Paulson Policy Memorandum

Meetng China’s Food Safety Challenge

John Kojiro Yasuda

April 2017 Paulson Policy Memorandum

About the Author

John Kojiro Yasuda

John Kojiro Yasuda is assistant professor in the Department of East Asian Languages and Cultures at Indiana University’s School of Global and Internatonal Studies (SGIS). He specializes in contemporary Chinese politcs. Yasuda’s research includes the study of regulatory reform in developing countries, governance, and the politcs of insttutonal integraton. He has published artcles in the Journal of Politcs, Regulaton & Governance, and The China Quarterly. His book, On Feeding the Masses, which examines the politcal roots of China’s food safety crisis, is forthcoming from Cambridge University Press. Prior to joining SGIS, Yasuda was a postdoctoral fellow at the University of Pennsylvania’s Center for the Study of Contemporary China. He received his PhD in Politcal Science from the University of California, Berkeley, an MPhil in Comparatve Government from Oxford University, and his BA in Government from Harvard University.

Cover Photo: Reuters/Aly Song Paulson Policy Memorandum

Introducton

ith over 240 million farmers, Why is China’s food safety system failing one million processors, and and, indeed, becoming worse? Wmany millions of distributors, China has struggled to develop a This policy memorandum argues that natonal food safety regime that can China’s safety-related food failures are efectvely integrate diverse interests a result of the challenges of governing a within a common framework of system of such massive scale. governance. Interviews with Chinese food safety experts reveal a system in In large-scale systems, such as China’s, disarray. Despite concerted state eforts regulators must harmonize local best to fx it, microbiological hazards remain practces with natonal standards, unchecked, supply chain management is coordinate actors in diverse global weak, and policies supply chains, are uncoordinated and navigate across disparate jurisdictonal levels of complexity government. within a farfung bureaucracy. In The number efect, China’s of adulterated challenge is to food complaints develop a coherent recorded by the governance China Consumer framework Associaton in Photo: Flickr/Mitch Altman in a large, 2011 increased by 22 percent from heterogeneous context—one in which 2010.1 Chinese statstcs artfcially regulators must routnely make trade- defate the number of poisonings and ofs afectng feasibility, policy design infate food inspecton pass rates, yet and the applicability of policy to diverse a recent survey conducted by the Pew local conditons. Their choices may well Research Center shows that in 2012 solve some problems but invariably 41 percent of respondents identfed create new ones.3 food safety as a “serious problem”—up from just 12 percent in 2008.2 Food To be sure, all countries face these safety now represents one of the top challenges in policymaking. But in China, three governance concerns of China’s the trade-ofs are more pronounced populaton, along with inequality and because of the country’s sheer size corrupton. and complexity. This memorandum

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contends, therefore, that the Chinese capacity, mismatched standards state’s overreliance on straightorward between politcal sub-units, and centralizaton or decentralizaton principal-agent problems between the (rather than the more complex federal central government and the periphery.5 approach we see in other countries) to But China difers from these other large address regulatory crises exacerbates polites in some important ways. these difcult trade-ofs.4 For one thing, China’s producton base is China faces a situaton where its system more extensive and less developed than its must simultaneously provide for exactng Western counterparts.6 Chinese producton standardizaton (which, in turn, requires practces vary signifcantly from province high levels of centralizaton) while also to province when compared to the EU accommodatng the extensive local and the US.7 Moreover, unlike these diversity of food producton (which other large-scale systems, China lacks a requires high levels of decentralizaton). federal framework that would provide Thus China’s food safety problem a clearer template for regulatory portends a new dynamic in central–local integraton among diverse localites.8 relatons: neither centralizaton nor decentralizaton is sufcient to address Not surprisingly, China has struggled the problem of scale. For instance, a to develop a food safety management decentralized strategy without the strong strategy that can cope with the country’s coordinatng hand of the center will fuel sheer scale. One result is that China’s contnued interprovincial disputes; yet a food safety regulatory system has centralized approach to food safety, by evolved largely as a reacton to recurrent contrast, will be too disconnected from crises. An ad hoc mix of centralizing and local food safety realites. decentralizing policies has emerged, but these ofen end up at cross-purposes, In short, the scale and complexity of further fuelling regulatory conficts. the food safety challenge implies the need for a new multlevel division of This policy memorandum focuses on labor in China between Beijing and local the four dominant strategies currently governments to assure more efectve being employed in China’s food safety and efcient regulatory control. system, all of which have produced lackluster results: (1) the use of China’s food safety system shares many coordinaton bodies, (2) locally directed of the pathologies of scale experienced model producton bases (MPB), (3) in other regulatory systems, such as top-down food safety propaganda the European Union (EU), the United and mobilizaton campaigns, and (4) States (US), and India, which also are regulatory segmentaton that has characterized by stretched regulatory created a less than coherent system.

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Each policy is encountering diferent The memo frst examines the factors challenges: for the coordinaton bodies, that are fueling China’s food safety crisis, the problem is an unclear template putng the emphasis on the problem of for regulatory coordinaton; for the scale. It then turns to each of the four MPBs, it is integraton with a natonally dominant food safety policies the state coherent strategy and standardizaton has employed, ofering a critcal view program; for the campaigns, the of the recent history of implementaton principal shortcoming is poor and efectveness. Finally, it ofers some insttutonalizaton; and for regulatory policy recommendatons for China to segmentaton, the problem is the improve its regulatory system for food narrow applicability of policies. safety.

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The Anatomy of China’s Food Safety Crisis

opular media accounts regularly newly re-vamped China Food and Drug assert that China’s food safety Administraton (CFDA).12 Pproblems are due to a lack of political will or insufficient investment Most critques of China’s food safety in food safety. Yet recent reforms failure focus on run-of-the-mill suggest otherwise. In the last ten governance problems. Some highlight years, the Chinese state has actually the pervasive role of corrupton in spent the equivalent of more than eroding the food regulaton system, $800 million to upgrade monitoring not least because of collusion between facilities, build laboratories, and hire ofcials and local entrepreneurs more food safety personnel.9 who seek to circumvent standards and monitoring, the buying of safety Alarmed by the increasing social unrest certfcatons, and the manipulaton that has resulted from widespread food of food safety audit reports.13 Others contaminatons, both central and local emphasize weak media oversight in ofcials are highly wary of the potental China, or the stll underdeveloped role for massive food safety-related of courts in tort liability as root causes protests. That means for China’s food safety they have strong The sheer size of China’s bureaucracy problems.14 politcal incentves to results in weak monitoring practices address food safety that, in turn, give rise to corruption Stll other critques focus issues. And global and other pathologies of governance. on the problematc scandals involving role of independent Chinese products shipped abroad have regulatory agencies in an authoritarian placed additonal pressure on central state, fragmentaton of the food safety government ofcials to ensure that bureaucracy, and local obstructon that China is not exportng its regulatory resists centralized authority.15 More problems.10 broadly, it has been observed that a general lack of social trust contributes to One result is that China has revised an environment of non-compliance.16 its performance evaluaton system to severely punish ofcials for mass This memo does not suggest that food poisonings. The State Council, China’s food safety problems have China’s cabinet, has created two special nothing to do with corrupton, a lack commissions led by senior leaders to of state capacity, or weak social trust. address food safety issues.11 And in 2013, But it aims to highlight another, ofen the central government established a overlooked dimension—scale—as

