MORE ON ZIKA PROTECTION FOR EXPORTS TO CHINA

Further Information on Anti-Mosquito Treatment of Exports to China

Wednesday, August 24, 2016

Sandler, Travis & Rosenberg Trade Report

Following an Aug. 18 meeting with officials from China’s General Administration of Quality Supervision, Inspection and Quarantine, the Department of Agriculture’s Foreign Agricultural Service has provided the following additional information on China’s Zika virus-related requirements affecting goods exported from the U.S., which are expected to remain in effect until March 2017. FAS notes that this is not official guidance regarding compliance with these requirements and may change as further clarifications and updates are made available from Chinese authorities. FAS highly recommends that U.S. exporters verify the full set of import requirements with their foreign customers before any goods are shipped.
Certification. All cargo shipments originating from the U.S. must provide proof of disinsection (i.e., killing live mosquitoes, their larvae and eggs) upon arrival at the Chinese air or sea port. This proof must be in the form of a certificate issued by a governmental body or an organization recognized by a governmental body (e.g., licensed pest control companies, fumigation operations licensed to apply pesticides, and registered vessels) and must describe the means of treatment. AQSIQ has provided a template that shows what information must be included on the certificate.
The certification requirement applies to all vessels that left the U.S. on or after Aug. 5. The only exception is for containers kept at or under a temperature of 15⁰C (59⁰F); bulk food, bulk feed, fruits and other commodities are not exempt. Either the vessel or the individual container must be certified, not the goods themselves. If the entire vessel can provide a certificate that it is free of mosquitoes, no additional certificates are needed and no additional inspection needs to be carried out.
All passenger and cargo aircraft departing to China from the U.S. must show proof of disinsection as well. Cargo aircraft should be disinsected prior to cargo loading and passenger aircraft should be disinsected before passengers board.
The certification requirement does not apply to shipments that only pass through the U.S. without loading or unloading. However, it does apply to (1) transshipped goods that originate from another country that is also listed on AQSIQ’s list of Zika-infected countries and (2) goods from a Zika-free country that are loaded in the U.S. before shipment to China.
FAS notes that because measures are not always applied in the same way by local AQSIQ branches it is possible that some certificates will be rejected; e.g., if the issuer of the certificate has a history of issuing certificates for shipments that are later found to carry live mosquito eggs, larva or adults. In such cases the shipment or vessel would need to be disinsected at the port, even if it already received a treatment.
AQSIQ will conduct a Zika risk assessment of Florida and neighboring U.S. states, based in part on the U.S. Centers for Disease Control and Prevention’s documentation of control measures, and depending on the outcome may apply a regional approach in its Zika response. There is no estimate for when AQSIQ might make such a determination.
Treatment. Disinsection treatment may be carried out by physical, chemical or a combination of means and does not require fumigation. Physical means could include trapping, air curtains or other integrated pest management techniques. Chemical means could include surface spraying, space spraying or fumigation. The treatment used should take into account human health and safety. Treatment may be carried out at any point during the shipping process; e.g., it is acceptable for containers to be disinsected before loading, certified as mosquito-free, then loaded in a mosquito-free environment.
AQSIQ has not contacted airlines, shipping lines, exporters, etc., about the treatment requirements and instead leaves it up to each branch office at the port of entry to give out this information.
All shipments found to contain live mosquito eggs, larvae or mosquitoes during inspection at a Chinese port will be subject to disinsection, including shipments that are chilled below 15⁰C (59⁰F). If one container is discovered to contain mosquito larva, eggs or adults, only that container would be disinsected, and possibly other containers from the same batch or origin.
Chinese authorities will direct a third party to perform any required disinsection in accordance with World Health Organization guidelines. The cost will vary at each port of entry, but AQSIQ estimates that it will be about RMB 200 ($30) for a 20-foot container and RMB 400 ($60) for a 40-foot container. The cost for disinsection of an entire vessel would depend on the size and complexity of the treatment, but AQSIQ has indicated that it will be a rare instance when an entire vessel will need to be re-disinsected.