Economic 

Information

Bulletin

Number 52

July 2009

United States 

Department 

of Agriculture

Economic 

Research 

Service

Fred Gale

Jean C. Buzby

Imports From China

and Food Safety Issues
www.ers.usda.gov

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Gale, Fred

Imports from China and food safety issues.

(Economic information bulletin; no. 52)

 1. Food industry and trade—China.

 2. Food adulteration and inspection—United States.

 3. Food handling—China.

 4. Imports—United States.

 I. Buzby, Jean C.

 II. United States. Dept. of Agriculture. Economic Research Service.

III. Title.

HD9000.9.U5

Photo credit: Fred Gale, USDA/ERS

www.ers.usda.gov www.ers.usda.gov
United States

Department

of Agriculture

www.ers.usda.gov

A Report from the Economic Research Service

Abstract

The U.S. Food and Drug Administration’s (FDA) increased attention to food imports 

from China is an indicator of safety concerns as imported food becomes more common in 

the United States. U.S. food imports from China more than tripled in value between 2001 

and 2008. Addressing safety risks associated with these imports is difficult because of the 

vast array of products from China, China’s weak enforcement of food safety standards, 

its heavy use of agricultural chemicals, and its considerable environmental pollution. 

FDA import refusal data highlight food safety problems that appear to recur in trade and 

where FDA has focused its import alerts and monitoring efforts. FDA refusals of food 

shipments from China suggest recurring problems with “filth,” unsafe additives, labeling 

(typically introduced in food processing and handling), and veterinary drug residues in 

fish and shellfish (introduced at the farm). Chinese authorities try to control food export 

safety by certifying exporters and the farms that supply them. However, monitoring such 

a wide range of products for the different hazards that can arise at varying points in the 

supply chain is a difficult challenge for Chinese and U.S. officials.

Keywords: China, food imports, food safety, U.S. Food and Drug Administration, FDA, 

misbranding, labeling, refusals, shipment, violation. 

Acknowledgments

We would like to thank ERS interns Shariyar Zarea and Andrew Anderson-Sprecher for 

their contributions to this project in data analysis and reviews of literature and regulations 

on Chinese food safety. We received helpful review comments on the manuscript from 

Geoff Becker, Congressional Research Service; Larry Busch, Michigan State University; 

Linda Calvin, ERS; Christopher J. Hickey, FDA; and Mark Petry, USDA’s Foreign 

Agricultural Service. This study benefited from information obtained from ERS trips to 

China supported by USDA’s scientific exchange program in 2006 and 2007 to assess 

food safety. 

Fred Gale, fgale@ers.usda.gov 

Jean C. Buzby, jbuzby@ers.usda.gov

Imports From China 

and Food Safety Issues

Economic 

Information 

Bulletin 

Number 52

July 2009
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Contents

Summary. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Potential Safety Hazards. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

What Foods Are Imported From China? . . . . . . . . . . . . . . . . . . . . . . . . . 5

FDA Refusals of Imports From China . . . . . . . . . . . . . . . . . . . . . . . . . . 10

 Three Industry Categories Account for Most Refusals. . . . . . . . . . . . . . 13

 Most Common Violations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

Efforts To Improve Chinese Food Safety . . . . . . . . . . . . . . . . . . . . . . . . 19

 China’s Food Safety System. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

 Approved Exporters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

 Third-Party Certifi cation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

 U.S.-China Consultations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

Conclusions and Discussion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

References. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

Recommended citation format for this publication:

Gale, Fred, and Jean C. Buzby, Imports From China and Food 

Safety Issues, Economic Information Bulletin No. 52, U.S. 

Department of Agriculture, Economic Research Service, July 2009.
iii

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Summary

Rising consumption of imported food poses challenges for U.S. food safety 

offi cials. Retailers and processors seeking low-cost suppliers and exotic and 

ethnic foods demanded by U.S. consumers procure foods and ingredients all 

over the globe. It is often diffi cult to ensure that suppliers in far-fl ung locations operate according to the high safety standards and tight quality control 

sought by U.S. consumers.

What Is the Issue?

China has emerged in recent years as an important source of food imports 

in the United States. Food imports from China more than tripled in value 

between 2001 and 2008. Several highly publicized incidents of food contamination and adulteration in both the Chinese food supply and in U.S. food 

imports from China have focused public concern on the safety of food from 

China. Motivated in part by these concerns, a U.S. Government Interagency 

Working Group on Import Safety issued an Action Plan for Import Safety

and the U.S. Food and Drug Administration (FDA) issued a Food Protection 

Plan in 2007. FDA opened its fi rst overseas offi ce in China in 2008.

This report discusses potential food safety risks associated with food imports 

from China based on available data. The report describes the types of foods 

imported from China based on U.S. Customs statistics and assesses their 

importance in the U.S. food supply, analyzes FDA refusals of food shipments 

from China, and describes food safety regulation and enforcement in China. 

Although the FDA data do not necessarily refl ect the distribution of risk in 

foods, the import refusal data highlight food safety concerns for which FDA 

has focused its import alerts, examinations (e.g., sampling), and other monitoring efforts.

What Did the Study Find?

The increase in U.S. food safety concerns is partly a result of the recent 

increase in global food trade. China is one of the fastest growing sources of 

U.S. food imports. In 2008, the value of food imports from China reached 

$5.2 billion, making China the third-largest source of food imports. About 

41 percent of this import value was from fi sh and seafood, most of it farmraised. Juices and pickled, dried, and canned vegetables and fruit accounted 

for another 25 percent. The remainder included a wide variety of products, 

many associated with Asian cuisine. 

Despite the rapid growth, less than 1 percent of the U.S. food supply 

comes from China. For a few specifi c items, like apple juice, garlic, canned 

mandarin oranges, fi sh, and shrimp, China is a major supplier. Imports 

from China accounted for about 60 percent of the U.S. apple juice supply 

and more than 50 percent of the garlic supply in 2007. Imports from China 

account for 10 percent of the U.S. shrimp supply, 2 percent of the catfi sh 

supply, and 8 percent of the basa (a type of catfi sh) supply. Basic foods that 

form the core of the U.S. diet—grain, meat, or dairy items—are generally not 

imported from China.
iv

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Data limitations constrain what is known about the safety of imported foods. 

ERS researchers analyzed FDA refusals of food import shipments originating 

from China by type of violation. Here, the term violation refers to products 

that appear to violate one or more of the laws enforced by FDA, such as 

those dealing with adulterated or misbranded products.

FDA refusals of food shipments from China peaked in early 2007, just before 

a series of highly publicized incidents. In 2007, FDA issued import alerts for 

wheat gluten, rice protein products, and fi ve kinds of farm-raised fi sh and 

shrimp from China. Customs statistics show that shrimp imports from China 

slowed after the FDA alert was issued. 

FDA refusals of Chinese food shipments refl ect the mix of products 

imported: fi sh and shellfi sh, fruit, and vegetable products account for most 

refusals. Most Chinese food imports are processed to some degree, and the 

most common problems cited by FDA—“fi lth”, unsafe additives, inadequate 

labeling, and lack of proper manufacturer registrations—are typically introduced during food processing and handling. Another of the most common 

problems—potentially harmful veterinary drug residues in farm-raised fi sh 

and shrimp—is introduced at the farm. FDA cites harmful pesticide residues 

and pathogens in Chinese food shipments less frequently. 

Chinese authorities seek to control the safety of food exports by certifying 

exporters and the farms that supply them. Certifi ed exporters constitute a small 

fraction of China’s food industry. Most of China’s 200 million farms and food 

companies are, in theory, excluded from export supply chains. Still, monitoring 

the wide range of products and hazards that can arise at varying points in the 

export supply chain is a challenge for Chinese and U.S. offi cials. Consultations 

and exchanges between Chinese and U.S. offi cials on food safety are an important step toward improving the effectiveness and effi ciency of monitoring 

and enforcing U.S. food safety standards in food shipments from China to the 

United States. Safety-related measures, such as facilities upgrades, careful 

record-keeping, closer control over suppliers, testing, certifi cations, and audits, 

are likely to raise costs for Chinese food exporters. 

How Was the Study Conducted?

ERS analyzed customs data on food imports from China to assess the trend 

and composition of imports. ERS obtained from FDA a comprehensive database on Import Refusal Reports (IRR) on Chinese food shipments refused 

entry into U.S. commerce between 1998 and 2004. ERS also downloaded 

more recent data for 2006-09 from the FDA web site. ERS tabulated the 

number of refusals of food shipments from China by year, product category, 

and violation in order to characterize the profi le of potential safety problems in food imports. The FDA data reveal recurring problems in imported 

foods, but the data are not an indicator of the actual level or distribution of 

food safety risks that imports may pose to U.S. consumers. The study also 

describes recent developments in food safety monitoring and enforcement for 

Chinese food exports, certifi cation of exporters, and consultations between 

U.S. and Chinese food safety offi cials.
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Introduction

Rising consumption of imported foods poses challenges for U.S. food safety 

offi cials (Becker, 2008b; Buzby, 2003; Buzby et al., 2008). Retailers and 

processors seeking low-cost suppliers and exotic/ethnic foods demanded by 

U.S. consumers procure foods and ingredients all over the globe. It is often 

diffi cult to ensure that suppliers in far-fl ung locations operate according to the 

high safety standards and tight quality control demanded by U.S. consumers. 

Recent incidents of food contamination and adulteration in Chinese food 

imports are a prominent manifestation of this issue. Adulterated milk, pet 

food, fi sh and shrimp, and news media reports about U.S. Food and Drug 

Administration (FDA) refusals of Chinese food shipments have created a 

groundswell of concern about the safety of food from China. Subsequent 

exchanges between U.S. and Chinese offi cials have addressed food safety 

issues. In 2007, a U.S. Interagency Working Group on Import Safety issued 

an Action Plan for Import Safety and FDA issued a Food Protection Plan.

1

FDA opened its fi rst overseas offi ce in China in 2008.

This report sets forth factual information about what foods the United States 

imports from China, safety risks that appear to be associated with those 

imports, and recent developments in food safety regulation and enforcement 

in China. The report provides a general assessment of where risks arise in the 

food supply chain. The analysis is based on customs statistics and data on 

FDA refusals of food shipments from China into the United States. 

1See http://www.importsafety.gov/ 

and http://www.fda.gov/oc/initiatives/

advance/food/plan.html.

The processing, handling, and distribution 

of food in China is labor intensive.

imports, and recent developments in food safety regulation and enforcement

in China. The report provides a general assessment of where risks arise in the

food supplychain. The analysisis based oncustoms statistics and dataon

FDArefusals offood shipments fromChinainto the United States. 
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Potential Safety Hazards

World attention was focused on Chinese food safety problems in 2008 when, 

by offi cial accounts, six Chinese infants died and nearly 300,000 children were 

sickened with kidney ailments after consuming infant formula adulterated with 

melamine, an industrial chemical added to raw milk to raise its apparent protein 

content. China’s top food safety offi cial resigned, a company chairwoman and 

dozens of others were jailed, and other offi cials were fi red. The problem spilled 

over into global markets when Chinese milk and other products (including 

candy, eggs, and biscuits) containing traces of melamine were found in other 

countries. The infant formula incident followed a string of domestic incidents, 

including an earlier series of infant deaths in 2004 from consuming fake milk 

powder; use of toxic dye in duck feed, chili sauce, and other foods; an outbreak 

of meningitis traced to snails served in a Beijing restaurant; periodic food 

poisonings in school or workplace cafeterias; use of industrial bleach to whiten 

noodles; carcinogenic drugs in fi sh and shrimp; poisoning from a steroid used 

in pork production; and the widespread sale of pork from pigs that were sick or 

had died from illness.2

Chinese food items have been periodically rejected in Japan, Europe, the 

United States, and elsewhere in recent years (Calvin et al.; Dong and Jensen). 