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another reason for China’s food safety food was valued at 954.6 billion yuan failures. The sheer size of China’s ($143.2 billion).20 Millions of small bureaucracy results in weak monitoring farmers co-exist in China with so-called practces that, in turn, give rise to dragonhead enterprises, the large-scale corrupton and other pathologies of agricultural companies that emerged in governance. Producton practces vary the mid-1990s as part of a government signifcantly across the country, owing to efort to industrialize the agricultural the immense number of producers and sector.21 In 1996, there were only 5,381 diferences in geography, climate, and such frms, but this number had grown socio-economic conditons. As a result, to over 61,286 by 2006.22 Chinese food producers ofen disregard central policies that do not comport As supply chains lengthened and with local producton realites. became more complex, China’s food safety problems were also Similarly, the very lack of state capacity transformed. Previously, food safety in food safety also stems in part from issues were localized and related to China’s sheer scale. The simple additon questons of hygiene, the accidental of even a single layer of bureaucracy in misuse of pestcides, and unsanitary an already large system can lead to an conditons in restaurants.23 However, exponental increase in personnel and intense market competton and weak substantal distortons and delays.17 monitoring practces, coupled with a thin commitment to food safety, soon During the 1980s, the Chinese led to the emergence of new food safety government pushed forward a series of problems. Natonwide scandals involving initatves to develop the infrastructure deliberate food adulteraton, the for new markets that dramatcally inserton of illegal additves in food, the altered the scale of producton and producton of fake food, and the use of ultmately led to the emergence of new pestcides as food preservatves became regulatory risks. Prior to the 1980s, more common.24 These new problems China faced constant food shortages.18 necessitated a fundamental restructuring So in an efort to stmulate productvity of China’s food safety system. and innovaton in the food sector, food producton was decentralized to local In this context, a nascent, but stll governments, spurring local investment fragmented, regulatory “system” began to in food processing.19 take form in the 1990s. As administratve reforms in the broader economy By 1990, the food industry was the decoupled food producton from the third largest industrial sector in China, state-owned enterprise system, regulatory valued at 144.7 billion yuan ($21.7 control began to concentrate in partcular billion); in 2001, industrial output of nodes in China’s vast state bureaucracy.

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Regulatory authority for food safety numbers of producers. But these ad hoc was shared between the Ministry of remedies cannot be a substtute for more Health, the Ministry of Agriculture, enduring insttutonal solutons, and that the General Administraton of Quality has certainly been the case in China. Supervision, Inspecton and Quarantne (AQSIQ), the Ministry of Commerce, the Second, regulators must consider ofen- State Administraton of Industry and confictng goals when they design policies Commerce, and a host of other agencies that aim to manage the problem of scale. involved in the diferent stages of food A centralized approach to food safety, for producton and distributon. example, may well streamline governance, but it can also fail to integrate local This fragmented system, populated by regulatory bodies into a common food so many responsible agencies, led to safety enforcement program. Conversely, serious gaps in regulatory management, designing a more decentralized system confictng standards, and bureaucratc may well improve the ft between turf wars across levels of the Chinese regulatons, on the one hand, and local government—for example, between food producton, on the other, but ministries, as well not cohere into a as among various This fragmented system, populated by so standardized system of localites. Beginning many responsible agencies, led to serious natonal regulaton. in the early 2000s, gaps in regulatory management, confictng Beijing moved standards, and bureaucratc turf wars. Third, Chinese forward with major regulators must reforms to re-design China’s inadequate assess whether broad-based solutons food safety system to cope with the new to food safety problems in the country realites of China’s increased scale of are practcable, given the problems of producton. geographic and industrial scale. Can a policy be applicable to every producer, The noton that China would need to or only to a specialized subset of elite manage the problem of scale has fgured processors? That is the sort of queston into its policymaking process in several that Chinese policy designers in the food ways: First, regulators must evaluate the safety area must regularly confront. feasibility of policies in terms of their cost and ease of implementaton, taking Because of these many trade-ofs, the into account the urgency of the food development of China’s natonal food safety problem. Instead of undertaking a safety system has been a contested tortuous process of insttuton building, it politcal process about how best to may be more cost-efectve and tmely to manage the problem of scale. How simply launch a food safety campaign as do regulators assess policy feasibility, a way to efect compliance among large design, and broad-based applicability

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in the management of scale? Ofen, annual work plans for ministries this has been driven by technocratc involved in food safety, facilitatng concerns, not economic interests. But communicaton between diferent technocratc disagreements do not ministries and levels of government, preclude ferce politcal contestaton and resolving disputes arising from and disagreement. Some technocrats bureaucratc turf wars. may prefer certain approaches based on cost and ease of implementaton. Others How does this work in practce? A may debate the efectveness of those central coordinatng unit creates a single policy designs. Stll others may queston reference point for the system, and then whether a given soluton can actually addresses the scale problem by reducing serve as part of a natonal, broad-based administratve complexity, streamlining system of regulaton. accountability, and setng clear regulatory goals. When faced with overwhelming In China, this jurisdictonal complex politcal complexity, local process around food obstructonism, and safety has led to a a morass of complex mix of centralizing standards and rules, and decentralizing the centralizaton of policies that have regulatory control by so far failed to using a coordinatng integrate confictng body, in efect, regulatory interests means that China has to efectvely chosen to prioritze manage scale. In Photo: Flickr/Tom Booth standardizaton over fact, because of the politcs that have insttutonal diversity. It is important to emerged around these various trade- note that the coordinatng body initatve ofs, regulatory tensions have led to a does not require a complete overhaul of breakdown in coordinaton and a failed the pre-existng system, but seeks to place food safety system in China. one bureaucratc actor in a leading role.

Centralizaton and Coordinaton And this appeared for a tme to be what China was doing in its food safety Following an infant formula scandal in system. Since the early 2000s, China Fuyang, Anhui province in 2003, China’s has created several such coordinaton frst major food safety initatve involved bodies to establish centralized control the development and strengthening over its fragmented food safety of central-level coordinaton bodies.25 bureaucracy. In 2003, the State Food “Coordinaton” (xietao) entails setng and Drug Administraton (SFDA) was

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formed to coordinate China’s food During this process, the central safety regulatory bodies by reinforcing government in Beijing made a strong hierarchical control and coordinatng push to establish coordinatng bodies local food safety enforcement across at each level of government. In a multple agencies. series of food safety notfcatons, plans, and circulars, local governments But then, owing to a series of failures were instructed by the central involving informaton fow, bureaucratc government to form “leading small competton, and corrupton, the SFDA groups” and “coordinatng bodies.” was swept away in favour of other Food safety authorites were to coordinatng bodies.26 In 2007, the State develop “organizatonal strength and Council formed a special commitee leadership” and set “clear responsibility to address food safety challenges led arrangements” through coordinatng by Vice Premier Wu Yi. Then, in 2009, bodies. the Ministry of Health was designated as the new lead ministry in charge of In the central government’s annual coordinatng regulatory actvity. assessment of food safety work at the provincial level in 2011, 70 out of the Later, in 2010, a Natonal Food Safety 100 points were about achievement Commission was established and led of regulatory coordinaton and the by then-Vice Premier Li Keqiang, which restructuring of food safety management would lead food safety commitees (FSC) in line with central policy aims (see Figure established at each level of government 1). This mandate is echoed in county-level to coordinate regulatory actvites. The assessments of food safety management newest coordinaton body, the CFDA, at the township level, through which the was created in 2013, and reports indicate formaton of an operatng food safety that the agency will likely face similar coordinatng body represented 50 out of challenges in establishing its authority. 100 points (see Figure 2).27

Figure 1. Provincial Food Safety Evaluaton Point Allocaton

Evaluaton Item Points Organizaton and system building 15 Government restructuring measures 55 Develop corporate responsibility 20 Efect of government restructuring measures 10 Extra credit 10 Penaltes (major food safety incident) -20

Sources: Provincial food safety document from author’s personal collecton.

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Figure 2. Township Food Safety Evaluaton Point Allocaton

Leadership/Organizaton Evaluaton 50 points Leadership commitee formed 10 points Districts have FSC 20 points FSC targets established 20 points Work Situaton 50 points Coordinaton 10 points Educaton work 10 points Monitoring work 10 points Meets county FSC plan targets 10 points Launch Trade Market Clean-up 10 points Total 100 points

Sources: Township food safety document from author’s personal collecton.

