My 12 Year Obsession with China Was Worth It!

Written by: Gina Tumbarello   |   April 14, 2023

Trade, China

Not many know what happens behind the scenes here at the American Feed Industry Association. This well-oiled machine may look easy-breezy-lemon-squeezy (as my Pilates instructor says) from the outside, but behind our closed doors, you’ll find dual, sometimes triple, computer monitors; multiple Excel spreadsheets open with trade data and colorful graphs; dozens of browser pages open with research; partially drafted Word documents; scribbled post-it notes; and LOTS and LOTS of caffeine. Well, I can’t speak for the rest of the AFIA, but that’s what it looks like at my desk, and I can tell you, it is all worth it when we score a win for our members and industry.

Let me paint you a picture of the past 12 years working with China…

Fresh on the job in 2011, I started at the AFIA with a gleam in my eye and big plans for expanding the association’s global initiatives, ensuring U.S. animal food manufacturers could continue thriving by having access to the important key inputs from foreign suppliers and new and continuing global customers. Now, with more than a decade of experience in international policy and trade, I see that this “gleam in my eye” was actually more of a mild sheen, because this stuff does not happen overnight.

Shortly after I started, I was introduced to what would become my obsession for the next 12 years - China’s Decree 118. China’s Decree 118, adopted in 2009 and implemented in 2011, requires foreign feed manufacturing facilities looking to export to China to register with what is now called China’s General Administration of Customs (GACC).

However, while China required registration for export, a process for registering facilities did not exist. This meant that starting in 2011, U.S. feed additive, premix and compound feed products that had not previously been exported to China could not be export there.

Furthermore, China had no accounting of what products had traditionally been exported, leaving those wishing to continue to export to ship at their own risk, not knowing if their product would still be able to get in and many were unwilling to risk it.

So, basically, my mission was to: 1) find a way to get traditionally traded products (TTP) recognized to keep trade flowing and 2) get China to accept a process for registering new facilities so new products could be exported.

Challenge. Accepted.

But as we know, nothing is ever easy, of course.

Decree 118 affected other feed ingredients, not just feed additives, premix and compound feeds, and China chose to address those other categories first, one at a time. First, forage, then, fishmeal, then, plant-based (which ended up just being sugar beet pellets and distiller's dried grains with solubles). Then, I helped our members work through the existing facility registration processes for non-ruminant and pet food. Fast forward to 2016, all that work has been done and now we can get to feed additives, premix and compound feed.

And remember, five years has passed, and we still do not have a recognized list of traditionally traded feed additive, premix and compound feed products, and no new products have been exported to China!

In the first year after Decree 118 was implemented, U.S. exports of feed additives, premix and compound feed fell 15%, from $196 million to $166 million. By 2015, exports fell to $112 million, down 43% from 2011.

Starting in 2014, the AFIA secured government funding to support our efforts to address this facility registration saga. We leveraged both the Emerging Markets Program (EMP) and Market Access Program (MAP) funds from the U.S. Department of Agriculture’s Foreign Agricultural Service (FAS). I spent much of my time 2016-18 planning an audit of the U.S. feed additive, premix and compound feed industry for Chinese government officials so that they could then determine the requirements for what a facility would have to do to get registered.

Back and forth-negotiating-starting over-changing minds. The usual.

Then, this all collapsed in 2018, when the U.S. and China went head-to-head in a tariff war.

However, the AFIA used this “opportunity” to pivot our efforts and develop a TTP list, which was almost in its entirety accepted and formalized by China in 2018. We worked with FAS-Beijing and the Chinese government to ensure those facilities that had previously exported would be listed. Once the U.S. and China moved to formal negotiations, the AFIA worked with the U.S. Trade Representative to get additional facilities added to the list and establish a process for registering new facilities. Both were included in the final text of the U.S.-China phase one trade agreement.

And since nothing is perfect, most recently, the AFIA worked with the Agricultural Marketing Service to revamp the facility registration process to address gaps in the information the GACC needs to add new products and products exempt from product registration to the list.

Now, 12 years later, the facility list for U.S. feed additives, premix and compound feeds has 442 (see Appendix 1) U.S. products on it, and the gleam in my eye has returned in full force.

Stay tuned for my next blog in my U.S.-China trade miniseries….