Food safety issues can arise at any stage of the chain. Where oversight of other stages is inadequate, simply issuing hefty fines to individual stallholders treats the symptoms but not the root cause and cannot solve food safety problems.
For a long time, China has prioritised quantity over quality in ensuring agricultural supplies, with quality consistently taking a back seat. Without a shift in this mindset, food safety regulation is unlikely to see any meaningful improvement.
Food traceability is another important means of strengthening food safety, but it remains very difficult in practice: first, the sheer volume of data involved and the absence of specific standards make it hard to achieve information interoperability; second, while farms of a certain scale can be traced relatively easily, the challenge for smallholder farmers is far greater.
Without accurate information, many pesticide residue tests are essentially conducted blindly. Inspectors can only guess which pesticides farmers are likely to have used based on experience, and test accordingly. If the guess is right, the inspection is worthwhile; if it is wrong, the work may prove entirely futile.
In Zhejiang, a farmer who slaughtered a home-raised pig and sold portions of the meat for 700 yuan was fined 50,000 yuan. In Luoyang, Henan, an elderly man was fined 110,000 yuan after earning a mere 21 yuan selling vegetables. Multiple restaurants have been fined 5,000 yuan for adding cucumber shreds to their liangpi (cold-skin noodles)… Stories like these have been cropping up one after another of late, and behind the hefty fines lies a deeper public anxiety about food safety. Are the vegetables at the wet market safe? What regulatory measures are in place? Beyond relying on the regulatory system, what else can consumers do to better protect what ends up on their plates?
On 27 July, Foodthink, in partnership with Tencent News’s programme Yiqilai Laoke, invited anthropologist Zhong Shuru, who researches wet markets and sustainable food systems; Zhang Xueming, an expert lawyer and Executive Director and Deputy Secretary-General of the Beijing Research Society for the Rule of Law in Food and Drug Safety; and Li Jie, a rural entrepreneur, to explore the question of “safety on the tongue” from the perspectives of legal regulation, food traceability and the everyday knowledge of buying fresh produce.
Foodthink will publish the edited transcript of this roundtable discussion in two parts over the weekend. This is the first part.
The discussion also follows our recent involvement in the revision of the Measures for the Supervision and Administration of the Safety and Quality of Edible Agricultural Products in Market Sales. Our proposed amendments were adopted in this revision, meaning that “Dried Fish, Dried Vegetables and Dried Fruit” Can Continue to Be Sold, and we hope that future laws and regulations will become more “accommodating” of smallholder farmers who produce and sell their own goods.
Roundtable Guests
Zhang Xueming
Expert lawyer; Executive Director and Deputy Secretary-General of the Beijing Research Society for the Rule of Law in Food and Drug Safety.
Zhong Shuru
Anthropologist researching wet markets and sustainable food systems.
Li Jie
Cooperative manager; rural entrepreneur who transitioned from being a village-resident worker.
Moderator
Wang Hao
Foodthink editor.
I. Why Is Food Safety Regulation So Difficult?
Wang HaoRecently, an elderly vegetable seller in Luoyang, Henan, was fined 110,000 yuan after earning a mere 21.05 yuan from selling vegetables with pesticide residue levels above the permitted limit (though the penalty was subsequently overturned on appeal). Some argue that food safety is no small matter and that heavy penalties are essential as a deterrent; others maintain that this is a case of disproportionate punishment for a minor offence — a rigid, mechanistic application of the law. So what is the real situation faced by small stallholders when it comes to food safety? Can they be expected to resolve quality problems in the vegetables they sell?Zhong Shuru: First, an individual stallholder may well have no idea whether the produce they sell carries pesticide residues, unless the vegetables come from their own farm. Having visited wet markets across the country, I have found that the provenance of produce at market stalls is remarkably complex. It may come directly from the farmer’s own plot or a nearby farm, shipped straight to the stall; or it may come from a wholesale market, where distribution can involve many tiers — some sourced from major wholesalers, others passing through second- and third-tier wholesalers, changing hands several times before reaching the stall. As a result, stallholders may know very little about what lies behind the produce they sell. If a vendor is heavily fined in complete ignorance of the problem, they are genuinely unfortunate. The fact is that food safety problems can arise at any stage of the chain. The most likely point, of course, is the production stage — that is, cultivation. Issues can also arise during storage, sale and other stages. Seafood and ready-to-eat foods, in particular, may develop safety problems during processing or preservation, whether through deliberate misconduct or inadvertent mishandling. There are also differences in how law enforcement is conducted from place to place. In some areas, when a problem is found, investigators trace the supply chain upstream to the stallholder’s immediate supplier; in others, enforcement officers simply issue the fine directly to the stallholder.
Where oversight of other stages falls short, simply issuing hefty fines to individual stallholders, or trying to bind them with purchase receipts and similar measures, only treats the symptoms and not the root cause — it cannot solve food safety problems.