Coordinating bodies have operated But the Ningxia and Shanghai effectively in some localities, but experiences with coordinatng bodies not everywhere. At the outset of are notable exceptons to the norm. the coordinating body initiative, Indeed, this centralizing initatve has, in the Shanghai FDA, for example, was fact, yielded signifcant problems. The lauded for its success in directing establishment of a single coordinatng the local food safety system. Foreign body, rather than a complete overhaul of experts highlight that local agency’s the food safety system, initally seemed high degree of technical expertise to be an efcient way of circumventng and its significant regulatory bureaucratc turf wars and quickly independence.28 The Shanghai FDA restoring order to a large-scale system. had been successful in insulating Yet ofcials at the provincial, county, the local market from unsafe foods and township levels of government sourced from other provinces, have struggled to understand the role effectively managed food recalls, of coordinatng bodies in food safety and expanded monitoring and governance, which has led to signifcant surveillance networks. The FDA in the implementaton problems. northwestern province of Ningxia had also been successful in coordinating The clear lesson of this experience local food safety efforts, promoting is that centralizaton, when it is not national food safety certification accompanied by a clear template for schemes, and facilitating cooperation coordinaton, actually exacerbates among provincial, county, and regulatory conficts. Chinese ofcials township levels of government.29 have explained that there remains

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fundamental uncertainty about food scandal, which in some localites what the directve to “coordinate” would lead to dismissal, coordinaton entails in practcal terms. Despite falls low on the list of food safety the acknowledged success of their priorites. coordinaton eforts, even Ningxia’s provincial ofcials admit (when asked The ambiguity of the role played by for details) that a major challenge in the coordinaton bodies in food safety facilitatng coordinaton among diferent management is exacerbated by the lack food safety agencies is that coordinaton of a statutory basis for their actvites. is a “sof target” because success New regulatory bodies have been in implementng it cannot be easily formed, but none of the pre-existng measured.30 agencies have writen mission directves or detailed by-laws governing how to Although inspectons, penaltes, and plan coordinated food safety regulaton, food safety campaigns can be counted interact with other agencies, and and recorded in adjudicate conficts food safety reports, between ministries the success of and diferent levels “coordinaton” is of government.32 indeed difcult to assess. Ofcials For example, when complain that it is the new SFDA was tough to evaluate developed, individual whether they bureaucrats simply are facilitatng did not understand “clear lines of how to interact communicaton,” Photo: Flickr/Lucius Kwok and redirect their “inter-ministerial contact,” or “inter- workfows in the new system. A former level planning”—all of which are policy director of the central-level SFDA has directves from Beijing.31 Apart from the described what happened this way: nominal establishment of commitees, “It was frustratng because, of course, most local regulatory ofcials have no we have ‘food’ in our agency name, so real sense of how to actually coordinate people expect us to be in control, but food safety actvites within their no one listened to us. We took all the territorial jurisdictons and between blame from the public, but were never levels of government. Local food safety empowered to do our job.”33 work is presented in an annual report and then evaluated at a higher level. Moreover, since coordinatng bodies However, given that a local ofcial’s do not actually replace pre-existng greatest concern is to prevent a major ministries, inter-agency tensions and

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overlapping regulatory actvites persist. networks efectvely. One specialist has Even afer the establishment of FSCs put the point this way: “commitees at (and more recently, the CFDA), ofcials the provincial level are not competent stll complain that the number of and are too far removed from the ground agencies involved in food safety remains … no one wants to take responsibility.”37 too high: “It is difcult to work with other regulators,” one bureaucrat has Husbandry ofcials in one county, noted. “There are far too many players for example, complained that few in the game and once something leaves of the FSCs understood the major our purview we really can’t manage it.”34 risks involved in pig farming and have litle experience in monitoring local The establishment of yet another distributon networks. Moreover, given organizatonal unit also adds to the limited stafng of these FSCs, the already burdensome reportng monitoring must stll be directed by requirements for ofcials. Agriculture local agencies. One Chinese ofcial and Aquaculture Bureau ofcials asserted, “these guys have no idea describe the FSC as a mere “reportng what they are doing. They don’t do any body.”35 County ofcials assert that of the real regulatory work. They have the reports they prepare for the to depend on the 20 other agencies coordinatng bodies are largely involved in developing food safety.” “politcally driven,” emphasizing hard He then cited an example: “When the targets and development goals decided clenbuterol campaign started, they by higher levels that, in actual practce, didn’t do anything.”38 fail to address China’s real food safety concerns pertaining to water quality, Despite the promoton of the new soil conditons, and technical capacity.36 coordinatng bodies in various localites, In efect, what initally appeared to their functonal role has been sidelined be a quick, cost-efcient approach for purposes of regulatory enforcement. to addressing food safety issues in a In 2011, a natonwide survey of food large, complex bureaucracy has led to safety systems in China’s municipalites increased politcking and confusion. showed that while 60 percent of cites had established a new food safety Local regulators in China ofen contend coordinaton body, 85 percent of these that the centralizaton of food safety cites nonetheless contnued to manage management through these coordinatng food safety through locally guided agencies bodies has the practcal efect of rather than through FSCs or the SFDA.39 disempowering local actors. This, they say, is unfortunate because it is In some countes, with the excepton local players who have the necessary of planning and reportng periods, food knowledge to monitor producton safety commitees seemed to be litle

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more than “empty conference rooms” government. So instead, “coordinaton” for most of the year. One food safety appeared to Chinese decision-makers director compared the role of the FSCs to be a far more politcally palatable to that of the “Japanese emperor”— choice. in other words, a positon with high visibility but limited legal authority.40 Similarly, rather than developing a careful scheme to harmonize standards One concrete indicator of the superfuity and regulatons, which would have of the FSCs is that laboratories and required signifcant tme and efort, technical equipment remain embedded decision-makers chose instead to within individual agencies rather than at emphasize central government- the local FSC. In one county, for example, mandated targets, thinking that this the husbandry bureau purchased an would help to focus food safety eforts expensive laboratory, but contnued to across the Chinese system. But here staf it with its own technical personnel. too, this scale management strategy Said one observer, “the within a large, county has a 3 million As a scale management technique, unwieldy bureaucracy yuan ($450 thousand) coordinatng bodies have engendered yielded a signifcant food safety laboratory, the very type of fragmented regulatory politcal backlash. and [yet] it’s [being politcs that they were meant to resolve. stafed and run by] the So in the process of husbandry bureau, not the FSC. What standardizaton, China’s food safety does that tell you about the FSC’s use?”41 coordinaton bodies have failed to realign interests, complicated As a scale management technique, implementaton of food safety policy, coordinatng bodies have engendered and disregarded the real needs of local the very type of fragmented regulatory regulators. While recent reforms have politcs that they were meant to resolve further empowered and centralized within China’s large-scale bureaucracy. food safety management in the Developing a special pilot agency CFDA and eliminated a number of rather than overhauling the entre food bureaucratc players, coordinaton safety system was thought to be a fast issues at the local-level and between and efectve strategy. Discussions of levels have yet to be resolved.42 developing a new single-agency model were rejected out of hand because of Model Producton Bases the chance of protracted bureaucratc infghtng; that is because food safety A second strategy, compounding the portolios would have had to be problems of the coordination bodies, reshufed across various ministries has been to develop so-called MPBs. and diferent levels of the Chinese This effort preceded the coordination