Japan introduced a stringent “positive list” system for testing food imports 

in 2006, largely in response to concerns about the quality of imports from 

China (Nelson and Sato). In early 2008, Japanese consumers were sickened by dumplings from China that were poisoned with pesticide residues, 

further elevating Japanese concerns about the safety of Chinese food imports. 

Inspections of imports from China by Thai health offi cials in 2007 found 

excessive pesticide residues in vegetables, high levels of sulfur dioxide in 

dried foods and preserves, and forbidden artifi cial colorings in candy (Ting). 

In 2007, the United States encountered a series of widely publicized problems with Chinese imports. FDA issued import alerts after it detected 

melamine in wheat gluten and rice protein products and unsafe veterinary 

drug residues in fi ve types of farm-raised fi sh and shrimp from China 

(Becker, 2008a; Schmit; Weise). In 2008, an import alert for milk products 

was issued in response to concerns about melamine adulteration. Since the 

1980s, FDA’s import alerts for Chinese products have also included red 

melon seeds (illegal dyes), bean curd (insect fi lth), dried fungus and mushrooms (fi lth from animals and insects), fresh garlic (mold, decomposition, 

insect fi lth/damage), and honey (fl uoroquinolone residues) from China. 

Potential food safety hazards in China stem from many sources. High crop 

yields and animal output from intensively cultivated land are achieved by 

widespread use of chemicals and veterinary drugs, some of which leave 

toxic residues on food. Banned toxic agricultural chemicals are still available 

through underground vendors. Even where they are not used, chemicals may 

still be present in the soil from use in past years or may drift when sprayed 

on adjacent fi elds. Many of China’s farms and food processors are situated 

in heavily industrialized regions where water, air, and soil are contaminated by industrial effl uents and vehicle exhaust. Hong Kong researchers 

found heightened levels of lead and cadmium in tests of crop soils from the 

Pearl River Delta region of southern China (Wong et al.). Contamination 

2Schönmann describes a Chinese 

journalist’s exposé on China’s food 

safety problems. A Chinese language 

description of problems is offered by 

China Central Television.
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from human and animal waste also contributes to poor water quality, partly 

because most rural areas lack sewage systems. It is common practice to let 

livestock and poultry roam freely in fi elds and to spread livestock and poultry 

waste on fi elds or use it as fi sh feed.

Many safety risks associated with foods imported from China are introduced 

in the manufacturing and handling of food. Poor handling and storage may 

introduce bacteria, viruses, parasites, fungi, and their toxins. Perishable 

vegetables and meat have traditionally been sold by small vendors the 

same day they are picked or slaughtered. Produce is typically transported 

in small open trucks. Refrigerated storage and transport equipment is relatively scarce. When temperature-controlled infrastructure is available, power 

outages, railroad delays, and differing temperature standards may lead to 

spoilage. Awareness of foodborne illness risks is relatively low in China, 

and the incidence of such illnesses reported by offi cial statistics is probably 

underestimated (Wang and Ren; Schönmann). Many food processors use 

unsafe additives, toxic dyes, or fake ingredients to preserve food, cut production costs, or improve product appearance. The melamine-adulterated milk 

powder and pet food incidents brought attention to the widespread practice 

of adding melamine to feed and milk to artifi cially raise the apparent protein 

content. A presentation by offi cials overseeing food safety in the southern 

province of Guangdong cites a long list of problems found in food manufacturers, including outdated facilities with inadequate building materials, 

old rusty equipment, poor control of worker health and hygiene, weak monitoring of raw materials, contaminated water, and nonexistent or fraudulent 

recordkeeping (Zhang and Zhao). Food labels often lack proper descriptions 

of ingredients and nutritional information or are otherwise inadequate. 

Making generalizations about China’s food industry is diffi cult. Several 

thousand modern, large-scale, multinational and joint venture companies and 

farms that use best practices and sophisticated equipment operate alongside 

millions of small independent farms, workshops, and merchants that use 

crude equipment and techniques. China has some 200 million farming households with average land holdings of 1-2 acres per farm and at least 400,000 

food processing enterprises, most with 10 or fewer employees. Millions of 

people and businesses are involved in the handling and transportation of 

food beyond the farm gate. The vast number of food suppliers increases the 

challenge of disseminating standards, monitoring production, and tracing 

problems to their source. In China’s food sector, farmers and entrepreneurs 

frequently enter new industries and worker turnover is high. Consequently, 

many participants in food supply chains are unaware of standards and proper 

practices. Some producers and merchants in China’s highly competitive 

market cut corners, add toxic substances, or skimp on safety controls to fatten 

razor-thin profi t margins or gain some other competitive edge.

Chinese offi cials historically have been preoccupied with increasing the 

quantity of food to feed China’s 1.3 billion people. Food safety became a 

government priority only during the fi rst decade of the 21st century, when 

a series of action plans, regulations, and certifi cation systems were enacted 

(see Cadilhon and Hoejskov; Calvin et al.; Ellis and Turner). Concerns about 

the use of unsafe pesticides, veterinary drugs, and rural pollution are so widespread that China’s Ministry of Agriculture and Ministry of Environmental 

Protection have begun extensive national testing of vegetables, meat, and 
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fi sh for chemical and drug residues and testing of rural soil, air, and water for 

heavy metals and other pollutants (Sun; Wu). National food safety standards 

and certifi cation programs based on international standards have been put in 

place, but provinces and industries can set their own standards. The resulting 

array of differing standards creates confusion. Domestic food safety enforcement is mostly at the local level and can vary widely. Many local governments lack resources to enforce food safety. Local governments frequently 

have ties to industry that discourage tight regulatory oversight. Responsibility 

for regulating safety for exported food is concentrated in the national General 

Administration of Quality Supervision, Inspection, and Quarantine (AQSIQ) 

and its provincial branches. Food exporters commonly attain internationally recognized certifi cations, but producers of food for the domestic market 

are certifi ed by local government organizations under domestic certifi cation 

programs that are not well understood outside China. 

A new Food Safety Law that took effect in June 2009 will attempt to address 

many of the long-recognized domestic food safety problems by establishing 

national food standards, setting up a food safety commission, requiring food 

manufacturers to keep extensive records, and making suppliers of food liable 

for food safety violations. However, the new law’s effectiveness will depend 

on how it is implemented and enforced.

The general level of food safety in China seems to be improving, but it is 

diffi cult to assess the seriousness of problems or the degree of progress since 

information is closely guarded by the Chinese Government. For example, the 

Ministry of Agriculture’s testing of vegetables, meats, and fi sh in domestic 

markets for pesticide and drug residues reported impressive compliance 

rates ranging from 91 to 100 percent in 2007. However, few details about 

the testing are made public, so the results are diffi cult to evaluate. China’s 

Center for Disease Control and Prevention conducts extensive surveys of diet 

and nutrition that can trace intakes of toxic substances to types of food and 

regions, but these results are also not widely publicized (Ellis and Turner; 

Wu). Liaoning Province has a database of soil, water, and air pollution test 

results that identifi es areas suitable for organic or “green” crops, but the 

information can be accessed only through government authorities (Gale, 

Avendaño, and Merel).
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What Foods Are Imported From China?

The growing share of imported foods in U.S. supermarkets and restaurants 

presents new challenges for food safety regulators and private decisionmakers (Becker, 2008b). While the U.S. food supply is still overwhelmingly from domestic sources, the share of imported foods has grown steadily 

(Jerardo). The growing presence of imported foods refl ects various trends: 

seasonal demands for produce from warm-weather regions; rising consumer 

demand for ethnic food, beverages, and spices; integration of nontraditional 

regions into global supply chains; and falling agricultural trade barriers. 

China is one of the most prominent examples of the emergence of a nontraditional supplier of food to the United States. Analysis of customs statistics 

shows that the annual value of food shipments from China rose from about 

$1 billion in 1999 to $5.2 billion in 2008 (fi g. 1). Before 1999, the value of 

food imports from China was under $1 billion annually, and in 1999, China 

was the 11th-largest source of U.S. food imports. But in 2008, China was 

the third-largest supplier. The share of U.S. food imports (by value) coming 

from China rose from about 2 percent in the 1990s to 5.8 percent in 2008. 

The value of food imports from China was exceeded only by that of North 

American neighbors Canada and Mexico.3

The rise in food imports from China refl ects robust demand for these products as well as the eagerness of Chinese exporters to supply them. The 

growth coincides with China’s December 2001 accession to the World 

Trade Organization, which not only lowered Chinese tariffs but also helped 

encourage a surge of Chinese food industry investment by both Chinese 

and multinational companies. Investment in China’s food industry has 

been spurred by low labor costs and plentiful supplies of agricultural raw 

materials, like aquaculture products, fruits, and vegetables. Chinese prices 

of fi sh, fruit, and vegetables are as low as one-fi fth to one-tenth of those in 

3If the 27 European Union (EU) 

countries are counted as a single entity, 

imports from the EU also exceed imports from China.

Figure 1

Value of U.S. food imports from China, 1990-2008

$ billion

Note: The definition of food items used here includes edible plant and animal items, 

foods, beverages, and animal feeds. It excludes live animals, live plants, seeds, straw, 

hair, animal guts and bladders, waxes, fuel alcohol, and plants for medicinal uses. The 

definition includes Harmonized System codes 02, 03, 04, and 07-23, except for 1209, 

1211, 1520, 1521, 1522, 2207.

Source: Estimated by ERS from U.S. Customs statistics accessed through 

Global Trade Information Services. 

1990 92 94 96 98 2000 02 04 06 08

0.6

1.6

2.2

2.5

3.0

3.8

4.5

5.2

0.8 0.90.9 0.7 0.60.6 0.7 0.5

1.2 1.3

1.0
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the United States (Gale and Tuan). Processing costs are so low that some 

fi sh, poultry, berries, and other products are imported to China, processed 

in factories along the Chinese coast, and re-exported (Sanchez, Franke, and 

Zecha). The Chinese Government supports agricultural and food exporters 

in various ways. Authorities give tax concessions, provide infrastructure and 

land, arrange low-interest bank loans, organize farmer supply chains, and 

assist exporters in obtaining required certifi cations and registrations (China 

Ministry of Foreign Trade and Commerce; Wang et al., 2009).

