VZCZCXRO1380
PP RUEHCN RUEHGH RUEHVC
DE RUEHBJ #6018/01 2570537
ZNR UUUUU ZZH
P 140537Z SEP 07 ZDK
FM AMEMBASSY BEIJING
TO RUEHC/SECSTATE WASHDC PRIORITY 1807
INFO RUCPDOC/USDOC WASHDC
RUEAUSA/DEPT OF HHS WASHINGTON DC
RUEATRS/DEPT OF TREASURY WASHINGTON DC
RHMFIUU/DEPT OF HOMELAND SECURITY WASHINGTON DC
RUCPDOC/DEPT OF COMMERCE WASHDC
RULSDMK/DEPT OF TRANSPORTATION WASHDC
RUEAWJA/DEPT OF JUSTICE WASHINGTON DC
RUEHRC/DEPT OF AGRICULTURE WASHDC
RHEHNSC/NSC WASHDC
RUEAEPA/HQ EPA WASHDC
RUEHOO/CHINA POSTS COLLECTIVE

UNCLAS SECTION 01 OF 05 BEIJING 006018 
 
SIPDIS 
 
EAP/PD FOR NIDA EMMONS 
HHS FOR OGHA/STEIGER AND PASS TO FDA/LUMPKIN 
USDA FOR FSIS/RAYMOND 
USDA FOR FAS OA/YOST, OCRA/ALEXANDER, OSTA/BRANT AND 
SHNITZLER 
COMMERCE FOR ITA/HIJIKATA AND CINO 
STATE PASS TRANSPORTATION FOR NHTSA ABRAHAM/KRATZKE 
STATE PASS CONSUMER PRODUCTS SAFETY COMMISSION RICH 
O'BRIEN/INTL PROGRAMS 
STATE PASS USTR CHINA OFFICE/TIM WINELAND 
STATE PASS OMB/INT'L AFFAIRS 
STATE PASS HOMELAND SECURITY COUNCIL 
STATE PASS IMPORT SAFETY WORKING GROUP 
 
SENSITIVE 
SIPDIS 
 
E.O. 12958: N/A 
TAGS: TBIO EAGR ECON HHS ETRD BEXP CH JA
SUBJECT: AQSIQ AND STAFFDEL DISCUSS IMPROVEMENTS TO CHINA'S 
EXPORT CERTIFICATION SYSTEM 
 
REF: A. Beijing 5273 
¶B. Beijing 5899 
¶C. Beijing 3210 
¶D. Beijing 3174 
¶E. Beijing 3252 
 
BEIJING 00006018  001.2 OF 005 
 
 
¶1.  (SBU) This report is Sensitive But Unclassified, for 
official United States Government use only and not for 
release to the media. 
 
¶2.  (SBU) SUMMARY:  A Congressional Committee on Commerce 
and Energy Staff Delegation led by investigator David 
Nelson met China's food safety ministerial and regulatory 
authorities August 19-24 to evaluate China's export food 
safety system and examine ways to enhance the safety of 
food exports to the United States. AQSIQ officials 
explained in detail the structure of their "system within a 
system" for export certification and their comprehensive 
electronic management system, even discussing with Staffdel 
additional ways to strengthen China's export regime through 
a dual positive list/blacklist, an "exporter fast-track" 
system that would adjust testing frequency to past 
performance, the possibility of increasing inspection 
rates/audits, and having China-based U.S. inspectors. 
Still, AQSIQ officials were hard-pressed to recap in detail 
the cause of contaminated plant proteins and fishery 
product shipments to the United States earlier this year. 
In another meeting, American Chamber of Commerce member 
firms suggested the United States could benefit from a 
Japanese-style regime that restricted the number of 
eligible exporters and provided for systems audits and 
supplemental testing by both governments. Staffdel members 
gave Chinese officials insight into the draft bill in 
development by the Committee modifying the current Food and 
Drug Act. END SUMMARY. 
 
AQSIQ REPEATS TALKING POINTS -- AGAIN 
------------------------------------- 
 
¶3.  (SBU) General Administration for Quality Supervision, 
Inspection, and Quarantine (AQSIQ) Vice Minister Wei 
Chuangzhong, Director General Wang Daning, and six other 
high-level AQSIQ food safety policy and regulatory 
officials met Congressional Committee on Commerce and 
Energy Staff Delegation led by investigator David Nelson to 
discuss the safety of food exports to the United States. 
Reiterating official talking points, Vice Minister Wei 
recited evidence of the effectiveness of China's export 
certification system and its superior performance compared 
to the U.S. system.  He complained that international press 
attention on this matter was disproportionate to the impact 
of the issue and sometimes factually wrong.  He further 
suggested, as other Chinese officials have in private 
meetings with emboffs and in public fora, that some are 
using the press to promote a protectionist U.S. trade 
agenda.  Wei also complained about specific cases of 
substandard or unsafe U.S. goods, noting that China has 
worked on technical and scientific levels to resolve the 
issues and keep them from the press. (Note: Contrary to 
Vice Minister Wei's assertion, China has released 
information about some of these cases to the press (Ref. 
A), including the names of specific U.S. firms. End Note.) 
Finally, Wei praised the AQSIQ food export certification 
system, suggested that previous problems were due to the 
lack of U.S. understanding of the system, and called on the 
United States to back AQSIQ's existing program.  (Note: 
 