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body initiative but only began to as key to addressing China’s food safety feature prominently in the state’s food crisis.43 The 12th Five-Year Plan (2011- safety plans in the early 2000s. 2015) emphasizes the establishment of producton bases as a top priority While coordinaton bodies were meant for the central government in Beijing.44 to emphasize standardizaton, China’s The underlying logic of this approach establishment of local MPBs seeks to is that, as farms become larger and leverage diversity in an efort to cope adopt scientfc procedures, food safety with the problem of scale. Given problems will be resolved. the sheer number of producers and heterogeneous producton conditons in At MPBs, farmers are taught new China, policymakers aimed to develop techniques and are closely monitored a decentralizing regulatory initatve, by regulators.45 As of 2007, there were using locally directed model agricultural 24,600 hazard-free producton bases in producton bases as a way to improve China, 593 central-level demonstraton food safety across the country. zones, 100 demonstraton countes, and 3,500 provincial-level demonstraton In terms of cost and feasibility, zones.46 Bases are typically over 25 regulators did not need to develop a acres in size. Training facilites are complex natonal law; they could instead developed on site for contnuing delegate regulatory authority and educaton on food safety procedures. standard setng for certain products to Most sites are equipped with express local governments. As a mater of policy testng equipment for pestcide design, such decentralizaton is meant residues and illegal additves. to encourage local innovaton and intergovernmental learning. Inspectors According to a policy of “one village, could presumably also beneft from one product” (yicun, yipin) provincial local knowledge and would be able to and county governments select villages identfy non-compliers. As each sub-unit to produce a specifed high-value improved food safety, the entre market crop, which is part of an agricultural would then provide an ever higher level branding efort.47 County governments of food safety, albeit incrementally. In develop specialized local protocols. efect, decentralizaton sought to build For example, in one county in Zhejiang efectve governance from the botom-up. province, the agricultural bureau guides farmers in bayberry producton. In a Under the MPB scheme, local county in Sichuan province, producers governments have been encouraged to follow local guidelines on lotus root establish specialized sites for industrial cultvaton and the producton of food producton. State ofcials view specialty “wild pigs.” Given that no modernizaton of the agricultural sector natonal standards exist for these

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local products, local governments are Standards may confict from one place allowed signifcant leeway to design to another and testng procedures from their own policies. MPB to MPB may be irreconcilable. For example, Shandong and Ningxia provinces For purposes of food safety developed diferent protocols for warm management, county-level regulators house producton, making it difcult for have observed that MPBs have made Shandong food producers to enter the it easier to implement regulatons in a Ningxia market. Ningxia agronomists cost-efectve way. Aggregatng farmers were unfamiliar with Shandong’s warm into a base enables regulators to house prototype and were hostle to conduct inspectons regularly, whereas outside experts interfering in Ningxia’s regulators typically must spend several agricultural development. In an interview, days to reach farms scatered all around one executve from Shandong based in a village.48 Crop specializaton also helps Ningxia observed, “of course, the local to enable training sessions.49 When agronomists didn’t like the fact that I had farmers follow a uniform schedule for entered into their territory. They had plantng, pestcide applicaton, and their own greenhouses, but the[se] did the harvest, regulators can identfy not work.”51 problems without overextending their resources. Importantly, MPBs The MPB policy creates additonal ofer increased market access for problems: Some observers have noted local produce and have substantally that interprovincial conficts due to improved farmer incomes.50 In contrast local level experimentaton could pose to the unfamiliar natonal Food Safety a serious impediment to natonal Law, MPBs provide a more practcal integraton.52 One notable example of approach to address immediate food such interprovincial disputes occurred safety challenges through their monthly in 2006, following the discovery of training sessions, which discuss safe excessive carcinogens in turbot fsh cultvaton techniques. from Shandong province. Shanghai, Beijing, Guangzhou and other provincial But the story is not all positve. By governments closed their markets to foregoing standardizaton, the MPB farm-raised fsh from Shandong. policy has raised the queston of whether a patchwork of locally directed The Shanghai FDA sent an investgatve model producton zones can cohere team to investigate fish farming to a natonal regulatory system, much practices in the Shandong cities less to assure safety. Diferences in of Weihai and Rongcheng. During local agricultural projects can lead the course of the investigation, the to regulatory disparites, fueling widespread use of nitrofuran and interprovincial regulatory politcs. chormycelinin was discovered.53

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Shanghai investgators exposed for China’s regulatory development signifcant disparites in how fshery writ large. MPBs are largely used for bases were managed; they then refused local specialty products and do not to allow turbot fsh from Shandong into necessarily serve as a model for more the Shanghai market. In this partcular general food products. Indeed, some case, a series of interprovincial Chinese local ofcials believe that the agreements were eventually brokered to MPB represents an unatainable ideal “harmonize” standards and producton of industrialized agriculture that is ill base management. This eventually led suited to China’s farming context.55 to a lifing of the ban. Many Chinese farming households Another signifcant problem with MPBs is are comprised of illiterate and elderly that these varied local standards can come people, who fnd safe farming techniques into confict with emerging standards of to be burdensome and difcult to learn. safety that are supported by internatonal Elderly Chinese farmers on one base consensus, such as “Good Agricultural declared that they are rarely permited to Practces” (GAP). Local standards may partcipate in training sessions and that indeed improve compliance in some government ofcials largely ignore them respects, but at the cost of confict with during the plantng season. internatonal best practces. Differences in local standards lead to So, a decentralized regulatory conflict, and local solutions scale management Food safety experts may simply fail. strategy has the hold that local beneft of relying on variaton is permissible, but only so local knowledge and local innovaton long as it falls within the parameters to increase compliance with food of internatonally established safety safety requirements. But ultmately, standards. For example, the ChinaGAP the fexibility ofered to localites to II standard, which has fewer critcal experiment with agricultural techniques control points, was writen to assist creates problems for natonal regulatory Chinese farmers in their gradual integraton. Diferences in local transiton to the more demanding standards lead to regulatory confict, GlobalGAP standard.54 But undirected and local solutons may simply fail. local experimentaton with no central guidance could lead to substantal food Food Safety Campaigns safety coordinaton problems and leave China in a worse state. Campaigns represent a third method that China has utlized in the quest for beter Many experts are skeptcal that the food safety. That is because, despite the MPB model is the correct template development of coordinatng bodies

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and MPBs, major food safety scandals country’s Maoist past.56 Food safety contnued to emerge throughout the campaigns can be broadly categorized 2000s. as (1) “strike hard” campaigns (yanda xingdong) aimed at violators and Following a major 2008 infant formula criminals, (2) government rectfcaton scandal, the government launched campaigns (zhengzhi xingdong) aimed campaigns with increasing frequency at instlling discipline in government aimed at unscrupulous producers and and Communist Party ofcials, and (3) malfeasant bureaucrats. As a scale holiday investgaton campaigns (jieri management strategy, campaigns xuncha xingdong). are a centralizing initatve that can be cost efectve and tmely when Strike hard campaigns are initated managing a large, diverse system. Afer at the central and provincial levels all, mass mobilizaton ostensibly cuts and focus on recent food scandals. through administratve complexity. For example, in 2011 a natonwide These eforts are not so much about campaign was launched following the building insttutons, which can be tme discovery of guter oil and clenbuterol consuming, as they are about setng an in pig feed.57 These campaigns serve example, “striking hard” against violators, a dual purpose by restoring faith in and punishing non-compliant individuals. government regulators and instlling confdence among consumers.58 A Intensive bursts of regulatory actvity can typical strike hard campaign involves help to promote a climate of regulatory the arrest of perpetrators of food safety compliance and restore confdence in violatons, food company executves, government. Directed campaigns provide and unlicensed producers.59 Short-term another clear signal from the center that campaign targets feature prominently food safety issues are important and of in the annual work plans of local immediate concern to Beijing. In efect, governments. For example, following a these ad hoc initatves instll policy 2008 melamine scandal, inspectons of coherence throughout a huge country all milk statons for melamine within one like China by realigning incentves county in Sichuan province became a through the threat of punishment. These key task of the annual food safety plan.60 new disincentves do have an efect, at least in the short term. Rectfcaton campaigns, meanwhile, focus specifcally on ofcials. Such Food safety campaigns draw on a long campaigns may be conducted in tandem politcal traditon in China. Campaigns with strike hard campaigns. Ofcials are a common feature of Chinese-style found to be in collusion with food safety governance and refect an inherited enterprises, or who fail to punish non- revolutonary traditon from the compliant companies, are disciplined.