Food imports from China include a broad range of items, but about threefourths fall into a few broad categories: fi sh and shellfi sh, juices, canned 

fruits, and other fruit, vegetable, and nut products. Nearly all imports are 

frozen, pickled, or further processed in factories along China’s coast. Few 

unprocessed perishable foods are imported from China due to long distance 

and concerns about disease or pest transmission. Chinese meat and poultry 

have not been approved for import into the United States.4 Bulk commodities 

(grains and oilseeds) are generally not imported from China. While China is 

now an important supplier of apple juice, garlic, canned mandarin oranges, 

fi sh, and shrimp consumed in the United States, imports from China account 

for less than 1 percent of the total U.S. food supply (see box, “Imports From 

China Account for a Small Share of the U.S. Food Supply”).

Fish and shellfi sh (mostly frozen and prepared products) are the largest and 

fastest growing category of foods imported from China. In 2008, fi sh and 

shellfi sh imports accounted for 41 percent of the value of food imported from 

China (fi g. 2). Fish and shellfi sh also accounted for 32 percent of the growth 

in Chinese food imports between 2002 and 2008 (table 1). Import volume 

exceeded 500,000 metric tons in 2008 (double the 2002 volume) and included 

tilapia, eels, cod, scallops, shrimp, prawns, crab, and various other fi sh. 

4In 2006, USDA listed China as an 

eligible exporter of poultry, but Chinese 

exporters could only process and re-export poultry meat sourced in approved 

third countries. However, no eligible 

plants were approved, and subsequent 

legislation prevented implementation 

of the China approval. No trade has 

occurred to date.

Figure 2

Value of U.S. food imports from China by category, 2008

Note: Chart shows share of U.S. food imports from China by value. 

Percentages do not add to 100 due to rounding.

Source: ERS analysis of U.S. Customs statistics.

Fish and shellfish–41%

Fruits, vegetables, and nuts–10%

Juices and other 

products of fruits 

and vegetables

24%

Food ingredients 

and preparations

8%

Pet food, animal

feed–4%

Confections–2%

Tea and spices–3%

Beverages–1%

Meat, dairy,

eggs, honey

1% Grains and oilseeds–2%

Other food–5%
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Most of China’s fi sh and shellfi sh products come from factories in coastal 

provinces that process fi sh and shellfi sh raised in ponds, lakes, or reservoirs 

tended by small-scale farmers. Chinese agricultural statistics indicate that 

fi sh and shellfi sh production doubled over the past decade; about two-thirds 

of production was cultivated, and a third was wild-caught (China National 

Bureau of Statistics, table 7-45). In addition, nearly 40 percent of exports are 

Imports from China constitute a very small share of the total U.S. food supply. The 

most recent estimates show that imports from all countries together constituted 

about 7 percent of the U.S. food supply measured by value in 2005 (Jerardo).1

Our tabulations of U.S. Customs statistics indicate that 5.8 percent of U.S. food 

imports (by value) came from China in 2008. Based on these fi gures, we estimate 

that food imports from China constituted approximately 0.4 percent of the U.S. 

food supply. 

Basic foods that form the core of the U.S. diet—grain, meat, or dairy items—are 

generally not imported from China. Grain and oilseed prices in China are generally 

higher than in the United States, so U.S. imports of Chinese grain are minimal. 

China exports very few dairy products to the United States. Imports of Chinese 

meat are also insignifi cant since China’s meat- and poultry-processing plants have 

not been approved for export to the United States. The United States imports small 

quantities of rice and soybeans from China. Most of the rice is imported by Puerto 

Rico. Soybean imports from China are likely special varieties for direct human 

consumption or for use as organic animal feed.2

China is a major supplier of a few specifi c items, like apple juice, garlic, 

canned mandarin oranges, fi sh, and shrimp. Apple juice imports from China 

totaled 420 million gallons in 2007, which was 60 percent of the U.S. supply. 

Industry reports suggest that the share of garlic imported from China exceeded 

50 percent in 2007 (Weise). FDA reported statistics provided by the National 

Oceanic and Atmospheric Administration that estimated imports from China 

account for 9.6 percent of the U.S. shrimp supply, 1.9 percent of the catfi sh 

supply, and 8 percent of the basa (a type of catfi sh) supply (U.S. Food and Drug 

Administration, 2007d). 

1Jerardo reports that the imported share of food by volume is a higher value of 15 percent. Estimating the share of food imported from China by volume is diffi cult because 

consumption data are unavailable for many of the products imported. Chinese imports 

tend to be “high value” processed products like fi sh fi llets and canned fruit rather than 

“low value” bulk products like grains, oilseeds, and unprocessed meats.

2U.S. soybean exports to China far exceed U.S. soybean imports from China.

Imports From China Account for a Small Share 

 of the U.S. Food Supply

The role of imports from China in the U.S. food supply by value

Item Share Source

Percent

Food imports from all countries as a share of 

U.S. food supply, 2005 7.0 Jerardo1

Share of U.S. food imports that come from 

China, 2008

5.8 Calculated by authors from 

U.S. Customs statistics

Food imports from China as share of

U.S. food supply

0.4 7%×5.8%

Source: Estimated from U.S. Department of Agriculture data.
8

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produced from imported fi sh and shellfi sh that are processed in China and 

re-exported (China Food Industry Net). Sanchez, Franke, and Zecha estimate 

that most U.S. seafood exports to China are re-exported. 

Fruits, vegetables, nuts, juices and other fruit and vegetable products account 

for about a third of the value of U.S. food imports from China. The total 

for this broad category was $1.7 billion in 2008, over four times the value 

in 2002. Most of these products are processed; relatively few fresh produce 

items are imported from China. Perishable items are hard to keep fresh over 

long shipping distances, and U.S. regulations forbid import of some kinds 

of Chinese fresh produce due to concerns about potential disease and pest 

contamination. Moreover, processing costs are low in China. The largest 

component of this category is fruit juice (mainly apple juice), accounting 

for $677 million in 2008.5 Vegetable imports totaled $282 million. Fresh 

and chilled garlic and onions (the most prominent unprocessed vegetable 

5China is a major exporter of apples to 

other countries, but Chinese apples are 

not allowed to be imported to the United 

States due to phytosanitary concerns.

Table 1

U.S. food imports from China by category

HS codes Category 

Main components

2008

value

2002-08

growth

Million $

All foods 5,162 3,531

03, 1605, 1606 Fish and shellfi sh

Tilapia, cod, scallops, shrimp, prawns, 

crab, and other fi sh

2,162 1,148

07, 08, 20 Juices, fruit, vegetable, and nut products

Apple and pear juice, canned mandarins, 

fresh and dried garlic, canned and dried 

mushrooms, frozen vegetables, dried and 

canned beans

1,732 1,365

11, 13, 15, 

18, 1901, 21, 

2301-2303

Food ingredients and preparations

Vegetable saps and extracts, cocoa butter, 

soy sauce, unspecifi ed food preparations, 

malt extract, wheat gluten, and starch

394 276

2309 Pet food and animal feed

Pet snacks and food

193 169

17 Candy and confections 126 80

09 Tea and spices 

Tea leaves, chili powder/paste, ginger

407 252

0409 Honey 6 -2

22 Beverages 

Sweetened water, beer, ethyl alcohol, 

vinegar

30 16

02, 04 (except 

0409), 1602, 

1603

Meat and dairy 

Frog legs, rabbit

26 11

10,12 Grains and oilseeds 

Rice, soybeans

94 88

Other foods 257 141

Note: HS refers to harmonized system of codes for classifying products in international trade 

statistics. “Food” is as defi ned in fi gure 1.

Source: ERS analysis of U.S. Customs data accessed through Global Trade Information 

Services.
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items) accounted for about $70 million (75,000 metric tons), and dried and 

powdered garlic imports accounted for another $36 million (50,000 metric 

tons). Mushrooms and fungi ($110 million)—most in canned, preserved, 

processed, or dried form—are another important vegetable import category. 

Other vegetables imported from China include dried and canned black and 

kidney beans, peas, peppers, and vegetables, like pickled radish, bamboo 

shoots, water chestnuts, and napa cabbage used in Chinese cuisine. Nut 

imports, mainly pine and macadamia nuts, totaled $80 million.

The remaining one-fourth of food imports from China includes a wide 

array of items, like tea, noodles, and vegetable saps and extracts (most of 

which appear to have nonfood uses6), ginseng, pastries, baked goods, soy 

sauce, tofu, beer, and liquor. Many of these items are Chinese specialty 

foods, like Chinese brands of beer and liquor, Chinese-style snacks, and 

cooking ingredients, that are likely sold through Asian specialty stores or 

restaurants. Some are used in Chinese traditional medicines or consumed 

as nutritional supplements.

China is also emerging as a source of ingredients used in food processing. 

Imports of miscellaneous food preparations, malt extract, and protein 

concentrates are small in quantity but could pose a food safety risk if products are adulterated. Wheat gluten is a relatively minor food import, but 

a major incident resulted when its adulteration with the toxic chemical 

melamine in 2007 was linked to pet deaths in the United States. Wheat 

gluten imports more than doubled in 2006 to just under $20 million but fell 

to less than $6 million in 2008 after FDA issued an import alert for Chinese 

wheat gluten in 2007. Pet food and animal feed imports from China totaled 

$193 million in 2008, which consisted of $131 million in pet food and over 

$50 million in poultry feed, additives, and other feeds. 

6Vegetable sap and extract imports from China are split between 

two categories—“substances having 

anaesthetic, prophylactic, or therapeutic properties” (HS1302194040) and 

“other vegetable saps and extracts” 

(HS1302194090).

Fish are often raised in ponds 

where they feed on waste from 

poultry and livestock.
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FDA Refusals of Imports From China 

ERS analyzed data on FDA import refusals of food shipments in order to characterize the types of problems that occur in food imports from China. FDA can 

refuse food imports that appear to be adulterated, misbranded, or fail to comply 

with U.S. labeling requirements or other laws. (USDA’s Food Safety and 

Inspection Service is responsible for meat and poultry imports, but as previously mentioned, Chinese meat and poultry products are not currently exported 

to the United States.) We fi rst analyzed reports of “entry lines” (unique shipments or lots of products or items offered for admission into U.S. commerce) 

that were refused entry into the United States by FDA between 1998 and 2004 

(Buzby et al., 2008). We supplemented that data with more recent reports of 

refusals of shipments from China between 2006 and 2009 obtained from the 

FDA web site.

FDA refusals are a general indicator of the frequency and type of recurring 

problems that appear in food shipments. The refusal reports are administrative records; they are not intended to be a statistical indicator of food safety 

problems, so the data should be interpreted carefully (see box, “FDA Import 

Refusal Data”, p.12). FDA inspects less than 1 percent of food shipments 

destined for the United States, and it performs laboratory examinations on 

an even smaller percentage of shipments.7 The refusal data do not include 

consistent measures of the value or volume of an entry line so we cannot 

calculate the value or share of food imports refused. 

Becker’s (2008b) analysis of FDA refusals for fi scal year (FY) 2007 (October 

2006-September 2007) showed that China’s share of import refusals that 

year—8.6 percent—was more than twice its 3.3-percent share of entry lines 

handled by FDA.8 The fi gures reported by Becker imply that 0.27 percent of 

entry lines from China was refused, higher than the 0.1 percent for all entry 

lines. Although these fi gures indicate that China accounts for a disproportionately large share of refusals, as Becker notes, we cannot draw strong conclusions from these fi gures about the safety of imports from China.