Wang HaoThe new Measures for the Supervision and Administration of the Safety and Quality of Edible Agricultural Products in Market Sales also requires centralised wet markets to conduct sampling inspections on agricultural products that lack a product quality compliance certificate; only items that pass inspection may be sold. What is the current state of this type of oversight in wet markets?Zhong Shuru: Overall, given the long chain and complex distribution channels, food safety regulation is genuinely complicated. The new regulations require centralised wet markets to conduct sampling inspections on produce sold by small-scale vendors. As far as I know, there are two types of inspection within a wet market. The first is routine sampling: each market has its own inspection team, trained by government authorities. Every day, they use dedicated test strips to check different categories of produce and upload their records; any problems found must be addressed promptly. The second is spot-check inspections, carried out by higher-level enforcement bodies — the Market Supervision Administration. These surprise inspections arrive unannounced and go straight to sampling; they form another important safeguard for food safety in a wet market. In addition, food traceability is an important means of strengthening food safety. I know that in Guangdong, some prefecture-level cities previously attempted to build a traceability system citywide. At each market stall, for instance, you could simply scan a QR code to see which channels and wholesale stages the produce had passed through to reach that stall — even down to the specific origin and, in the ideal scenario, back to a particular farm. Unfortunately, this traceability system faces genuine difficulties in practice. Achieving information interoperability between prefecture-level cities and between major wholesale markets remains extremely difficult; different markets use different traceability approaches, meaning information cannot flow effectively between them, and the trail easily breaks down.
Li Jie: On the issue of agricultural product traceability, having run a farmer cooperative in a village for some years, my experience is that farms of a certain scale can be traced relatively easily. But when the produce comes from smallholder farmers, traceability becomes extremely difficult. Take loofah, for instance — each household grows no more than one mu and eight fen (around 1,200 square metres). The pesticide and fertiliser each family uses differs from the next, and even within one household, the products chosen for one crop cycle may differ from those used in the next. This makes traceability and oversight a real challenge for smallholder farmers.
● This year, national standards for pesticide residues in a range of foods have been successively revised. Foodthink previously examined the impact of the relaxed Chinese chive standards. See Pesticide Residue Limits Relaxed 24-Fold: Can We Still Eat Chinese Chives with Confidence?Wang HaoAs an expert who participated in revising the Law of the People’s Republic of China on Quality and Safety of Agricultural Products, how does lawyer Zhang view the difficulties currently facing food safety oversight of agricultural products?Zhang Xueming: I began researching amendments to the Law of the People’s Republic of China on Quality and Safety of Agricultural Products seven or eight years ago. Two years ago, I was also honoured to take part in the revision review organised jointly by the Ministry of Justice and the Ministry of Agriculture and Rural Affairs. Supervision and regulation of agricultural product quality falls mainly into two parts: the production stage is overseen by the Ministry of Agriculture and Rural Affairs system, while distribution is managed by the market supervision system — the Market Supervision Administration. This division of regulatory responsibility between the two stages has arguably made the challenge of food safety oversight even more complex. The biggest obstacle to regulating quality at the production stage is, in essence, a question of mindset. China is a country of 1.4 billion people; feeding them is the paramount priority. For a long time, therefore, the safeguarding of agricultural supply has prioritised quantity above quality. Performance evaluations of relevant officials focus largely on whether output has increased or decreased. The prevailing mindset places quantity first and quality second; far too often, quality is made to give way to quantity. If quality regulation at the production stage is to work, the first step must be a change of mindset. Without shifting the emphasis away from quantity at the expense of quality, food safety oversight is unlikely to see any significant improvement.
In the distribution domain, the biggest issue is information. The fundamental tool that market regulators rely on to oversee safety and quality is testing. Issues such as pesticide and veterinary drug residue exceedances all require laboratory analysis to confirm. Yet there are nearly 3,000 varieties of pesticide; according to 2015 customs data, imported pesticides alone numbered over a thousand. With so many products available to farmers, can regulators realistically test for every one? Even screening just 20 to 30 would drive up both the financial and time costs enormously. Without accurate information, much of our testing is conducted in the dark. Inspectors can only guess which pesticides farmers are likely to have used on a given crop based on experience, and test accordingly. Broadly speaking, there are established patterns — which pest infestations affect which crops, and what pesticides are typically needed — that can guide inspectors. If the guess is right, the inspection is worthwhile; if it is wrong, the work may prove entirely wasted. This is why obtaining accurate pesticide-use information is critical.