Meeting China’s Food Safety Challenge 16 Paulson Policy Memorandum

In 2012, the Central Disciplinary campaigns” in other contexts, food Inspection Commission—China’s main safety campaigns have only further anti-corruption body and Communist fuelled bureaucratc tensions at Party watchdog—investigated over the lower levels of the Chinese 300,000 cases related to food safety, government.64 eventually disciplining 40,000 officials for regulatory abuse or negligence.61 Since the early 2000s, campaigns have During one recent campaign, been launched each year to target illegal evaluators were instructed to ensure additves, corrupt ofcials, and fake that “officials followed all procedures, food products. But, with litle support did not simplify procedures, did from the central government, much not recognize certifications from of the actual cost of the campaigns is other counties, and kept thorough borne by local governments, giving rise records.”62 to resentment at what is, in efect, an unfunded policy mandate. In interviews, Holiday investgaton campaigns are ofcials in several Chinese countes conducted with a focus on distributon explained that, for many campaigns, points and dining local governments establishments simply do not have prior to signifcant sufcient funds holidays, a tme or the necessary when consumpton testng equipment.65 of food in China is generally expected In the short to increase. term, regulators In additon to emphasize that inspectons, ofcers campaigns do promote food much to restore safety by passing Photo: Flickr/Andrew Hefer confdence in the out informaton pamphlets and making market. Following an incident in one public food safety pronouncements.63 county in Jiangsu province that involved excess pestcide residues, producers From the perspectve of the central asserted that quick acton from Nanjing government, of course, food safety (the provincial government seat) helped campaigns can be a cost-efectve tool to prevent the collapse of food prices.66 to realign incentves across a highly Yet other interviewees highlight that diverse producton system. Yet they are insttuton building will be required for hardly straightorwardly successful. For the long-term preventon of food safety instance, in contrast to the apparent scandals and that campaigns are simply efectveness of China’s “managed not enough.

Meeting China’s Food Safety Challenge 17 Paulson Policy Memorandum

Both of these regulatory objectves The ad hoc nature of the campaigns are important for the development can also contribute to regulatory of a food safety system. However, uncertainty: food safety goals are short-term campaign-style solutons constantly being changed. One ofcial have ofen come into confict with the complained, “we are at a loss as to long-term goal of ratonal regulatory how to handle food safety; there are development. Ofcials increasingly standards, but with campaigns, these queston the efectveness of launching might change or move on.”70 Local so many food safety campaigns.67 government ofcials are concerned by the “one size fts all” nature of Furthermore, aside from countng campaigns, which is sometmes referred up the various references in food to in Chinese as “cutng with a single safety reports to arrests made and blade” (yi dao qie). Ofen, the kneejerk penaltes levied, it is difcult to assess, reactons to food safety scandals by the quanttatvely or qualitatvely, whether central government do not refect local food safety has actually improved as food safety concerns. a result of these campaigns. In many cases, non-compliant food processors For example, during a recent ant- simply move to another locaton and additve campaign, ofcials in one county contnue to produce substandard pointed out that the farmers in their foods. One producer confessed, “the jurisdicton were so poor that it was government usually ofers no real help highly unlikely that additves had even … but [during a campaign], they come been used in producton, yet everyone around and inspect and make you do a was stll subjected to inspectons.71 lot of paperwork … but then go away.”68 Regulatory Segmentaton Ofcials have also admited that the constant barrage of campaigns has The fourth method to improve safety interrupted routne monitoring and involves a process of regulatory surveillance work.69 Because new segmentaton. China’s export sector food safety implementaton measures operates a specialized regulatory regime are stll being writen, food safety that developed independently of the campaigns contnue to take precedence. domestc system in the 1990s. As a During the recent clenbuterol result, the export sector has largely been campaign, for instance, ofcials in one insulated from many of the food safety county had to halt important day-to- management problems that plague the day regulatory monitoring actvites to domestc sector. conduct urine tests in all farms with more than 50 pigs, which included Chinese government reports show that several thousand farms. the inspecton pass rates of Chinese

Meeting China’s Food Safety Challenge 18 Paulson Policy Memorandum

food exported to foreign countries Food safety in China’s export sector is remain high at 99 percent.72 This claim managed by the AQSIQ, which restricts is supported by the 2007 customs the number of exporters by imposing data from foreign governments, which a strict licensing system and also indicate that Japan rejected just 0.58 subjects exportng plants to additonal percent of food imports from China, the monitoring and inspectons.74 EU just 0.2 percent, and the US below 1 percent.73 The relatve efectveness As of 2007, only 12,714 enterprises of China’s export food safety program were formally registered with the results from a decentralizing strategy of AQSIQ registraton system.75 Selected regulatory segmentaton that separates enterprises are assisted in ataining and its export and domestc sectors. maintaining a Hazard-Access Critcal Control Point System (HACCP). The Regulatory segmentaton addresses government established a development the challenge of managing scale by fund for export brands to help frms reducing the size and complexity of the with marketng eforts abroad and to system. Limitng the procure professional system to a certain Ofen, the kneejerk reactons to assistance in brand class of producers food safety scandals by the central development. Training facing similar market government do not refect local food is ofered to all export pressures and food safety concerns. enterprises in a range safety risks facilitates of areas to enhance the development of food safety policies technical standards, food safety that are beter aligned with producer monitoring, and the atainment of interests. This process can be broadly internatonal certfcatons. characterized as “decentralizing,” because it foregoes the creaton of a Chinese regulators and producers single system of regulaton, instead do acknowledge that the cost of creatng smaller, ring-fenced systems implementing a segmented export that operate according to an entrely sector strategy is high. However, diferent regulatory scheme. they agree that the small-scale and exclusivity of the export sector leads Segmentaton may be used to to a more responsive and efficient implement regulatory controls gradually market. Because investments in where comprehensive reform is food safety are signifcant, exportng impractcal—for example, because of producers must sell their products at high costs or lack of technical capacity. A a higher price. In the domestc sector, closed regulatory system also allows the pervasive mistrust of food producton government to tailor the food sector to and the weak regulatory system mean more exactng safety controls. that consumers are unwilling to pay a

Meeting China’s Food Safety Challenge 19 Paulson Policy Memorandum

premium for quality food. In the export system also enables AQSIQ to closely sector, by contrast, government ofcials monitor a select number of licensed and third party actors more closely farmers rather than dissipate its limited monitor producers to preserve consumer resources to cover 240 million farmers confdence and justfy high prices. who ofen use non-standard producton methods. A separate export sector Importers, in fact, support the reduced regulatory regime also permits focused scale of the Chinese export system, and direct investment in food safety for preferring to work with an elite set of high-value products. reliable producers that can supply high quality and safe food. EU companies But even in this fourth area, there are work directly within China’s export problems in China’s efort to manage licensing system and refuse any product scale. Rather than solve China’s scale that does not comply with AQSIQ’s problem, segmentaton simply sidesteps stringent food safety requirements. the nature of its food safety governance Moreover, EU food safety ofcials would challenge. Some internatonal observers prefer that the volume of trade from contend that China’s export sector can China be reduced in order to ensure serve as a model for its domestc food higher levels of food safety.76 Japanese safety system, as Chinese exporters also food safety ofcials permit only a subset begin to supply their domestc market.79 of China’s licensed export enterprises to But extending a system based on export food to Japan. segmentaton to such a diverse producer base facing diferent market conditons Chinese ofcials maintain that the would be problematc. use of a closed export system is highly suited to the country’s current stage of For one, regulators in the domestc development. China’s own domestc sector simply do not share the same standards are less exactng than those of risk management perspectves as those most of its trading partners, partcularly in China’s export sector. Exporters who Japan and the United States.77 seek to enter the domestc market assert that domestc regulators are In short, creatng a separate controlled considerably less professionalized than system for exports provides China their counterparts in the export sector.80 with the necessary fexibility to tailor its export food sector to the specifc Domestc ofcials set unrealistcally high requirements of overseas importers. food safety standards for unfamiliar For example, China adopts Japanese products and resist the introducton labelling requirements and employs of new products even from reputable Japan’s quality standards for product producers. One Chinese exporter size, shape, and color.78 The closed commented in an interview that,