China’s State Council reported a 0.8-percent rejection rate for food shipments 

to the United States in 2006, a fi gure cited by Chinese offi cials as evidence that 

the country’s food exports are overwhelmingly safe. However, this statistic 

hides higher refusal rates for certain products. For example, FDA reports 

that its tests of fi sh and shrimp during October 2006-May 2007 found excessive drug residues in 22 of 89 samples of fi sh and shrimp, a rejection rate of 

25 percent (U.S. Food and Drug Administration, 2007a). Also in 2007, FDA 

reported that 44 percent of wheat gluten samples and 32 percent of rice protein 

concentrate samples tested positive for melamine. All of the positive samples 

were traced to China (U.S. Food and Drug Administration, 2007b).

Our tabulation of monthly FDA refusals of entry lines from China from June 

2006 to February 2009 shows surges of refusals during the early months of 

2007 and in January 2009 (fi g. 3).9 The number of refusals was 80 or higher 

in 6 of 7 months from December 2006 to June 2007, peaking at about 150 in 

April 2007 and 140 in January 2009. The average number of refusals over the 

entire June 2006-February 2009 period was 69 per month. 

7Food and Water Watch reported that 

less than 2 percent of fi sh and seafood 

shipments were inspected by FDA in 

2003-06.

8China’s share of entry lines (3.3 percent) is less than its share of the value 

of U.S. food imports (5.8 percent) that 

we calculated from Customs statistics. 

We found that China was the thirdlargest source of food imports by value, 

but it was only the sixth-largest source 

of entry lines handled by FDA.

9The 2006-09 data were acquired 

from the FDA web site, which posts 

data for 12 months at a time. We began 

collecting the data in May 2007 and 

were able to obtain data beginning from 

June 2006. The 1998-2004 database 

was obtained through an interagency 

agreement (Buzby et al., 2008).
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The 2007 surge preceded the series of incidents that generated wide publicity 

that year. In July and August 2007, FDA issued import alerts for wheat 

gluten and rice protein (following the detection of melamine) and fi ve kinds 

of fi sh and shrimp (following the detection of unsafe levels of toxic veterinary drug residues) from China. The Janury 2009 peak in refusals followed 

an FDA alert issued in November 2008 for products from China containing 

milk due to concerns about melamine adulteration. Over 70 shipments of 

candy, cocoa mixes, cookies, and pet snacks were refused for melamine adulteration during January 2009, up from 7 in December 2008. Melamine was 

cited in 41 refusals during February 2009.

Analysis of the FDA data for 1998-2009 suggests that the surge in early 

2007 was unusual. The more than 1,000 refusals of Chinese products during 

2007 was about 50 percent greater than the 600-700 annual refusals during 

calendar years 2002-04 (fi g. 4). There were unusually few refusals during 

1999-2001—about 150-300 per year versus about 490 in 1998—but this 

pattern followed a general one of lower refusals from all countries during 

Figure 3

Monthly FDA import refusals of food shipments from China

Number

Source: ERS analysis of U.S. Food and Drug Administration import refusal data.

June Jan. July Jan. July Jan.

0

50

100

150

200

2006 2007 2008 2009

Figure 4

FDA refusals of food entry lines from China, 1998-2008

Number

Note: Data are for calendar years. Data were not available for January 2005-May 2006.

Source: ERS analysis of U.S. Food and Drug Administration import refusal data.

1998 99 2000 01 02 03 04 07 08

0

200

400

600

800

1,000

1,200

Fish and shellfish

Vegetables, mushrooms

Fruit products

Other foods
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that period observed by Buzby et al. (2008, p. 7). The 690 refusals during 

2008 were comparable to the number of refusals during 2003-04. Refusals of 

fi sh and shellfi sh products were higher during 2007-08 than in earlier years. 

Refusals of fruit products surged in 2007 before falling in 2008. Refusals of 

vegetable products during 2007-08 were fewer than in previous years. 

The number of refusals from China has not grown nearly as fast as the 

growth of food imports from China noted above. The increase in FDA 

FDA generates computerized Import Refusal Reports that record the product, 

its supplier, country of origin, and the reason(s) that products are refused entry 

into U.S. commerce (U.S. Food and Drug Administration, 2004). Imported food 

must be free from adulteration, be properly and truthfully labeled in English, and 

comply with all other U.S. laws and standards. Buzby et al. (2008) and Becker 

(2008b) provide greater detail on FDA’s import program and the FDA data.

The FDA data must be interpreted carefully since they are not a representative 

sample of all food imports. The data reveal recurring problems that appear in 

imported foods, but they do not indicate the actual level or distribution of food 

safety risk that imports may pose to U.S. consumers. FDA inspects a small 

proportion of food import shipments. Shipments are targeted for inspection or 

other administrative actions to assess existing and emerging problems identifi ed 

by FDA. Thus, the pattern of refusals may refl ect where FDA has focused its 

import alerts and monitoring efforts.

Note that violations cited in import refusals refer to products that appear to be 

adulterated, misbranded, or in violation of laws enforced by FDA. According to 

England (2000) of FDA, “the signifi cance of the appearance standard under U.S. 

law is that the Government is NOT required to prove an actual violation of law or 

the regulations has occurred. Rather, FDA must be able to show that there exists 

an “appearance” of a violation to refuse admission of goods.” 

FDA reports are based on “entry lines”—individual, unique lots of a particular 

food offered for import into U.S. commerce by a particular importer/producer at a 

particular point in time. When FDA refuses an item, it assigns violation codes to 

document the reasons for the refusal (see http://www.fda.gov/ora/oasis/ora_oasis_

viol_rpt.html). Multiple violations can be associated with a refusal of a particular 

entry line. 

The number of refusals posted on the FDA web site (www.fda.gov/ora/oasis/ora_

ref_cntry.html) includes many nonfood shipments because FDA also oversees 

imports of pharmaceuticals, medical devices, and radiation-emitting equipment. 

We deleted records with product descriptions that indicated the shipment contained 

nonfood items. For August 2008, for example, the FDA site shows 146 refusals 

for China, but 100 of those were nonfood entry lines, such as medical equipment, 

cosmetics, televisions, toothbrushes, and nutritional supplements.

The 1998-2004 data included detailed information on refusals, but the newer 

data from the FDA web site included only the product name, supplier name and 

location, and violation codes. The data for 1998-2004 include three types of 

product descriptions describing the shipment, but the more recent 2006-08 data 

only include a less structured product description provided by the importer on the 

shipment invoice. 

FDA Import Refusal Data
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refusals may have been constrained by FDA’s limited resources. The number 

of food entry lines under FDA’s responsibility tripled between FY 1997 and 

FY 2007, and the percentage of shipments inspected has reportedly fallen 

from 8 percent in 1992 to 1 percent in recent years (Becker, 2008b; Schmit). 

Changes in refusals could also stem from differences in reporting procedures 

or from the increased number of inspections (Buzby et al.).

Three Industry Categories Account 

for Most Refusals

Analysis of refusals by industry group shows that three broad categories 

of products—fi sh and shellfi sh, fruit products, and vegetable products—

combined accounted for 70 to 80 percent of FDA import refusals from China 

in recent years (fi g. 5). Whereas, in 2002-04, these three categories accounted 

for about half of refusals for all countries. 

Fish and shellfi sh products were the industry group with the most refusals 

from China, followed by vegetables and fruit products. Fish/shellfi sh share of 

refusals from China doubled from about 20 percent in 2000-04 to nearly 40 

percent in 2007-08. Buzby et al. found that fi sh/shellfi sh and vegetable products had the largest share of refusals from all countries, with about 20 percent 

each. Becker (2008b) reached a similar conclusion in analysis of 2006/07 

data. Food and Water Watch also drew attention to the high incidence of 

safety problems with fi sh and shellfi sh imports from China.

Eels (frozen and/or roasted), catfi sh fi llets, and shrimp accounted for most 

of the refused fi sh/shellfi sh shipments, but a wide variety of other products 

were also refused, including tilapia, tuna, monk fi sh, squid, jellyfi sh, crawfi sh, crab, cod, mackerel, and other fi sh species. Most of these products were 

processed in some manner—frozen, breaded, fi lleted, de-boned, and/or skinless. The large number of fi sh and shellfi sh refusals may refl ect increased 

monitoring of these products that began in 2006 due to chronic problems 

Figure 5

Share of FDA refusals by industry

Percent

Source: ERS analysis of FDA import refusal data and Buzby et al.

2002-04 2002-04 2007 2008

0

20

40

60

80

100

Fish and shellfish products

Fruit, juice and products

Vegetable, mushroom products

Grain/bakery

Sauces, spices, flavorings

Candy

Other foods

Refusals from Refusals from China

all countries
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with veterinary drug residues and unsafe additives in aquaculture products. 

Schmit reported that FDA devoted half of its testing of aquaculture products 

to shipments from China due to widespread problems. In 2006, FDA issued 

an import alert for eels produced in China, and on June 28, 2007, an alert 

was issued for all farm-raised catfi sh, basa (a type of catfi sh), shrimp, dace 

(related to carp), and eel from China (Kraemer; see box, “Import Alert Slows 

Shrimp Imports”). While the alert is in effect, these products are refused 

unless they can be shown to be free of harmful drug residues. Many of the 

import refusals were eels and shrimp covered by this alert.

Refused fruit product shipments included mainly preserved, dried, and salted 

plums, haw (similar to crab apple), goji berries, wolfberries, several other 

types of dried or preserved fruits, and some fruit drinks. Vegetable products 

were the leading refusal category in 2002-04, but the number was markedly 

lower in 2007-08. 

It is not clear whether the reduced refusals of vegetable products refl ected an 

improvement in compliance for these products or whether some other factor 

was responsible. Most vegetable refusals appeared to be products used in 

Asian cuisine. Mushroom and fungus products (dried, boiled, and canned) 

were the predominant vegetable type refused. Others frequently refused 

included bamboo shoots, ginger, and pickled radish and cabbage. Nearly all 

vegetable and fruit product refusals were processed to some extent.

Many of the other refusals from China during 2007-08 appeared to be 

distinctively Asian products. Tofu and soy sauce accounted for most of the 

refusals under sauces/special foods, and soybeans accounted for many of the 

refusals in the nuts and edible seed category. One type of non-Asian food 

with multiple refusals was candy, including bubble gum, candy canes, chewy 

candy, and chocolate. In past years, candy accounted for a relatively small 

share of refusals from China, but refusals in this category rose in 2008. Grain 

and bakery products (including noodles and almond cookies) also accounted 

for a relatively small share of Chinese refusals. Among the “Other food” 

category, common refusals included tea-based drinks and pet snacks. 

Another notable result is the absence of several large import items from the 

refusal list during 2007-08. Several of the largest food import categories—garlic, 

apple juice, and honey—had only a handful of FDA refusals during this period. 