BEIJING 00006018  002 OF 005 
 
 
Chinese ministries have now closely coordinated talking 
points regarding the efficacy of AQSIQ's system and the 
quality rate of Chinese exports versus U.S. exports, points 
that are recited to media and U.S. government 
representatives. (Ref. B) End Note.) 
 
FOOD EXPORT CERTIFICATION: 
A SYSTEM WITHIN A SYSTEM 
-------------------------- 
 
¶4.  (SBU) AQSIQ provided details of their overall food 
export certification system and its structure. Export 
certification is a "system within a system" that isolates 
exported food from the domestic food supply.  The first 
stage of export certification actually begins at the farm, 
part of the "farm-to-fork" surveillance system, with the 
registration of the farm or production facility. In the 
case of farmed fish, the farmer or company that owns the 
pond or pen is required to gain AQSIQ export accreditation. 
This entity may only supply fish to a processor that is 
also accredited with AQSIQ.  With an export certification, 
every step of the production and export process from 
primary production to product acceptance by the final 
exporting company must gain AQSIQ accreditation.  Each part 
of this chain is supposed to know and adhere to Chinese 
standards or the importing country standards, whichever is 
stricter.  The accreditation is done either by AQSIQ or the 
Certification and Accreditation Administration (CNCA), a 
subsidiary of AQSIQ. CNCA is responsible for the sanitary 
registration for those firms engaged in import and export 
of foods.  CNCA also engages in the inspection, auditing 
and approval for food import and/or export firms, 
maintaining the register of approved firms and assuring 
that they meet foreign requirements as necessary. 
 
CHINA HAS AN ADVANCED ELECTRONIC 
SYSTEM -- AND ROOM FOR IMPROVEMENT 
---------------------------------- 
 
¶5. (SBU) Beijing's local Entry and Exit Inspection and 
Quarantine Bureau (CIQ) officials explained in detail the 
process and types documents that accompany shipments in the 
final phase of AQSIQ certification.  First, a local CIQ 
staff member inspects and tests in a CIQ lab every export 
shipment according to specific parameters of both China and 
the importing country.  Second, paper documents attesting 
to the results are returned to the manufacturing or 
processing company. Third, the exporter prepares the entire 
export document portfolio for submission, in person, to the 
local CIQ. The portfolio includes the firm's registration, 
the lab results done on the product to be exported, 
veterinary or phytosanitary certificates, special quality 
certification, shipping documents, and customs forms. The 
CIQ export officer crosschecks the paper documents with an 
electronic database that contains the food exporter 
registration number and the lab test results. The Staffdel 
noted that AQSIQ's electronic certification and filing 
system (incorporating electronic record keeping, 
certificates, and export shipment traceability) is an 
example of an advanced system. The potential exists, 
staffdel leader Nelson said, for it to form the backbone of 
an electronic certification system that would allow U.S. 
inspectors easier, electronic validation, and verification 
of official Chinese documents and possibly limit 
opportunity to produce fraudulent or fake paper 
certificates. 
 
BEIJING 00006018  003.2 OF 005 
 
 
 
¶6. (SBU) AQSIQ officials claimed that the system could be 
used to prevent recurring food safety problems, noting that 
the system could be altered to provide electronic 
information to trading partners so they could independently 
verify documents.  Officials also touted AQSIQ's "positive 
list," a selective list determined in cooperation with 
importing nations to limit the number of exporters. 
Japanese importers employ this type of list for chicken, 
eels, and vegetables. The list includes only those 
importers who can prove they meet the importing country's 
standards. A separate "blacklist" identifies repeat 
offenders that fail to meet these standards. AQSIQ and 
staffdel discussed the possibility of operating a two-list 
system, although the United States currently only accepts 
a "blacklist," not a positive list. The two sides also 
discussed the notion of an "exporter fast-track" system 
that would adjust testing frequency to past performance, 
the possibility of increasing inspection rates/audits, and 
having China-based U.S. inspectors. These methods could 
potentially help close loopholes in China's system. 
 
