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REPORT ON THE INVESTIGATION OF COMMODITIES IMPORTED FROM EUROPE 1990-2000

Animal Health and Production Division

May 2001

As a result of a media report that Statistics Canada’s import data showed Canada had imported meat waste from the United Kingdom (UK) and Germany during the 1990s, the Canadian Food Inspection Agency (CFIA) conducted an extensive review of import records to determine whether any products that pose a risk for the transmission of bovine spongiform encephalopathy (BSE) were imported from Europe in the past decade.

For the period from 1990 to 1994, the CFIA based its investigation on a review of its Restricted Commodity Reports, which are produced by the ports of entry to document all incoming commodities. In these documents, CFIA agricultural inspectors describe the commodity and classify the risk of importation as low, medium, or high.

For the period from 1995 to December 2000, Canada Customs and Revenue Agency (CCRA) was able to provide the CFIA with transaction entries for commodities that were alleged to have been imported for use in the manufacture of livestock feed. These documents provide more detail on individual importations than the Restricted Commodity Reports; however, they are only available from 1995 to the present.

The CFIA also received transaction reports from the CCRA regarding cooked, canned prepared/preserved meats such as chicken and pork, which were illegally imported from Great Britain in the summer and fall of 1998 for British specialty shops located in Calgary, Alberta. All such imported products were recalled by the CFIA’s Calgary office in 1998 and were subsequently destroyed by disposal in sanitary landfill.

The CCRA produces its transaction entry reports under the Harmonized Commodity Description and Coding System or Harmonized System – a multipurpose international product nomenclature developed by the World Customs Organization (WCO). The Harmonized System comprises about 5,000 commodity groups, each identified by a six digit code to achieve uniform classification. This system is used by more than 177 countries as a basis for Customs tariffs and for the collection of international trade statistics. More information on the Harmonized System is available on the WCO Web site: http://www.wcoomd.org/ie/index.html.

Of the 4000 transaction entries provided by CCRA for the period from 1995 to 2000, the CFIA was able to determine on the basis of the information provided that 3600 entries related to importations that did not pose any risk for the transmission of BSE. The CFIA identified the remaining 400 entries as requiring further scrutiny and asked the CCRA to provide additional documentation. The CCRA complied and submitted three supporting documents for each of the transactions in question.

As Harmonized System coding was designed primarily for the purposes of freight tariffs and statistics on the various modes of transport, it does not provide the detail required to track specific import commodities and can lead to a misinterpretation of the data.

The CFIA’s investigation revealed that of the 400 entries identified for further investigation, some of the importations were mixed shipments that required further clarification; there were also instances where the shipments had been coded incorrectly; and, in a few cases, the end use of the product imported was not correctly identified. Finally, as the HS categories are extremely broad, it is not possible to determine the specific commodity imported based solely on the category.

An example of a mixed shipment would be an importation from the Netherlands coded as feather meal, which on examination of the manifest was found to contain two small amounts of feathers, along with glass vases, tables, candles, etc.

There were several examples of imported commodities that had been coded incorrectly. Under the CCRA code HS 05119900, which refers to meat scraps for the manufacture of animal feed, the investigation revealed that spray-dried blood (hemoglobin) of porcine and bovine origin was imported under permit from Belgium and Denmark for unrestricted use in animal feed as permitted by the CFIA’s import policies until December 2000. This code was also used for the importation of ground sturgeon bladder for use as a wine additive; pig ears from Germany, Denmark, Portugal, Belgium for use as a pet food product; and, bull pizzles from Portugal, Spain and Denmark for use as a pet food product.

With regard to the identification of the end use of an imported commodity, under the CCRA HS Code 05069000 (bone meal for the manufacture of animal feed), approximately 6000 kg of pharmaceutical grade bone meal of mostly porcine origin was imported from Holland over a period of several years. The material was imported under permit by an importer who re-sold it for use in preparation of vitamin capsules for human consumption.

HS Code 05069000 (bone meal for the manufacture of animal feed) was also used for the importation of 453,567 kg of bone charcoal from the UK. Bone charcoal is subject to such extreme temperatures (approximately 1200^o F) during processing that it does not pose any risk for transmission of BSE and was deregulated in 1996. Bone charcoal is used by industry to refine sugar. After the sugar is refined, the remaining charcoal dust is sold for use in animal feed.

The above code was also used to import 6980 kgs of bone ash from Great Britain, used in the manufacture of machine shop crucibles (containers in which metals can be melted).

In another example of the breadth of the HS code categories, CCRA’s HS Code 23011000, which describes flours, meals and pellets of meat or meat offal (greaves), was used to import feather meal under import permit from France for use as animal feed. This code was also used to import, under permit, high protein binder containing porcine blood meal of Danish origin.

HS Code 230910000 is used by the CCRA for pet food imports. There are many importations of pet food products from Great Britain that are imported as cooked, canned, or shelf-stable products such as dog biscuits. The ingredients generally include plant product with a minimal amount of animal ingredients, such as liver powder digest from the U.S. and/or dairy ingredients from Denmark and Poland.

In one other record, the transaction shows that 11,047 kg of pet food were imported from Great Britain; however, only 20 kg of rawhide pet chews came from Great Britain and the remainder of the shipment consisted of pet chews and leashes, collars etc., which were exported from other countries, mostly the U.S.

The CFIA’s investigation, which was based on the available records of the CCRA and the CFIA, has concluded that no meat or bone meal was imported into Canada for use in livestock feeds from BSE-infected countries in the last decade. Although the imprecise nature of the HS coding used by the CCRA contributed to some of the discrepancies that the investigation revealed, it must be noted that the need for a more detailed breakdown in categories of commodities could not have been foreseen.

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