Most Common Violations

FDA has cited over 50 different violations in its refusals of Chinese products, 

but most fall into a few general categories that include general fi lth, unsafe 

additives or chemicals, microbial contamination, inadequate labeling, and 

lack of proper manufacturer registrations.10 Here, we analyzed the FDA data 

on refusals of Chinese food imports by violation for 2002-04 and 2007-08 to 

characterize the types of problems occurring in imports from China (fi g. 6).11

 Our tabulations show the most frequently occurring violations in Chinese shipments. The occurrence of violations in products from all countries for 2002-04 

is shown for comparison. Note that this analysis is based on the total number of 

violations and that many refusals had multiple violations. For example, many 

fi sh refusal reports listed both veterinary drug residues and fi lth violations; each 

of these violations were counted separately in this part of the analysis.12

10Keep in mind that FDA can refuse 

products based on the appearance of a 

violation, so these refusals are in fact 

based on “apparent violations,” but we 

drop the “apparent” in this discussion to 

avoid repetition and enhance readability.

11We combined data for 2007-08 in 

this analysis since the pattern of violations in the 2 years was similar.

12Buzby et al. found the average 

number of violations per shipment to 

be between 1.3 and 2.0 for various 

industry groups.
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FDA issues import alerts on products and shippers that have food safety or other problems 

in violation of the laws enforced by the agency. Alerts can apply to all shipments of a 

particular product from a country or from specifi c fi rms. Firms can have their products 

exempt if they demonstrate to FDA that they have adequate internal quality controls and 

processes in place and can document a history of problem-free shipments.

In 2007, FDA issued import alert no. 16-131 for four kinds of farm-raised fi sh—

catfi sh, basa, dace (related to carp), and eel—and shrimp from anywhere in China. 

The alert was triggered by chronic problems with drug residues in imported fi sh and 

shrimp and was the latest in a series of related alerts issued since 2001 (Acheson; 

Kraemer). During increased monitoring of these products from October 1, 2006, 

through May 31, 2007, FDA found drug residues in 25 percent of the samples it 

tested. The main residues detected included malachite green, nitrofurans, and gentian 

violet (banned in the United States as potential carcinogens) and fl uoroquinolones 

(banned in the United States due to concerns that ingestion by humans might build 

up antibiotic resistance). Malachite green and nitrofurans were also banned in 

China in 2002, but FDA continued to detect residues in some imports from China. 

Fluoroquinolones are permitted for use in China. 

Shipments covered by the alert can be released into U.S. commerce if third-party 

test results or other evidence is provided to prove that the product is free of harmful 

drug residues. By April 2008, FDA had detained nearly 3,000 shipments and 1,387 

had been released into U.S. commerce following laboratory tests (Kraemer). In 

2008, FDA and Chinese authorities formed a working group to focus on improving 

aquatic products’ safety (U.S. Food and Drug Administration, 2007d). 

Analysis of customs statistics suggests that the import alert slowed a surge of 

shrimp imports. U.S. imports of processed shrimp (HS code 160520) from China 

were unusually high during the months preceding the alert. Imports were 6,000-

7,000 metric tons (mt) monthly from September 2006 to January 2007 before 

falling off according to seasonal patterns (see fi gure below). Following the alert 

announced June 28, 2007, imports slowed but did not cease entirely. Imports 

slowed to 2,000 mt or less for July-October 2007 and slowed further in 2008. 

Shrimp imports for 2008 averaged 2,600 mt monthly in 2008, down from over 

4,800 mt in 2006. FDA import refusals of entry lines from China due to veterinary 

drug residues averaged about 15 per month in the 12 months after the import alert, 

almost identical to the average during the 12-month period before the alert. 

Import Alert Slows Shrimp Imports

Monthly U.S. processed shrimp imports from China, 2006-08

1,000 metric tons

Note: Figure shows monthly U.S. imports (HS code 160520) from China.

Source: ERS analysis of U.S. Customs data accessed through Global Trade 

Information Services.

Jan. Mar. May July Sep. Nov.

0

1

2

3

4

5

6

7

8

2006

2007

2008

Import alert

June 28, 2007
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The most common violations during 2007-08 included “fi lthy” and unsafe 

additives, each of which accounted for 20 percent of violations. These violations together accounted for 42 percent of violations for China shipments, 

nearly double the share of violations from all countries (a combined 22 

percent). “Filthy” violations occurred when the food appeared to contain a 

fi lthy, putrid, or decomposed substance (like human or animal hair, feces, 

insects, or dirt), was spoiled, or was otherwise unfi t for food (20 percent 

of violations for 2007-08 and 25 percent for 2002-04). This category also 

included some shipments rejected for containing non-nutritional substances 

or embedded foreign objects. Filthy violations occurred frequently for all 

types of products. Unsafe additives, including colorings or dyes, dulcin, 

cyclamate, and excess sulfi te levels, accounted for 22 percent of 2007-08 

violations. Melamine adulteration is included in this category. Unsafe additives were most common in fruit products. The unsafe additive share of 

violations in shipments from China is much higher than the share among 

shipments from all countries.

Labeling problems accounted for about 22 percent of 2007-08 violations. 

Labeling problems included lack of clear English labeling that truthfully 

identifi ed ingredients, weight or count, nutritional information, and whether 

the food contained artifi cial coloring or sweeteners. Manufacturers’ lack of 

proper registration (for example, when a manufacturer of low-acid canned 

food or acidifi ed food failed to fi le information on its scheduled process or 

register its plant with FDA) accounted for about 10 percent of China shipment violations during 2007-08. This violation was most common for vegetable products, most of which are pickled, dried, or otherwise processed. 

Pesticide residues

Pathogens

Manufacturer lacks registrations

Veterinary drug residues

Labeling problems

Figure 6

Violations cited in FDA refusals of food imports from China1

Percent

Note: Chart shows share of violations in FDA import refusal reports. Many refused 

shipments had multiple violations. 

1For a description of violation codes, see http://www.fda.gov/ora/oasis/ora_oasis_viol_rpt.html.

Source: ERS analysis of FDA import refusal reports. 

2002-04 2002-04 2007-08

0

20

40

60

80

100

Filthy

Unsafe additives

Refusals from China

Other violations

All countries
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The most recent period had a high incidence of veterinary drug residue problems that were likely linked to FDA’s more careful examination of fi sh and 

seafood during that period. Veterinary drug residues are a common problem 

in fi sh and shrimp shipments and were the fourth most frequent category 

of problems overall during 2007-08, accounting for 14 percent of violations. Most fi sh and shrimp imported from China are cultured in ponds that 

frequently have poor water quality. Farmers commonly use drugs to control 

disease and fungal infections in these ponds. Veterinary drug residues can 

also be a problem in other farm animals and their products, such as bees and 

honey. The type of drug residue is not usually reported by FDA, but some 

shipments of honey were found to contain chloramphenicol, an antibiotic that 

is a known carcinogen and has also been linked to aplastic anemia, a rare and 

generally fatal side effect in humans. Nearly all veterinary drug residue violations were in fi sh and shrimp products (the United States does not import 

meat or poultry from China). 

Other types of adulteration included unsafe pesticide residues, pathogens, 

and pathogen toxins. Pathogens appear to be a problem mainly in fi sh and 

seafood shipments. Salmonella was found mainly in fi sh, seafood, spices, and 

fl avorings, and Listeria was found in fi sh and seafood. Other bacteria were 

found on a variety of products. Afl atoxin, a carcinogenic byproduct of mold 

infestations in food crops, was found on nuts, seeds, and candy (which may 

contain nuts). Pesticide residues were a less frequently occurring problem 

during 2007-08, accounting for about 4 percent of violations, down from 

6 percent during 2002-04. Unsafe pesticide residues were found on some 

vegetables and their products: celery, soybeans, lotus, pea pods, mushrooms, 

scallions, ginger, and ginseng. Several shipments of purportedly organic 

beans and berries were refused for unsafe pesticide residues. A number of 

shipments of eels were also contaminated with pesticides.13

Most of the violations fl agged by FDA in imports from China over the 

analyzed periods were problems linked to the processing and handling of food 

products rather than to farm production practices. Filth generally results from 

introducing dirt or foreign materials in unsanitary packing or processing facilities. Unsafe additives are generally added by processors to enhance color or 

fl avor or to preserve products. Unsafe additives are a much more common 

violation among Chinese refusals than those for all countries, and the share of 

unsafe additive violations increased between 2002-04 and 2007-08. 

Lack of English-language labels that clearly describe ingredients is typically 

the responsibility of the manufacturer or packer. Labeling was one of the most 

common problems among Chinese violations (22 percent during 2007-08 and 

14 percent during 2002-04), as it was among shipments from all countries (20 

percent during 2002-04). The share of Chinese violations due to manufacturer 

registration problems declined from 26 percent in 2002-04 to 10 percent in 

2007-08, perhaps refl ecting Chinese regulators’ emphasis on ensuring that 

exporters have proper registrations and certifi cations (described below).

Farm-level problems were cited less frequently. One farm-level problem—

veterinary drug residues in fi sh and shrimp—stands out with 14 percent of 

violations during 2007-08, up from 4 percent of violations during 2002-04. 

FDA has been concerned about veterinary drug residue problems in Chinese 

fi sh and shrimp for some time (Kraemer), but the recent high incidence of 

13A China Central Television investigative report discovered an individual who 

sprayed pesticide on drying fi sh to keep 

insects away. Eels may have been contaminated with pesticides by this practice.
18

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veterinary drug violations may refl ect the 2007 FDA import alert for this issue. 

Unsafe pesticide residues, which stem mostly from farm production practices 

and environmental conditions, also accounted for just 4 percent of violations. 

Farm-level problems like unsafe pesticide residues and heavy metal contamination could be more prevalent than indicated by FDA violations. Toxic 

residues can be detected only through lab tests, so they could be present in 

untested shipments that are rejected for more obvious violations, such as fi lth 

and inadequate labeling. Pesticide residues and heavy metal contaminants 

have been a major concern in China’s exports to Japan and Hong Kong and 

in produce sold in China’s domestic market. Likewise, pathogen problems 

account for a small percentage of violations identifi ed by FDA refusals, but 

these are potentially serious because pathogens may lead to acute and chronic 

illness and premature death. Domestic pathogen-related food poisonings, 

usually linked to school or workplace cafeterias, are a common problem in 

China (Wang et al., 2007).

This extension station sells seeds and other farm inputs, but many 

Chinese farmers purchase from unlicensed dealers who sell 

poor quality seeds and toxic chemicals.
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Efforts To Improve Chinese Food Safety

U.S. and Chinese offi cials are involved in complex multi-pronged efforts to 

address potential safety risks from food imports from China. These efforts 

include inspecting and testing products at the border as well as measures 

to address hazards at their source in processing plants and on farms, an 

approach stressed by the U.S. Interagency Working Group on Import Safety, 

U.S. Congress, and FDA’s Action Plan for Import Safety (Becker, 2008a). 

China’s Food Safety System

Since 2002, Chinese authorities have been attacking food safety problems at 

all points in the supply chain (China State Council). They have stepped up 

regulation and enforcement for both domestic and exported food, but safety 

standards for exports are generally higher and more stringently enforced than 

those for domestic food (Calvin et al.; Dong and Jensen). Domestic food safety 

responsibilities are split among provincial and city agricultural, commerce, 

technical supervision, and health bureaus (see Ellis and Turner, pp. 43-44). 

