Customs’ new customs? Mat Ryan on alcohol, sugar and metals testing for wine imports in China

I last wrote about Mat Ryan of Podium as one of three case studies of people not doing the same old, same old when it comes to selling imported wine (see here and here). Today he shared some info on what seems to be a more intense wine inspection regime in China. He explained the new directive, how the quarantining of bottles works, and how wine is checked for alcohol content, sugar content and three metals — copper, manganese and iron. I have reprinted, with permission, his comments in full below (all highlights are mine).

“Although there have for many years been allowable limits of certain elements present in wine imported into China, it seems that this year, there is a pointed effort to test and reject quite substantial amounts of wine. This has led to quite a lot of confusion over how it works, why are WE being tested, what are the actual allowances, and are they flexible.

“Just last week I met with a senior manager at CIQ (China Inspection and Quarantine) and found out exactly what the current process and regulations are.

“Firstly, I was advised that the directive is to test at least 30 percent of ALL Australian wine coming into China, regardless of the port. I didn’t ask what it was for other regions, but I’m guessing it may be a little less, as it’s only Australian wine I’m hearing issues about on testing failures. That said, ANY wine has the potential to be tested.

“At present, CIQ are also holding two bottles of EVERY wine imported into China, per vintage, per bottle size. They take two bottles and store them in quarantine for six months, as a safeguard against any contamination problems, so that they are available for testing later. We successfully argued against them taking some large format bottles, but there are no arguments against anything else. They take two bottles, hand you a letter, and you can retrieve them in six months. None of these go for testing, unless of course there is a problem down the track.

“CIQ will then randomly select a container for testing. If your container is selected, they will then take another two bottles of the wines to be tested. However, they may or may not test every SKU in that container. If there are only a few numbers of SKU’s, they will most likely all be tested, if it’s over 10 or so, they might test 50 to 75 percent of them. These wines are sent to an independent laboratory, and the results are sent back to CIQ with an approved or rejected stamp. CIQ therefore have surprisingly little flexibility in what they will allow past these testing limits.

“They are testing for three main things ;

“1: Alcohol content. Under Chinese regulations, the alcohol percent has to be within 0.5 percent of what you declare on your Chinese back label. If you have already made and labelled your wines before the testing, and you are off tolerance, you WILL have to redo them. Make sure you know the real alcohol percent of your wine.

“2: Sugar content. Wines are classified according to the following : Dry, semi-dry, semi-sweet, sweet, still. Make sure your importer registers them according to what they are in regards to sugar content. Again, if you’ve already labelled your wines, you will have to redo them.

“3: Metal content. This is the most important one, as there is no way to fix this once it’s here. The metals they are testing for are copper (allowed 1 mg/ litre), manganese (allowed 2 mg / litre) and iron (allowed 8 mg / litre). The Australian Government is arguing that manganese at 2 mg is just too small a limit, and that the safe limit should be much more. However, at the moment, those are the limits, and if you are over, they will be rejected. We’ve found that copper is seemingly present in a lot of fortifieds, due to the old base wine being used having been sprayed in the past, or because of the copper / brass fittings used in the storage and manufacture of these products. TEST THEM ALL BEFORE it leaves.

“If your wines are rejected for metal content, you have two options. Either ship them back, or destroy them under bond. Now either of these methods require a certificate of compliance from Customs to show CIQ that this has been done. Those items affected will then be removed from the official shipment, and a health certificate will be issued by CIQ for the remaining goods, allowing them to be sold. You CANNOT get a partial certificate without a Customs letter. Therefore, if you fail the first test, CIQ will most likely test the second bottle they took to see if that one passes. The problem with this is that it will more than likely also fail, and in the meantime, the other wines are still unable to be sold for the two to three weeks it takes to test. If you fail the first test, the best option is to start looking at your options immediately.

“In order to get the Customs letter of compliance, your goods should either be dispatched back to the country of origin, destroyed, or you can try to ask Customs to “impound them” for you whilst you either consolidate a shipment back, or determine how to destroy them. In theory, Customs only requires you to destroy the bottle, so you could sit in the bonded warehouse with a few friends drinking as much as you can, and then destroy the empty bottles, and the remaining filled ones. Customs are a bit more flexible in what they will and will not allow, so make sure your agent has a very good relationship with them. CIQ are for obvious reasons not allowed to be so flexible, as any mistakes on their behalf can be a health issue.

“So in summary, it’s best to make sure that EVERY wine you ship has been tested for the three items above. Try to label the alcohol correctly on your labels, know what the sugar content is, and be certain that they will test below for heavy metals.”

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