Meeting China’s Food Safety Challenge 20 Paulson Policy Memorandum

“they aren’t that well trained and high risk of microbial contaminaton, create unrealistc standards to protect farmers must operate according to strict themselves.”81 An internatonal food safety schedules and standardized procedures. auditor complained, “More must be done to ensure that standard setng is based on Local producers resent the overbearing, scientfc risk analysis, and the integrity of ill-informed, and costly surveillance testng procedures is protected.”82 programs of large multnatonal corporatons, and are known to actvely Ofcials do support a “scientfc” approach subvert food safety protocols. Thus most to regulaton, but they are unwilling export managers conclude that China’s to relinquish control over regulatory careful and detailed export practces processes to technocratc experts. cannot be replicated in the uncontrolled Exporters complain that local government domestc sector. One exporter observed, ofcials in the domestc sector do not “the domestc market is not really respect the impartality of scientsts.83 capable of meetng such standards … pursuing standards would bankrupt China’s food exportng enterprises also the vast majority of farmers … so real express reservatons about entering the bleed into the domestc sector is not domestc sector due to the persistent possible.”86 resistance of farmers to food safety practces.84 Executves cite low levels Ultmately, global best practces cannot of educaton, lack of exposure to be easily difused, nor can export global food safety standards, and the producers easily control local producer lack of experience with supply chain networks. Regulatory segmentaton may management among the country’s integrate regulatory interests on a limited domestc producers.85 Given the short scale, but will surely fail as a broad-based shelf life of most food products and the soluton to China’s food safety dilemma.

Meeting China’s Food Safety Challenge 21 Paulson Policy Memorandum

A Beter Way Forward

he fact is, China has been unable Decentralization through model to develop a scale solution agricultural production bases may Tfor its food safety crisis that produce a better fit for regulatory accommodates conflicting regulatory rules and local food production interests. Problems continue to contexts. But there is no mechanism plague the feasibility of the four basic in place to assure that local projects policy approaches outlined in the will cohere to a national food safety last section—and their broad-based system. applicability (see Figure 3). Launching national campaigns is a Centralization through coordination cost-effective approach to manage bodies may streamline authority but scale and realigns incentives through this approach often alienates local mass mobilization. Yet the increasing officials. Moreover, to date, such frequency of the campaigns reduces coordination bodies lack adequately their effectiveness and impedes qualified personnel and implementing institution building for day-to-day food guidelines. safety management.

Figure 3. The Trade-ofs in Scale Management Cost/Feasibility Policy Design Applicability Coordinaton Implementaton of Streamlines authority, but Natonal body “coordinaton” policies alienates local ofcials unclear Model Central government released Uses local knowledge to Elderly, producton from primary responsibility; advantage, but can lead to illiterate, base focused implementaton at interprovincial confict small-scale local level makes it easier farmers excluded Campaigns Cost-efectve alternatve to Short-term improvements in Natonal insttuton building consumer confdence, but long-term consequences for insttuton building Segmentaton Focused implementaton Specialized regime focused Barriers more manageable; aligns on elite producers; tailored to policy regulatory interests despite to food safety needs of difusion high costs importers.

Meeting China’s Food Safety Challenge 22 Paulson Policy Memorandum

Regulatory segmentaton reduces previous policies mix with new agencies administratve complexity by creatng and regulatory actors. The old SFDA focused regulatory regimes that are ofces, which were stripped of their ring-fenced to deal with the specialized coordinatng role in 2008, co-existed needs of a partcular sector; this makes with the new FSCs. The recent 2013 food it easier to implement policies. And safety re-organizaton created a new yet the closed nature of a segmented regulatory framework. This included the approach makes it difcult to expand it establishment of the Natonal Health and to other contexts—for example, from Family Planning Commission, which is in the export sector to the domestc sector. charge of developing standards, and a restructured CFDA, which is responsible Each food safety approach has its for the implementaton of food safety strengths but cannot serve as the laws. In additon, the Food Safety Law core of China’s future natonal food was amended again in late 2015.87 safety system. The real queston to be considered, then, is whether, in its efort Local ofcials are confronted with to manage scale, China’s existng food confictng pressures as ministerial safety policies can be combined in a way and agency roles are shufed and that will draw from their strengths while re-shufed. Food safety authorites addressing weaknesses. are encouraged to establish their own regulatory rules, only to have their Indeed, some aspects of centralized eforts at insttuton building interrupted and decentralized approaches to food by intermitent natonal campaigns. safety might be employed together, thus providing a common regulatory But China’s decision-makers do have framework while permitng some some optons: insttutonal diversity. 1. Federal Approaches Few countries have the opportunity to build an ideal regulatory system from Chinese policymakers may fnd that scratch. And China’s food safety system, the EU’s multlevel approach to food too, has largely developed in reacton to safety provides guidance for the crises rather than as a mater of ratonal efectve management of China’s own regulatory design. scale problems. As in the EU, a similar approach in China would focus the Since the 2000s, the central government authority of the central government on has restructured the food safety system managing the “Chinese common market” at least fve tmes in major aspects. And while facilitatng positve integraton of has implemented many more minor provincial food safety systems. Provinces reforms. Insttutonal artefacts from would be empowered to develop their

Meeting China’s Food Safety Challenge 23 Paulson Policy Memorandum

own food safety systems but would have employed in multlevel systems to beter to comply with minimum natonal food cope with the problem of scale. standards to engage in commerce in other provincial markets. Lagging provinces For example, China should certainly would then face compettve pressure engage in a fundamental restructuring to improve food safety for fear of losing of its food safety apparatus from the access to the natonal market.88 As of central government down to the localites. 2016, Beijing has already engaged in a Centralizing and decentralizing gradualist food safety benchmarking exercise that reforms have only complicated food safety grades provinces, municipalites, and local enforcement. Instead, the state needs to areas on their food safety management. ascertain the strengths and weaknesses of each level of government in regulatory In this approach, acton, and then provinces would designate regulatory have representaton authority accordingly. in central level decision-making Practcal modes bodies concerning of coordinaton the development across governments of common market and between standards, risk diferent levels of assessments, governments need and enforcement to be explained in policies. As Photo: Flickr/Will Clayton concrete terms— interprovincial disputes arise, the for example, sharing of resources, central government could intervene informaton processing, and so on. to adjudicate diferences in standards and enforcement. The primary politcal At the same tme, the central government problem of this approach is that the must refrain from unilateral regulatory multlevel framework would require actons in the form of campaigns, a reconfguraton of China’s unitary and instead provide support for local governance structure, but it is worth insttutonal capacity building. The central exploring in various aspects. government should largely dedicate itself to auditng subnatonal units. 2. Mimicking Multlevel Systems 3. Standard Setng If the government is unwilling to establish a de jure federal or multlevel system Standard setng should refect the for purposes of promotng food safety, reality of China’s producton and then it could stll adopt certain practces administratve system. Complex

Meeting China’s Food Safety Challenge 24 Paulson Policy Memorandum

standards devised at the center in Beijing of government should be encouraged should be reframed as aspiratonal goals to meet and discuss the challenges rather than as hard and formal targets. they face, and share successful and unsuccessful approaches to food safety. In this approach, standards development should actvely refect how Obviously, reform of the regulatory local governments operatng in diverse bureaucracy is just one part of the circumstances can eventually achieve soluton to China’s food safety problem. these standards in a step-by-step Other solutons should include public- fashion over several years. private collaboratons, improved supply chain management, broad-based 4. Encouraging Regulatory Debate and agricultural development, and third- Diversity party certfcaton. Taken together, all of these could help to build a more efectve Ultmately, a multlevel forum in which food safety system. Getng food safety regulators at diferent levels can freely policy right in China will require a more deliberate and discuss emerging nuanced understanding of the country’s problems needs to be developed. In scale, and thus the unique trade-ofs its additon, regulators of the same level policymakers must face.

Meeting China’s Food Safety Challenge 25 Paulson Policy Memorandum

Endnotes

1 Zhou, Wentng, “Food Safety Complaints More Common,” China Daily, November 1, 2011, htp://www. chinadaily.com.cn/business/2011-11/01/content_14012784.htm.