Export food safety is centralized in the ministry-level General Administration 

of Quality Supervision, Inspection, and Quarantine (AQSIQ) and its provincial branches—known as CIQs—which are directly under AQSIQ’s authority. 

AQSIQ requires that exported food meet domestic Chinese standards as well 

as those of the importing company and country. The CIQ tests product samples 

at the point of export to ensure compliance with safety standards. Beginning 

September 2007, each exported shipment inspected by entry-exit or quarantine 

authorities was required to have a seal from AQSIQ.

Domestic food safety efforts tend to lag behind those directed at exports. 

Chinese offi cials—in response to both domestic and international safety incidents—have stepped up domestic inspection and testing of food, introduction 

and dissemination of standards, and regulation of food producers and have 

initiated other measures aimed at achieving a broad-based improvement in 

the general level of food safety. Some of the prominent measures include the 

following (Calvin et al.; Ellis and Turner; Cadilhon and Hoejskov):

• Restricting agricultural production to areas free of contamination by 

heavy metals, like lead, cadmium, mercury, and arsenic, and controlling 

use of dangerous chemicals in agricultural production.

• Inspecting and testing fi nal products in domestic wholesale and retail 

markets for compliance with chemical residue standards.

• Constructing a vast network of government laboratories to test agricultural products, soil, air, and water in rural areas.

• Setting up hundreds of central and provincial government demonstration 

projects related to “safe” agriculture. 

• Implementing domestic certifi cation programs (some voluntary, some 

mandatory) for food manufacturers and farms. 

• Linking “production bases” (company farms or groups of small farmers) 

with processors or packing houses to standardize agricultural products 

and to control use of chemicals and veterinary drugs. 
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• Setting up a product tracking and tracing system.

• Publishing a “blacklist” of banned food additives.

Approved Exporters

China’s approach to export food safety emphasizes creation of closed supply 

chains limited to elite export-oriented companies and farms that can demonstrate that they have instituted appropriate safety controls and have high sanitation standards, qualifi ed personnel, and control over raw materials to ensure 

safety of their products. AQSIQ requires that exporting companies apply 

to their provincial CIQ for a sanitation registration. The company provides 

information on the production facility, equipment, its products, countries to 

which it exports, water quality and treatment, production process, worker 

qualifi cations, laboratory equipment, raw material sources, and certifi cations 

it has obtained. Exporters of most food products must procure agricultural 

raw materials from a registered “production base”—a farm controlled by the 

company directly or a fi xed group of farm suppliers that supply the company 

with raw materials.14 In order to facilitate “trace back” capability, AQSIQ 

requires exporters to keep production records on their source of raw materials. Producers of raw materials are required to keep records of where products were grown, dates of planting and harvesting, and chemical applications. 

An inspection by CIQ auditors determines whether the company can be certifi ed.15 The closed supply chain approach is illustrated by China’s agreement 

with Hong Kong, which restricts exports to a limited number of Chinese 

suppliers. Shipments must be accompanied by a health/sanitation certifi cate 

and are restricted to certain border crossings where compulsory checks are 

performed (Thompson; Sanchez, Franke, and Zecha). In theory, the registration system limits the pool of exporters to an elite minority of suppliers. 

According to a 2007 report by China’s State Council, only about 12,000 of 

448,000 food processing enterprises in China were approved to export food, 

and only 380,000 hectares out of 121 million hectares of farmland were of 

suppliers approved for growing export crops.

Lists of approved exporters of selected products to specifi c countries are 

posted on the AQSIQ web site (http://english.aqsiq.gov.cn/SpecialTopics/

ImportandExportFoodSafety/DataService/). Some provincial CIQ web sites 

include subsets of the national lists showing exporters from their province, 

but we did not fi nd a master list of all registered exporters. When ERS 

checked the site in March 2009, the English-language section contained lists 

of about 90 companies approved to export aquatic products, 190 companies 

approved to export poultry and eggs, and over 800 fruit packing houses 

registered to export. The site listed companies approved to export vegetables, 

pork, honey, and ginger to Hong Kong, Macao, and Japan. Most of these 

companies are not eligible to export to the United States because China does 

not currently export meat, poultry, or apples to the United States. The lists 

included company name, location, the name and area of the farms supplying 

the company, the provincial CIQ offi ce responsible for that company, and the 

countries to which the company exports. 

In theory, restricting imports to suppliers within the AQSIQ system may 

improve food safety. However, considerable resources will be required to 

continually monitor so many companies and production bases and keep the 

14The Shandong CIQ requires exported spinach and other exported crops 

considered vulnerable to safety problems to be grown on land controlled 

directly by the exporting company.

15During interviews in 2007, representatives of the Liaoning CIQ said that 

over 50 percent of applicants pass the 

initial inspection, about 40 percent are 

required to make improvements, and 

1-2 percent are refused. The CIQ certifi cation must be renewed after 3 years 

(Gale, Avendaño, and Merel).
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information up to date. A journalists’ investigation of the export registration 

in Shaanxi Province noted that some exporters’ monitoring of raw material sources had not kept pace with their upgrade of facilities and expanded 

scale of operations (Yang). Exporter lists on the AQSIQ site were about 2 

years old when ERS checked them in March 2009. The AQSIQ site listed 

over 1,000 export-approved aquaculture “production bases” controlled by 

nearly 400 companies and nearly 400 poultry production bases controlled 

by 90 companies. While these are a small percentage of all producers in 

China, regular inspections and audits of this many companies and farms 

would require substantial human and fi nancial resources. Other diffi culties 

include changes of name and/or location, varying English translations of 

Chinese company names, and multiple companies with the same owner (see 

box, “Profi le of a Chinese Fish Exporter”). Some lists were translated into 

English, but much of the material is published only in Chinese.

To investigate potential problems, ERS cross-checked FDA refusal reports 

with the list of aquatic product exporters. FDA’s import refusal reports 

for August 2008 listed refusals of shrimp at ports in Florida, Los Angeles, 

and New York from two Chinese companies in the city of Zhanjiang in 

Guangdong Province. Neither of these companies was on the list of approved 

aquatic product exporters, although the list included dozens of companies 

in the same city. The web site of one of the companies with rejected shrimp 

(http://www.zjlw.com.cn) notes that the founder owns fi ve seafood companies

with distinctly different names.16 A company with products placed on an

alert potentially could ship the same products under the name of a 

related company. 

AQSIQ uses inducements and punishments to enforce export safety. 

Companies and CIQ offi cials that approve shipments are subject to fi nes for 

shipments that fail to pass inspections in importing countries. AQSIQ established lists of “famous brand” and “inspection-exempt” food exporters. The 

domestic “inspection-exempt” program was abandoned in September 2008 

when milk sold by companies on the list was found to be adulterated with 

melamine. In addition, a “blacklist” of companies with a history of violations 

is banned from exporting (http://www.aqsiq.gov.cn/ztlm/jckspwgqymd/). 

The February 2009 blacklist included 105 companies (up from 66 on the 

December 2007 list), about half of them identifi ed as exporting to the United 

States.17 Fish and eel were the most common products of blacklist companies, but many companies selling vegetable and fruit products were also 

listed.18 Seventy-three blacklist companies were cited for “evading inspection and quarantine.” Other violations included excessive drug and pesticide 

residues; falsifi ed documents; lack of registration in the importing country, 

including products from outside the authorized export base; and switching 

substandard products for compliant ones. An AQSIQ investigation of 

Chinese fi rms placed on FDA import alert in 2007 concluded that the alerts 

resulted from “illegal shipments,” “duplicated reports,” and “discrepancies in 

testing methods” (U.S. Food and Drug Administration, 2008c).

Third-Party Certifi cation

China has differing food safety certifi cation systems for domestic and 

exported food. Food producers serving the domestic market are under 

16None of these company names 

were found on the AQSIQ exporter list 

or in FDA refusal reports, but one company was found on a Canadian import 

refusal report.

17ERS could only fi nd a Chinese version of this list on the AQSIQ web site.

18The blacklist of food product exporters also included listings for many 

cosmetic products. Only 20 blacklist 

companies were identifi ed as exporters to Japan, China’s largest market for 

food exports.
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Fuzhou Kangdeli Fisheries Co., Ltd., is listed on the AQSIQ web site as an 

exporter of basa fi sh. The company lists its main products as roast eel, fi sh fi llets, 

and octopus. It exports to Japan, the United States, South Korea, Singapore, and 

Europe. The Fuzhou region is the source of many refused shipments of fi sh, 

but we did not fi nd this company’s name on FDA import refusal reports. The 

company’s investment is 30 million yuan ($4.4 million), and it is a subsidiary of 

another company. Photos of the processing plant show clean facilities, modern 

equipment, and workers with appropriate protective clothing. 

The company web site displays copies of several certifi cates: 

• A Hazard Analysis and Critical Control Point (HACCP) certifi cate was 

awarded by the provincial CIQ. It specifi es that the certifi cate is for export 

to the United States (HACCP is required for fi sh to be sold in the United 

States) and specifi es the product as frozen roasted eel, but basa is specifi ed 

on the AQSIQ listing. 

• A sanitation certifi cate awarded by the Chinese Government’s accreditation 

agency states: “After audits, your unit complies with requirements for 

companies exporting food.” 

• A certifi cate for ISO-9001:2000 was awarded by CQC (China Quality Center).

The “production base” approved to supply Fuzhou Kangdeli listed on the AQSIQ 

site appears to consist of three separate companies. Some English names had 

misspellings and questionable translations that could cause confusion. The 

suppliers are reported to have areas ranging from 58 acres to 185 acres, but it is not 

clear whether these companies operate their own farms or serve as intermediaries 

that procure fi sh from dozens of small farms or fi shermen. 

The names of the suppliers on the AQSIQ list do not match the suppliers shown 

on the company web site. One photo on the company site captioned “procuring 

raw materials” shows a harbor with dozens of small fi shing boats. Other photos 

show a complex of aging concrete aerated ponds, a series of nets for cultivating 

fi sh in a natural body of water, and several plastic-covered structures in a valley. 

(The English- and Japanese-language versions of the web sites do not display all 

of the photos.) 

Profi le of a Chinese Fish Exporter

Fuzhou Kangdeli Fisheries Co., Ltd.

Minhou County, Minjiang Township

Fuzhou Redland

Ecological Agriculture

Ltd. Co.

58 acres

500 metric tons

output

Fuzhou Wanfa 

Yongchan Ltd. Co.,

Gui’an Chenglong Eel

Farm

158 acres

350 metric tons output

Yongtai County

Chengfeng Minming

Hot Spring Fish Farm

185 acres

1,000 metric tons 

output

Production base
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certifi cation programs developed in China and run by government organizations. A “Pollution-Free” (also known as “no harm” or “safe” food) 

program was introduced in 2001 by the Ministry of Agriculture as a basic 

food safety system for agricultural products. The program certifi es that a 

contiguous “production base” of farms meets environmental standards and 

that products meet domestic standards for chemical residues. A “Green 

Food” certifi cation was introduced in the 1990s as an early attempt to offer 

farm products that meet higher overseas standards. Green Food products 

are exported and sold as premium products in the domestic market. Food 

processors and manufacturers are required to obtain a “QS” (quality-safety) 

certifi cation administered by provincial technical supervision bureaus. The 

QS certifi cation was introduced in 2002 by AQSIQ, which checks the facility’s environment, equipment, personnel, plant layout, sources of raw materials, and monitoring capability. 