Exactly which pesticides have been applied to agricultural produce? Who holds that information? The Ministry of Agriculture and Rural Affairs system oversees the entire chain — from pesticide manufacture, sale, wholesale and retail, through to application by farmers — and is, in principle, responsible for tracking it. Solving the food safety oversight problem therefore requires closer cooperation between agricultural regulators and market regulators. When agricultural authorities carry out product quality monitoring, they should share that data with market supervision departments. At the review meeting, I put forward precisely this recommendation: regulatory information should be shared. The newly promulgated Law on Quality and Safety of Agricultural Products reflects this well in Articles 13 and 15. But the law has only just been amended, and putting it into practice will take time. Because it involves two departments, the State Council will need to issue specific implementation rules on the sharing of monitoring data.
Speaking of information sharing, there is also the food traceability system that Professor Zhong just mentioned. For the sake of food safety, both regulators and consumers want to know, quickly and accurately, where every link in an agricultural product’s journey came from. At present, however, traceability in the food sector remains genuinely difficult, first and foremost because there are no specific standards for it. The sheer volume of data in the food sector demands enormous databases; without unified standards, even individual bodies that have attempted traceability operate as information silos, unable to effectively integrate information across regions and stages. There is even the possibility of grey-market transactions involving the buying and selling of QR codes — a practice that has been exposed by the media.
On top of that, the information problem extends to food labelling: inaccurate or incomplete labels can themselves cause safety issues. If a food contains sugar but the label does not disclose it, a diabetic consumer may suffer harm; if ingredients are not clearly listed on the ingredient list, a consumer with a relevant allergy could face danger.
II. How Can Ordinary People Protect What’s on Their Plates?
Wang HaoAs outlined above, food safety regulation and governance in this country indeed still face many challenges and problems. Beyond hoping for effective adjustments from the government at the institutional level — in regulation, legislation and so forth — what steps can ordinary consumers take to protect what is on their plates? Please share, from a consumer’s perspective, how you each deal with food safety issues.Zhong Shuru: In everyday life, consumers are actually in a rather passive position. The first issue is one of mindset. I have interviewed many consumers, and I feel their attitude towards food safety is essentially one of “lying flat” — this is simply the way things are, it is hard to change, and if you do run into a problem, consider yourself unlucky… This kind of mentality is very common, and it amounts to surrendering the precious right to protect your own dietary safety. So no matter the current situation, we must adopt a positive attitude, strengthen our awareness of food safety, and strive to take control of our own eating lives. Do not lightly hand the decision of what you eat over to others. Those who have the means to cook should make an effort to prepare their own meals as much as possible; if you always eat out, neither the ingredients nor the processing is under your control, and problems are more likely to arise.\n\nAlso, to eat safely, healthily and well, consumers need to develop their discernment in this area and seek out better sources of food. For instance, I love visiting wet markets; I try to choose locally grown, in-season produce, and I encourage maintaining long-term buying relationships with vendors I know, building mutual trust. This too is a strategy.\n\nBeyond wet markets, you can also explore and learn about channels run by small producers such as Li Jie, purchasing ecologically grown organic produce to elevate the quality of your diet.\n\n● Wet market vendors are masters of their daily trade; cultivating good relationships with them can also bring valuable knowledge and information about food. See Foodthink contributor Zhong Shuru’s earlier article “Why Do We Need Wet Markets? An Anthropologist’s Field Observations.” Photograph: Kong Xiaoyan\n\n
Zhang Xueming: As consumers, to protect what is on our plates, we can learn more about the laws relating to food safety and use legal means to uphold our legitimate rights when problems arise. Consumers should also actively educate themselves about food safety, learn to read food labels, ingredient lists and so on, and develop their own set of effective practices. When opportunities arise, learn as much as you can about agriculture — for instance, choose in-season fruit and vegetables whenever possible and avoid out-of-season produce. Take pesticide residues: because the range of possible pesticide products is so wide, proving something safe or proving it unsafe is equally difficult. Given limited information, we can try to choose fruit and vegetables grown without or with minimal pesticide use. This requires us to understand the characteristics of a given fruit or vegetable: what pest infestations it may encounter during growth, what pesticides may be used, the stages and dosages of application, and so on. In fact, farmers know best which vegetables are safe — learn more from them. Once you truly understand a crop, you can build your own food safety knowledge for the table.\n\nMany people say every day that food safety must be addressed from the source. But where is the true source? This is not just a matter for the Food and Drug Administration and the Market Supervision Administration, nor is it merely an agricultural issue; it involves many government departments and is a question of social co-governance. Alongside continually refining food safety regulatory and governance systems to make them ever more rational, consumers themselves need to take action, building up their own knowledge of everyday food to safeguard our food safety.\n\nTranscript: Hu YunwenUnless otherwise stated, all images are from Foodthink\n\n This article was first published on Tencent News’s programme Yiqilai Laoke\n\n The Foodthink WeChat account has been granted permission to republish this article\n\n Editor: Wang Hao\n\n
Zhang Xueming