2 Huang, Yanzhong, “Fatal Mispercepton: How Unsafe Is China’s Food?” Council on Foreign Relatons: Asia Unbound, htp://blogs.cfr.org/asia/2013/07/10/fatal-mispercepton-how-unsafe-is-chinese-food/.

3 In my forthcoming book, On Feeding the Masses: An Anatomy of Regulatory Failure in China(Cambridge University Press), I discuss other aspects of China’s scale problem: (1) the challenge of developing policies that operate efectvely at multple scales (central, provincial, prefectural, county) simultaneously; (2) the difculty of identfying at what level a policy problem is emerging and which level of government is best suited to solving that problem; and, (3) the complexity of identfying and addressing scale externalites (i.e. when policies at one scale adversely afect governance at other scales).

4 In other work, I refer more specifcally to the problems with “partal” centralizaton and decentralizaton. A topic that is discussed extensively in my forthcoming book.

5 For the EU, see Alemanno, Alberto, “Solving the Problem of Scale: the European Approach to Import Safety and Security Concerns,” in Cary Coglianese, Adam M. Finkel and David Zaring (eds.), Import Safety: Regulatory Governance in the Global Economy, Philadelphia: University of Pennsylvania Press; for the US, see GAO (US Government Accountability Ofce), “Federal Oversight of Food Safety,” Testmony before the Subcommitee on Oversight and Investgatons, Commitee on Energy and Commerce, House of Representatves, htp://www.gao. gov/assets/130/120329.html; for India, see Umali-Deininger, Dina, and Mona Sur, “Food Safety In A Globalizing World: Opportunites and Challenges for India,” paper presented at the Internatonal Associaton of Agricultural Economists Conference, Gold Coast, Australia, 12–18 August 2006.

6 Gale, Fred, and Jean C. Buzby, “Imports From China and Food Safety Issues,” Economic Informaton Bulletn 52, 1-30, 2009.

7 Interview with independent laboratory president, Qingdao, Shandong, 23 September 2011; interview with US agricultural ataché, Beijing, July 2007.

8 Alemanno, Alberto, “Solving the Problem of Scale: the European Approach to Import Safety and Security Concerns,” in Cary Coglianese, Adam M. Finkel and David Zaring (eds.), Import Safety: Regulatory Governance in the Global Economy, Philadelphia: University of Pennsylvania Press.

9 Meador, Melida, and Jie Ma, “The Food Safety Management System in China,” FAIRS Subject Report, Global Agricultural Informaton Network Report No. CH13020.

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10 DeLisle, Jacques, “The Other China Trade Defcit,” in Cary Coglianese, Adam M. Finkel and David Zaring (eds.), Import Safety: Regulatory Governance in the Global Economy, Philadelphia: University of Pennsylvania Press.

11 Dyer, Geof, “China Arrests 774 in Crackdown,” Financial Times, October 29, 2007, htp://www.f.com/ cms/s/0/1acf1f42-865f-11dc-b00e-0000779fd2ac.html#axzz2VYjmrM45. Hu Yinan, and Lei Hou. 2009. “Vice Premier to Head Food Safety Commission,” China Daily, March 9, 2009, htp://www.chinadaily.com. cn/china/2009-03/09/content_7554541.htm.

12 Roberts, Dexter, “China Sets Up a Food Safety Super-Regulator,” Bloomberg Businessweek, March 14, 2013, htp://www.businessweek.com/artcles/2013-03-14/china-sets-up-a-food-safety-super-regulator.

13 Huang, Yanzhong, “Fatal Mispercepton: How Unsafe Is China’s Food?” Council on Foreign Relatons: Asia Unbound, htp://blogs.cfr.org/asia/2013/07/10/fatal-mispercepton-how-unsafe-is-chinese-food/. Calvin, Linda, Fred Gale, Dinghuan Hu and Bryan Lohmar, “Food Safety Improvements Underway in China,” Amber Waves 4(5), 16-21.

14 Yang, Guobin, “Contestng Food in the Chinese Media: Between Hegemony and Counter-Hegemony,” The China Quarterly 214, 337–355, 2013; Balzano, John, “China’s Food Safety Law: Administratve Innovaton and Insttutonal Design in Comparatve Perspectve,” Asian-Pacifc Law & Policy Journal 13(2), 23-80, 2012.

15 Liu, Peng, “Tracing and Periodizing China’s Food Safety Regulaton: A Study on China’s Food Safety Regime Change,” Regulaton and Governance, 4(2), 244–260, 2010.

16 Yan, Yunxiang, “Food Safety and Social Risk in Contemporary China,” The Journal of Asian Studies, 71(3), 705-729, 2012.

17 Lewis, John P., “Some Consequences of Giantsm: the Case of India,” World Politcs, 43(3), 367-389,1991.

18 Smil, Vaclav, “Who Will Feed China?” The China Quarterly 143, 801–813,1995.

19 Hsueh, Roselyn, China’s Regulatory State: A New Strategy for Globalizaton, Cornell University Press, 2011.

20 Liu, Peng, “Tracing and Periodizing China’s Food Safety Regulaton: A Study on China’s Food Safety Regime Change,” Regulaton and Governance 4(2), 244–260, 2010; Wei Shiping.,“China’s Food Industry Reports Healthy Progress,” Beijing Youth Daily, December 12th, 2002, htp://www.china.org.cn/ archive/2002-01/15/content_1025275.htm.

21 Zhang, Q. Forrest, and John A. Donaldson, “From Peasants to Farmers: Peasant Diferentaton, Labor Regimes, and Land-Rights Insttutons in China’s Agrarian Transiton,” Politcs & Society 38(4), 458–489, 2010.

Meeting China’s Food Safety Challenge Paulson Policy Memorandum

22 Huang, Philip, “China’s New-Age Small Farms and Their Vertcal Integraton: Agribusiness or Co-Ops?” Modern China 37(2) 107-134, 2011.

23 Yan, Yunxiang, “Food Safety and Social Risk in Contemporary China,” The Journal of Asian Studies 71(3), 705-729, 2012.

24 Ibid.

25 Prior to 2003, a mix of food safety policies was implemented regarding market access and monitoring. For a detailed account of food safety developments prior to the early 2000s, see Liu Peng, “Tracing and Periodizing China’s Food Safety Regulaton: A Study on China’s Food Safety Regime Change,” Regulaton and Governance 4(2), 244–260, 2010.

26 The SFDA had struggled to coordinate the food safety system since its establishment. In 2007, the SFDA’s head, Zheng Xiaoyu, was executed for corrupton, which led a reshufing of the SFDA’s portolio. By 2008, the MOH had acquired much of the SFDA’s former food safety roles.

27 For in-depth discussions of the cadre evaluaton system and its efect on policy implementaton, see Landry, Pierre F., Decentralized Authoritarianism in China, New York: Cambridge University Press , 2008.

28 ADB (Asian Development Bank), SFDA (State Food and Drug Administraton) and WHO (World Health Organisaton),The Food Safety Control System of the People’s Republic of China, Beijing: ADB, 2007.

29 Interview with SFDA, Ningxia, 16 November 2011; interview with provincial-level ofcials, multple ministries, Ningxia, 16 November 2011.

30 Interview with dragonhead enterprise executves, Ningxia, 16 November 2011.

31 Interview, SFDA, Ningxia.

32 Balzano, John, “China’s Food Safety Law: Administratve Innovaton and Insttutonal Design in Comparatve Perspectve,” Asian-Pacifc Law & Policy Journal 13(2), 23-80, 2012.

33 Interview with SFDA central government ofcial, Beijing, 19 May 2009.

34 Interview with county AQSIQ ofcial, Yunnan, 14 July 2011.

35 Interview with agricultural county bureau chief, 2 April 2011; interview with fshery bureau chief, Sichuan, 4 May 2011.