Food exporters—usually processing or manufacturing companies—typically 

obtain internationally recognized safety certifi cations like Hazard Analysis 

and Critical Control Point (HACCP), Good Manufacturing Practices (GMP), 

and ISO 9001 (in addition to domestic certifi cations) that are demanded 

by foreign customers or required by regulations in importing countries 

(Buzby, 2003). The Chinese Government now requires exporters of meat, 

poultry, fi sh, frozen foods, and canned food products to obtain HACCP 

certifi cation since it is required in many overseas markets. The Organic 

Food Development Center, affi liated with China’s Environmental Protection 

Agency, is accredited internationally as an organic certifi er, and some 

international organizations also certify organic products in China. China’s 

national accreditation agency has developed standards for Good Agricultural 

Practices (GAP) in partnership with GLOBALGAP, and Chinese authorities are promoting GAP pilot programs for exporters of medicinal crops, 

dairy, vegetables, and other produce (Cadilhon and Hoejskov). About 2,800 

Chinese food companies have attained HACCP certifi cation and about 300 

are certifi ed for GAP. Most of these fi rms are exporters that typically have 

modern facilities, equipment, and management practices.19 Most Chinese 

food companies—those serving the domestic market—lack the prerequisite 

facilities, equipment, and well-designed production processes needed to 

effectively implement HACCP (Zhang and Zhao). 

Companies using HACCP or GAP are certifi ed and periodically audited by 

a third-party organization that sends experienced professionals to assess the 

company’s plans, inspect facilities, make recommendations, and confi rm that 

the management system is properly implemented. Usually companies can 

choose from a pool of third-party certifi ers—companies, governmental body, 

or nongovernmental organizations—that have gained accreditation from the 

relevant government or industry body. 

In China, certifi cations and lab tests are performed mainly by government 

or government-affi liated organizations (Ye). Domestic “pollution-free” and 

“QS” certifi cations are performed by organizations affi liated with provincial 

agricultural or technical supervision bureaus. The sanitation certifi cation for 

exporters is conducted by a team of provincial CIQ auditors, and products are 

tested by CIQ. Only a few private-sector certifi ers and labs have been accredited to work in China.

19Yang noted that some food exporters’ operations were disrupted because 

the companies were not able to integrate 

multiple management systems, such 

as HACCP and ISO 9000. Wang et al. 

describe the experience of a poultry 

company in implementing HACCP.
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HACCP certifi cation for Chinese exporters is performed by provincial quarantine bureaus. CQC, China’s largest certifi cation agency, also 

performs HACCP certifi cations, as well as organic, GAP, ISO 9000, and 

other certifi cations. CQC is nominally an independent entity but was a 

branch of AQSIQ until 2002. Wang and Ren concluded that water quality 

testing in China was beset by technical problems, funding and manpower 

shortages, and selective testing or manipulation of data by offi cials. Both 

overseas and domestic consumers might have greater confi dence in Chinese 

food products if a wider range of certifi ers and labs were given greater latitude to operate in China. Overseas consumers might have more confi dence 

in government-sponsored tests and certifi cations if their results could be 

verifi ed by private-sector third parties.

U.S.-China Consultations

FDA, USDA, and other government agencies have been involved in technical exchanges and training designed to disseminate best practices in food 

safety to Chinese regulators and producers. Exchanges intensifi ed following 

the extensive publicity surrounding import safety problems during 2007. In 

December 2007, U.S. Department of Health and Human Services (which 

includes FDA) and China’s AQSIQ announced an agreement on the safety of 

food and feed (Becker, 2008a; U.S. Food and Drug Administration, 2008c) 

and agreed to take the following actions: 

• Work to use AQSIQ registration and certifi cation processes on certain 

high-risk products intended for import to the United States so that FDA 

can use such registration and certifi cation to inform decisions on the 

admissibility of products.

• Strengthen AQSIQ’s commitment to facilitating timely access for FDA 

inspectors to Chinese fi rms, especially during emergency situations.

• Establish joint training programs for food safety inspectors and 

laboratory technicians.

• Establish a food traceability system in China. 

• Require mutual notifi cation by each country of product safety problems, 

food recalls, and other situations affecting public health. 

In implementing the Agreement, FDA and AQSIQ have worked to increase 

their collaboration in the area of science- and risk-based safety systems, 

engaged in consultations on standards for lab testing, and begun work under 

the auspices of working groups on aquatic products and ingredients. In 

November 2008, FDA opened its China Offi ce, which represented its fi rst-ever 

overseas offi ce. The China-U.S. agreement may improve the information available to U.S. regulators by establishing systems for China’s CIQs to electronically forward company information and test results before shipments arrive at 

U.S. ports. AQSIQ’s information system may eventually develop trace-back 

capabilities to enable it to better identify sources of food-safety problems. 
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Conclusions and Discussion

The rapid increase in food imports from China—and their resilience even 

after widespread negative publicity—refl ects the robust demand for these 

products. It is in the interest of U.S. consumers and Chinese suppliers to fi nd 

ways to ensure a fl ow of safe products from China. Regulators and business 

leaders face stiff challenges in fi nding creative solutions to facilitate trade 

between countries with differing agricultural and legal systems.

There are no simple solutions to addressing the safety hazards since they 

appear to occur in many different types of foods at all links in the supply 

chain. The diffi culty of addressing problems is highlighted by two highprofi le food safety incidents—Chinese dumplings adulterated with toxic 

pesticide in Japan and infant formula adulterated with melamine—that 

occurred in 2008 after widespread publicity and tightened food safety 

vigilance in 2007. The incidents occurred in products of companies with 

well-known brands, HACCP certifi cations, and offi cial Chinese “inspectionexempt” status.

Safer imported food from China and other overseas sources is likely to entail 

higher costs. Zhang and Zhao urged Chinese food companies to build in 

substantial “food safety” costs—investments in sanitary facilities, equipment, water treatment, worker hygiene, changes in production processes, 

and third-party certifi cations. A Chinese poultry company studied by Wang 

et al. (2009) incurred substantial initial investments and higher operating 

costs to implement a HACCP system. Maintaining laboratories, employing 

trained technicians, treating water, and complying with environmental regulations raise operating costs. Many exporting fi rms already have made such 

investments, but most Chinese fi rms have little access to capital, operate on 

thin profi t margins, and frequently cut corners to generate profi ts in China’s 

fi ercely competitive food industry. Similarly, some Chinese farms operate 

according to best practices, but these operations generally require higher 

investment and operating costs than those of conventional Chinese farms. 

China’s restriction on the potential pool of suppliers by requiring rigorous 

certifi cation and eliminating contaminated farmland and water from food 

and fi sh production reduce the fl exibility of companies in choosing suppliers 

and sourcing raw materials, which also raises costs. As safety-related regulations place constraints on Chinese suppliers, China’s cost advantage may be 

eroded to some degree. 

Exported products often bring a higher price than those sold on the domestic 

Chinese market because of the higher costs of strict safety controls and the 

large differential between domestic and world prices (Gale and Tuan; Huang 

and Gale). Because the difference in price is so wide, producers have strong 

incentives to sell inferior products for export produced at lower cost with 

fewer safety controls, which creates a challenge in policing supply chains to 

ensure that unsafe products are excluded.

Private-sector decisionmakers may need to take costly steps that include 

closer relationships with Chinese suppliers, regular audits, third-party certifi cations, and independent testing of products. Reportedly, U.S. companies increased their testing of Chinese products (Schwartz) and audits of 
26

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Chinese suppliers (Newman) following the adverse publicity regarding 

food safety in 2007. The diffi culty of conducting reliable company audits in 

China is highlighted by Harney’s description of “shadow factories,” sophisticated strategies to falsify records, and other means of evading audits by 

foreign customers.20

Consultations and exchanges between U.S. and Chinese offi cials on food 

safety are an important step toward a more coordinated safety/quality control 

system between the two countries (Ellis and Turner). Increased interactions 

may promote each country’s understanding of the counterpart’s food safety 

requirements and differing approaches to food safety control. Food safety has 

been heavily promoted in China since 2002, but Chinese regulators, farmers, 

and private decisionmakers are still learning about international safety standards and practices. 

Training is helpful in raising awareness of standards and good practices. 

Lack of experience and training may hamper the effectiveness of personnel 

who perform laboratory testing, certifi cations, and audits. Informing industry 

participants is especially challenging given the high turnover customary 

among private-sector workers and fl uid rates of entry and exit in China’s 

agricultural and food sectors. Training programs in China often reach only 

technical workers in government organizations; getting information to 

workers on factory fl oors and farmers in the fi eld is a challenge. Offi cials in 

China have developed web sites, published books, and produced videos on 

food safety standards and practices for farmers.21 Government “demonstration projects” post descriptions of safety standards and practices on signboards in fi elds and greenhouses. Given China’s weak agricultural extension 

service, Chinese offi cials rely on an “agricultural industrialization” strategy 

in which agribusiness enterprises transmit technical and market information to farmers, but recent fi eld surveys have found virtually no evidence of 

farmers receiving technical information from companies (Huang et al., 2008). 

Thompson and Hu point out the importance of working with China’s provincial offi cials on food safety oversight issues. Central government offi cials 

set general policies, but it is typically up to local offi cials to carry them 

out. China has sought to centralize export food safety by putting provincial CIQs directly under the authority of the central AQSIQ (domestic food 

safety bureaus are under provincial authorities), but local offi cials still have 

signifi cant responsibilities and autonomy. For example, the CIQ in Shandong 

Province (the main source of vegetable exports) implemented a provincial 

“green card” system to improve vegetable safety following a series of rejections for excessive pesticide residues in Japan. Thompson and Hu emphasize 

that Hong Kong designed its food import program through consultations with 

Guangdong Provincial authorities. 

Initial U.S.-China consultations have focused on fi sh and shellfi sh products, the 

category that stands out with the most problems. Filth and other common problems, such as dangerous additives and labeling problems, appear to be introduced in the processing of products. Training processors in safe food handling 

practices and U.S. labeling requirements, clearly specifying allowable additives 

in contracts, conducting surprise inspections and audits, and requiring thirdparty certifi cations may address frequently encountered problems. 

20Harney discusses audits focused on 

labor practices, but her discussion applies to food safety audits as well.

21It is not clear whether farmers use 

these materials. Anecdotal and limited 

survey evidence indicates that farmers 

in China seldom read newspapers or 

magazines and few have Internet access; they get most of their information 

from television.
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References

Acheson, David. “Food Safety and Food Imports from China,” Testimony 

to Committee on Appropriations, Subcommittee on Agriculture, Rural 

Development, Food and Drug Administration, and Related Agencies, 

U.S. House of Representatives, Tuesday, September 25, 2007, accessed at 

http://www.dhhs.gov/asl/testify/2007/09/t20070925c.html.

