STiR coffee and tea magazine

48 STiR coffee and tea / Issue 4, 2017 (August / September) A spring cleaning of the Food and Drug Administration's (FDA) foreign food facilities database eliminated more than a quarter of registered food suppliers (28%), an unusually high number that possibly foretells even larger reductions of registered foreign- based suppliers in 2018. The FDA database (as of February 2, 2017) listed 149,933 registered food facilities, a number than includes all coffee and tea processing locations in the US. Approximately 47% were outside of the United States (70,976). In the previous purge, done in 2014, only 14% of the food processing firms were deleted. Even more telling is the fact that only 9% of the attrition was do- mestic food facilities. Attrition was very high among foreign suppliers. • Mexico – 53% drop (9,575 down to 4,499 registered food facilities) • China – 46% drop (9,667 down to 5,236) • India – 44% drop (3,455 down to 1,944). • Italy – 39% drop (10,125 down to 6,169) • Canada – 38% drop (6,690 down to 4,169) Attrition, mergers, and forgetfulness all contribute to churn. Foreign firms that cease doing business typically do not cancel their registration, they simply do not renew and are purged. Food facilities located outside the US are now required to designate a US agent for FDA communications in their registration renewal. Many foreign firms did not comply by the Dec. 31, 2016 deadline. A reason for additional concern are provisions of the Food Safety Modernization Act (FSMA) require that all foreign suppliers comply with US regulations. Should an importer become aware FDA Purges Foreign Food Suppliers of non-compliance by one of its approved suppliers, the importer must ensure corrective action is taken. FSMA's foreign supplier verification program requirements are effective next year. At that time US agents of foreign firms that meet the definition of import- ers will have to ensure that food and dietary ingredients imported into the US meet applicable US food safety standards, including having a preventive controls plan in place. The challenge is that foreign suppliers were not previously required to complete a detailed food safety assessment. To be in compliance, exporters must analyze their products for possible hazards, provide product histories and other relevant information and pass that on to US based importers. "Unlike in previous years, individuals or entities listed as US Agents in 2016 were required to confirm with FDA acceptance of their designation and corresponding responsibility," explains Da- vid Lennarz, vp Registrar Corp. "FDA did not consider a facility's 2016 renewal confirmed unless the designated US agent affirma- tively agreed in writing. If a foreign facility submitted its registration renewal but its US agent did not affirmatively agree, its registration was removed from FDA's food facility registration database," he writes. Manufacturing, processing, packing, or storing food for US consumption without a valid FDA registration is a prohibited act, he writes. By Dan Bolton parent company or an outside source, the expectations for Firsd Tea remain the same. "No one's nervous about this," Chen said. "They all have everything in place. It's just a bit more documen- tation. The other companies are doing a very good job. They are all sending what we want." Chen explained that FDA wants to know how the tea is pro- duced before exportation. "And once the tea lands in the US we don't have to do any further processing. If something happens, we would know where the problem occurred." QTrade Teas & Herbs imported approximately 5.2 million pounds of tea blends and another 1.7 million pounds of herbs last year. Teas arrived from throughout Asia while the herbs arrived from all over the world, according to Kanagasunderam. Throughout the year, QTrade reviewed its FSMA compliance for accuracy. "We started this in 2011 [after the law was passed]," Kana- gasunderam said. "Many [exporters] weren't ready then." They are now, she said. "FSMA changed the way people think about food safety. We have federal regulations on good manufacturing practices in food production but it did not address other food safety is- sues. With FSMA, all foods are covered and manufacturers and importers have a clear understanding on what is required and expected. When the requirements are streamlined, it is easy to follow," Kanagasunderam said. "I think this is good because it gives us the opportunity to analyze our programs more closely and see how we can give our customers safe, quality products. QTrade is supportive of any kind of regulation that keeps the food safe." Chen sees importers as the gatekeepers charged with provid- ing transparency in the tea supply chain. "From what I see, the burden is more on the importers' side because it's for them to verify if the information they get is cor- rect and truthful," Chen said. I don't want to rule out the pos- sibility that there are factories who are not in compliance. "Perhaps they chose to do so because it will lower their op- eration cost and in other words, they are able to offer better pricing on certain products. But again, it's up to the importers they want to work with. Big companies naturally offer better quality assurance but when it comes to price, they don't always have the advantage. I think FSMA helps to regulate the market and will be beneficial for big players."

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