36 Interview, fshery bureau chief, Sichuan.

Meeting China’s Food Safety Challenge Paulson Policy Memorandum

37 Interview with food safety policy researcher, Zhejiang University, Hangzhou, Zhejiang, 5 December 2010.

38 Interview with FSC county food safety ofcials, Sichuan, 13 December 2011.

39 Yang, Lijie, Yongzhong Qian, Chen Chen and Fang Wang, “Assessing the Establishment of Agro-Food Control Systems Based on Relevant Ofcials’ Survey in China,” Food Control, 26(2), 223-230, 2012.

40 Interview, FSC county food safety ofcials, Sichuan.

41 Ibid.

42 Balzano, John, “New Layers of China’s Food Safety Regulaton,” Forbes, September 20th, 2015, htps://www.forbes.com/sites/johnbalzano/2015/09/20/new-layers-of-chinas-food-safety- regulaton/#57701d9a361d.

43 Calvin, Linda, Fred Gale, Dinghuan Hu and Bryan Lohmar, “Food Safety Improvements Underway in China,” Amber Waves 4(5), 16-21.

44 Ministry of Agriculture, “Natonal Modern Agriculture Development Plan (2011-2015),” htp://english. agri.gov.cn/hotopics/fve/201304/t20130421_19482.htm.

45 “Green Development of Food Producton,” People’s Daily, August 15th, 2012, htp://news.hexun. com/2012-08-15/144755593.html.

46 State Council, “White Paper on Food Quality and Safety,” htp://www.china.org.cn/english/ news/221274.htm.

47 Han, Jun (ed.), Report on Food Safety in China, China Social Sciences Academic Press, 2007.

48 Interview with township ofcial, Sichuan, 7 April 2011.

49 Interview with agricultural county bureau ofcial, Zhejiang, 12 October 2011.

50 Interview, fshery bureau chief, Sichuan.

51 Interview with dragonhead executve, Ningxia, 15 November 2011.

52 Thompson, Drew, and Ying Hu, “Food Safety in China: New Strategies,” Global Health Governance 1(2), 1-19, 2007. China watchers will recall that, in the early 1980s, local protectonism balkanized China’s internal market for certain resources.

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53 “Shandong Bans Sales of Contaminated Turbot,” Xinhua, htp://www.china.org.cn/english/ health/189526.htm.

54 Interview with food safety expert, Qingdao, Shandong, 18 September 2011.

55 Interview with township ofcial, Yunnan, 18 July 2011; interview with township ofcial, Yunnan, 19 July 2011.

56 Heilmann, Sebastan and Elizabeth J. Perry (Eds.), Mao’s Invisible Hand: the Politcal Foundatons of Adaptve Governance in China, Harvard University Press, 2011.

57 “Over 100 Arrested for Making New-Type ‘Guter Oil’,” Xinhua, April 3rd, 2012, htp://news.xinhuanet. com/english/china/2012-04/03/c_131504678.htm.

58 Interview with independent producers, Jiangsu, 15 September 2011.

59 Yao, Peishuo, “Beijing Promises to Take Food Safety Seriously,” China News, htp://fnance.chinanews. com/jk/2012/07-03/4005579.shtml.

60 XX County Annual Food Safety Work Plan, “Food Safety Document No. 10,” from author’s personal collecton.

61 “More than 540,000 Grassroots Ofcials Punished for Discipline Violatons,” Xinhua, October 11th, 2012, htp://news.xinhuanet.com/english/china/2012-10/11/c_131900598.htm. Accessed 11 June 2013.

62 XX County Campaign Report, “Food Safety Document No. 87,” from author’s personal collecton.

63 XX Township Food Safety Work Report, “Food Safety Document No. 82,” from author’s personal collecton.

64 Heilmann, Sebastan and Elizabeth J. Perry (Eds.), Mao’s Invisible Hand: the Politcal Foundatons of Adaptve Governance in China, Harvard University Press, 2011. For a discussion regarding the potentally negatve efects of campaigns, see Wedeman, Andrew, “Antcorrupton Campaigns and the Intensifcaton of Corrupton in China,” Journal of Contemporary China 14.42: 93-116. On campaign governance and its compettve role with insttutonalizaton of a professionalized bureaucracy, see Trevaskes, Susan, “Courts on the Campaign Path in China: Criminal Court Work in the ‘Yanda 2001’ Ant-Crime Campaign,” Asian Survey 42.5 (2002): 673-693.

65 Interview with township ofcial, Sichuan, 6 March 2011; interview, county AQSIQ ofcial, Yunnan.

66 Interview, independent producers, Jiangsu.

Meeting China’s Food Safety Challenge Paulson Policy Memorandum

67 Interview with producer associaton leader, Yunnan, 18 July 2011; “China Makes Arrests over Food,” Wall Street Journal, August 5th, 2011, htp://online.wsj.com/artcle/SB100014240531119038856045764877805 29072912.html.

68 Interview with cooperatve member, Sichuan, 2 April 2011.

69 Interview, FSC county food safety ofcials, Sichuan; interview, county AQSIS ofcial, Yunnan.

70 Interview, county AQSIS ofcial, Yunnan.

71 Interview with township husbandry chief, Yunnan, 15 July 2011.

72 State Council, “White Paper on Food Quality and Safety,” htp://www.china.org.cn/english/ news/221274.htm.

73 United Natons, Ofce of Resident Coordinator in China, “Occasional Paper: Advancing Food Safety in China,” United Natons, Beijing, htps://archive.org/stream/365292-advanicng-food-safety-in- china/365292-advanicng-food-safety-in-china_djvu.txt.

74 General Administraton of Quality Supervision, Inspecton and Quarantne, “Administratve Provisions on Filing of Export Food Producton Enterprises,” htp://en.ciqcid.com/Zjl/Comprehensives/51829.htm.

75 State Council, “White Paper on Food Quality and Safety,” htp://www.china.org.cn/english/ news/221274.htm.

76 Interview with EU food safety ofcial, Beijing, 13 April 2011.

77 The recent 2010 US Food Safety Modernizaton Act has specifed more stringent requirements.

78 Chen, Kevin, Yongfu Chen and Minjun Shi, “Japanese Safety Regulaton System on Imported Foods and Vegetables Pestcide Residues Standards,” in Zihui Huang, Kevin Chen, and Minjun. Shi (eds.), Food Safety: Consumer, Trade, and Regulaton Issues, Zhejiang University Press, 2005.

79 United Natons, Ofce of Resident Coordinator in China, “Occasional paper: Advancing food safety in China,” United Natons, Beijing, htps://archive.org/stream/365292-advanicng-food-safety-in- china/365292-advanicng-food-safety-in-china_djvu.txt; Calvin, Linda, Fred Gale, Dinghuan Hu and Bryan Lohmar, “Food Safety Improvements Underway in China,” Amber Waves 4(5), 16-21.

80 Interview with food safety auditor, Qingdao, Shandong, 29 November 2011; interview with exporter, Qingdao, Shandong, 22 September 2011; interview with export–import food producer, Qingdao, Shandong, 18 September 2011.

Meeting China’s Food Safety Challenge Paulson Policy Memorandum

81 Interview, export–import food producer, Qingdao.

82 Interview, independent laboratory president, Qingdao.

83 Ibid.

84 Interview, exporter, Qingdao; interview, export–import food producer, Qingdao; interview with export company “F,” Qingdao, Shandong, 19 September 2011.

85 Interview with exporter, Qingdao, Shandong, 22 September 2011.

86 Ibid.

87 Balzano, John,“Three Things to Watch for in Chinese Food Safety Regulaton in 2014,” Forbes, February 5, 2014, htp://www.forbes.com/sites/johnbalzano/2014/02/05/three-things-to-watch-for-in-chinese-food- safety-regulaton-in-2014/.

88 As of August 2016, Beijing engaged in a process of benchmarking food safety performance across provinces, municipalites and other localites - presumably to create compettve pressures to improve regulatory oversight.

Meeting China’s Food Safety Challenge Paulson Policy Memorandum

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