Becker, Geoffrey S. Food and Agricultural Imports from China, 

Congressional Research Service report for Congress, updated 

January 2, 2008a, accessed at http://www.nationalaglawcenter.org/assets/

crs/RL34080.pdf.

Becker, Geoffrey S. U.S. Food and Agricultural Imports: Safeguards and 

Selected Issues, Congressional Research Service Report for Congress, 

updated April 16, 2008b, accessed at http://opencrs.cdt.org/document/

RS22664.

Buzby, Jean C., Laurian J. Unnevehr, and Donna Roberts. Food Safety and 

Imported Food: An Analysis Using USFDA Import Refusal Reports, 

Economic Information Bulletin No. 39, U.S. Department of Agriculture, 

Economic Research Service, September 2008.

Buzby, Jean (ed.) International Trade and Food Safety: Economic Theory 

and Case Studies, Agricultural Economic Report No. 828, U.S. 

Department of Agriculture, Economic Research Service, November 2003, 

accessed at http://www.ers.usda.gov/publications/aer828/.

Cadilhon, Jean-Joseph, and Peter Sousa Hoejskov. Quality Standards for 

Fruits, Vegetables and Pork Meat in China and Hong Kong, Working 

document from the Food and Agriculture Organization rapid appraisal 

mission, Regional Offi ce for Asia and the Pacifi c, Food and Agriculture 

Organization of the United Nations, March 2008, accessed October 5, 

2008, at ftp://ftp.fao.org/docrep/fao/010/ai416e/ai416e00.pdf.

Calvin, Linda, Fred Gale, Dinghuan Hu, and Bryan Lohmar. “Food Safety 

Improvements Underway in China,” Amber Waves 4(5):16-21, U.S. 

Department of Agriculture, Economic Research Service, November 2006.

China Central Television. “Bianle Weide Haiwei (Seafood with Altered 

Taste),” Weekly Quality Report, November 29, 2004, transcript available at http://news.enorth.com.cn/system/2004/11/29/000913795.shtml, 

accessed October 5, 2008.

China Food Industry Net. “Aquaculture Product Export Growth Rate Slows 

in 2007 and Development Faces Challenges,” News report, September 3, 

2008, accessed at http://agri.gov.cn/fxycpd/xcp/t20080903_1126060.htm.

China Ministry of Foreign Trade and Commerce. Agricultural Product 

Export Development Plan for 11th 5-year Plan, August 2006.
28

Imports From China and Food Safety Issues / EIB-52

Economic Research Service/USDA

China National Bureau of Statistics. Rural Statistical Yearbook 2006, 

Beijing: China Statistics Press, 2006.

China State Council. The Quality and Safety of Food in China, White Paper, 

August 2007.

Dong, Fengxia, and Helen Jensen. “The Challenge of Conforming to Sanitary 

and Phytosanitary Measures for China’s Agricultural Exports,” Choices

22(1):19-24, 1st quarter 2007. 

Ellis, Linden J., and Jennifer L.Turner. Sowing the Seeds: Opportunities for 

U.S.-China Cooperation on Food Safety, Woodrow Wilson International 

Center for Scholars China Environment Forum, September 2008.

England, Benjamin L. “Import Operations, Policies, and Procedures,” 

Presentation by the Regulatory Counsel to the Associate Commissioner 

for Regulatory Affairs, U.S. Food and Drug Administration, October 27, 

2000, accessed on March 3, 2008, at www.FDA.gov/oia/embslides/importops/sld001.htm.

Food & Water Watch. Import Alert: Government Fails Consumers, Falls 

Short on Seafood Inspections, Washington, DC, May 2007.

Gale, Fred, Belem Avendaño, and Pierre Merel. Developing and Improving 

Techniques and Strategies to Promote Food Safety, USDA Scientifi c 

Exchange Program Trip Report, 2007.

Gale, Fred, and Francis Tuan. China Currency Appreciation Could Boost 

U.S. Agricultural Exports, WRS-0703, U.S. Department of Agriculture, 

Economic Research Service, August 2007, accessed at http://www.ers.

usda.gov/publications/WRS0703/.

Harney, Alexandra. The China Price: The True Cost of Chinese Competitive 

Advantage, New York: Penguin Press, 2008.

Huang, J., Y. Wu, H. Zhi, and S. Rozelle. “Small Holder Incomes, 

Food Safety and Producing and Marketing China’s Fruit,” Review of 

Agricultural Economics 30(3):469-79, Fall 2008. 

Huang, Sophia, and Fred Gale. China’s Rising Fruit and Vegetable Exports 

Challenge U.S. Industries, FTS-32001, U.S. Department of Agriculture, 

Economic Research Service, February 2006, accessed at http://www.ers.

usda.gov/Publications/fts/2006/02feb/fts32001/.

Jerardo, Andy. “What Share of U.S. Consumed Food Is Imported?” Amber 

Waves 6(1):36-37, U.S. Department of Agriculture, Economic Research 

Service, February 2008.

Kraemer, Don. Testimony before U.S.-China Economic and Security Review 

Commission Hearing on Chinese Seafood: Safety and Trade Issues, April 

25, 2008, accessed at http://www.FDA.gov/ola/2008/seafood042408.html.
29

Imports From China and Food Safety Issues / EIB-52

Economic Research Service/USDA

Nelson, Stacey, and Suguro Sato. Update on MRL Violations in Japan 2007, 

GAIN Report No. JA7009, U.S. Department of Agriculture, Foreign 

Agricultural Service, March 2007, accessed at http://www.fas.usda.gov/

gainfi les/200703/146280598.pdf.

Newman, Douglas. “Canned Fruit: China Field Notes,” Unpublished trip 

report, U.S. International Trade Commission, September 2007.

Sanchez, Jorge, Tanya C. Franke, and Amy Zecha. U.S. Seafood Exports to 

China are Re-Exported to Third Countries, GAIN Report No. CH8005, U.S. 

Department of Agriculture, Foreign Agricultural Service, January 2008, 

accessed at http://www.fas.usda.gov/gainfi les/200808/146295431.pdf.

Schmit, Julie. “U.S. Food Imports Outrun USFDA Resources,” USA Today, 

March 18, 2007.

Schwartz, Nelson. “Companies in U.S. Increase Testing of Chinese Goods,” 

New York Times, July 1, 2007.

Schönmann, Jochen. “China Being Poisoned by its Food Industry, Says 

Author,” Der Spiegel, December 18, 2007, accessed at http://www.

spiegel.de/international/world/0,1518,523988,00.html.

Sun, Xiaohua. “SEPA Sets Sights on Polluted Soil,” China Daily, January 9, 2008.

Thompson, Drew, and Hu Ying. “Food Safety in China: New Strategies,” 

Global Health Governance 1(2):1-9, December 2007.

Ting, Cheng. “Thailand Finds Carcinogens in Imported Chinese Produce,” 

Radio Free Asia, August 23, 2007. 

Unnevehr, L.J. “Food Safety Issues and Fresh Food Product Exports from 

LDCs, Agricultural Economics 23(3):231-40, September 2000.

U.S. Congress. Food from China: Can We Import Safely? Subcommittee on 

Oversight and Investigations, staff trip report, September 2007.

U.S. Food and Drug Administration. Data on the numerous individual import alerts 

can be obtained from the FDA Import Alert Retrieval System (FIARS), accessed 

January 2008a at http:// www.FDA.gov/ora/fi ars/ora_import_alerts.html. 

U.S. Food and Drug Administration. “Detention Without Physical Examination 

of Aquacultured Catfi sh, Basa, Shrimp, Dace, and Eel Products from the 

People’s Republic of China Due to the Presence of New Drugs and/or 

Unsafe Food Additives,” Import Alert 16-131, August 8, 2007a, accessed at 

http://www.FDA.gov/ora/fi ars/ora_import_ia16131.html.

U.S. Food and Drug Administration. “Detention Without Physical 

Examination of all Vegetable Protein Products From China for Animal 

or Human Food Use Due to the Presence of Melamine and/or Melamine 

Analogs,” Import Alert 99-29, July 31, 2007b, accessed at http://www.

FDA.gov/ora/fi ars/ora_import_ia9929.html.
30

Imports From China and Food Safety Issues / EIB-52

Economic Research Service/USDA

U.S. Food and Drug Administration. Food Protection Plan: An Integrated 

Strategy for Protecting the Nation’s Food Supply, November 2007c, 

accessed on February 28, 2008, at http://www.FDA.gov/oc/initiatives/

advance/food/plan.html.

U.S. Food and Drug Administration. Home page for “Operational and Administrative 

System for Import Support (OASIS),” October 28, 2004, accessed January 2008b 

at http://www.FDA.gov/ora/import/oasis/home_page.html.

U.S. Food and Drug Administration. “Joint Progress Statement Regarding 

the Five-Year Work Plan Under the Agreement on the Safety of Food and 

Feed,” June 2008c, accessed at http://www.FDA.gov/bbs/topics/news/

international/progress_HHS_China.pdf.

U.S. Food and Drug Administration. “Questions and Answers on FDA’s 

Import Alert on Farm-Raised Seafood From China,” June 28, 2007d, 

accessed at http://www.cfsan.FDA.gov/~frf/seadwpe.html.

Wang, Shijie, Huili Duan, Wei Zhang, and Jun-Wen Li. “Analysis of Bacterial 

Foodborne Disease Outbreaks in China Between 1994 and 2005,” FEMS 

Immunology and Medical Microbiology 51(1):8-13, October 2007.

Wang, Yichao, and Bo Ren. “Waking Up to China’s Water Crisis,” Caijing, 

web edition, September 12, 2007. 

Wang, Zhigang, Huina Yuan, and Fred Gale. “Costs of Adopting HACCP: 

Case Study of a Chinese Poultry Processing Firm.” Review of Agricultural 

Economics, forthcoming 2009.

Weise, Elizabeth. “China’s Budding Food Industry Faces Scrutiny,” 

USAToday, May 22, 2007. 

Wong, S.C., X.D. Li, G. Zhang, S.H. Qi, and Y.S. Min. “Heavy Metals in 

Agricultural Soils of the Pearl River Delta, South China,” Environmental 

Pollution 119:33-44, 2002.

Wu, Yongning. “Food Safety in China: Where Do We Stand?” Presentation 

at Woodrow Wilson Center China Environmental Forum, Washington 

DC, December 2007.

Yang, Chengsuo. “Strengthen Sanitation Supervision for Food Export 

Enterprises.” (in Chinese) China Inspection and Quarantine Times, 02 

December 2008, p. 4. accessed April 2, 2009 at http://cngm.cqn.com.cn.

Ye, Zhihua. “Investigation on Third Party Certifi cation for Food Safety in 

China,” Presentation at International Symposium on Food Traceability, 

Beijing, October 2007.

Zhang, Dingdong, and Guilin Zhao. “Chukou Shipin Qiye HACCP Tixi 

Yingyongde Cunzai Wenti he Duice (Problems and Measures for Foodexporting Enterprises That Must Use the HACCP System),” (in Chinese) 

Presentation, October 11, 2006, accessed June 4, 2008 at http://www.

cnca.gov.cn/rjwzcjgb/haccp/yt/images/20061011/338.ppt.