LOOPHOLES ARE HARD TO PIN DOWN 
------------------------------ 
 
¶7. (SBU) When discussing the weaknesses of the Chinese 
export certification system, officials were hard-pressed to 
answer basic questions about loopholes that were exposed 
when melamine-contaminated plant proteins and farm-raised 
fish with illegal chemical residues were exported to the 
United States. (Note: FDA site investigations in the 
melamine incident (Refs. C, D) and discussions with AQSIQ 
revealed that manufacturers can classify their export 
products as "industrial," exempting them from AQIQ food 
quality export checks; in other words the plant proteins 
in that case were not required to be certified by AQSIQ 
because they were not initially classified as food 
products. End Note.) With regard to fraud prevention, 
officials did not describe AQSIQ's recent measures 
requiring melamine-free certification and inspection in 
addition to export certification for all plant proteins. 
Officials were unable to explain effectively how fishery 
products repeatedly passed quality tests and slipped into 
the export market with levels of residual chemicals not 
allowed by the United States, especially in light of 
China's policy to apply the same level of scrutiny and 
standards regardless of whether the importing country 
accepts the Chinese certification.  (Note: The United 
States does not accept Chinese certification.) 
 
OTHER AGENCIES BLAME AQSIQ 
AND STEER CLEAR OF SUBSTANCE 
---------------------------- 
 
¶8.  (SBU) Discussions with Ministry of Agriculture (MOA), 
Ministry of Health (MOH), and State Food and Drug 
Administration (SFDA), left the delegation frustrated that 
the Chinese side did not have any new ideas to present. 
Chinese counterparts seemed to avoid any opportunity for 
questions and exchange of ideas on how to improve their 
food safety procedures. MOA Market and Information 
Department Director Mr. Zhang Yanqiu led a round table 
discussion with specialists from four MOA departments. 
Zhang repeated many of AQSIQ's facts about export quality 
and described provincial-municipal coordination of primary 
food safety monitoring and supervision.  He noted the 
 
BEIJING 00006018  004.2 OF 005 
 
 
important role played by regional and local authorities in 
coordinating adherence to the four types of quality 
standards pertinent to food/feed producers: national, 
local, industry, and enterprise. When asked about reports 
of wide-scale use of melamine as an additive to plant 
proteins in China, Zhang said that extensive MOA tests have 
only shown isolated cases.  Each ministry representative 
deflected thorny export quality questions by pointing a 
finger at AQSIQ. 
 
JAPAN'S IMPORT SYSTEM AS A MODEL? 
--------------------------------- 
 
¶9.  (SBU) Staffdel met American Chamber of Commerce members 
August 22 at Beijing's Committee on Food and Agriculture. 
The AmCham group acknowledged a lack of regulatory 
enforcement in the standard AQSIQ export certification 
regime.  Two members noted that their firms require 
employees to duplicate surveillance and testing to ensure 
that export product quality meets the demands of their 
customers. Success in quality, another member said, is 
something that requires constant attention.  Member 
companies also focused their comments on AQSIQ's changes to 
suit strict Japanese import requirements.  Some of these 
measures include a restricted number of eligible exporters, 
systems audits, and supplemental testing by both the 
Japanese and Chinese government agencies responsible for 
those food products.  It was noted during the official 
meetings that the additional measures that China currently 
takes for exports to Japan could potentially be applied to 
exports to the United States (e.g., limiting the number of 
approved suppliers would make inspection and adherence to 
quality standards easier to verify). 
 
COMMENT: TRUST BUT VERIFY 
------------------------- 
 
¶10. (SBU) The Staffdel was reassured about the strengths of 
many aspects of China's export inspection system, but left 
wanting additional reassurances that loopholes allowing 
repeated exports of contaminated fish can be eliminated. 
An electronic export certification system has clear 
benefits for AQSIQ's role in China's massive export market, 
with a large decentralized system of 35 CIQs in addition to 
31 mainland local/city Technical Supervision Bureaus (TSBs) 
that provide additional quality monitoring.  One staffel 
member commented that, if Chinese regulatory officials do 
everything they say they do, and one puts aside problems 
like endemic corruption, then the Chinese system is 
qualitatively better than the U.S. system. (This would also 
assume that China's inspectors operate with the same degree 
of integrity, that random or scientific sampling occurs 
from every batch of exported food, and that samples are 
tested in laboratories staffed by dispassionate public 
servants and are appropriately trained and capable to 
perform the required tests, so that their seal represents a 
true certification.)  The missing link is China's assurance 
that their methods of analysis are verifiable and that 
their certification systems can be checked electronically 
to remove the fraudulent paper trails that seem to keep 
appearing.  Staffdel members commented further that China's 
reaction to food safety problems has been "finger-in-the- 
dike." The government's tough talk on food safety has yet 
to catch up to all the exports landing in the United 
States. Importers are going to "get what they inspect -- 
not what they expect." There are few absolutes in China's 
 
BEIJING 00006018  005.2 OF 005 
 
 
existing export system, but flexibility to new approaches 
and verification of results could be the keys to 
improvement. 
 
RANDT