kenneth H. Mathews, Jr., Lorraine Mitchell, Donna Roberts, Laurian
Unnevehr, and David Zorn. November, 2003.