Food Policy 36 (2011) 412–420

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The China melamine milk scandal and its implications for food safety regulation
Xiaofang Pei a, Annuradha Tandon b, Anton Alldrick c, Liana Giorgi b,⇑, Wei Huang a, Ruijia Yang a a West China School of Public Health, Sichua University, Chengdu, China The Interdisciplinary Centre for Comparative Research in the Social Sciences, Austria c Camden BRI Food and Drink Research and Services, United Kingdom b a r t i c l e

i n f o

a b s t r a c t
This article examines the development of the Chinese dairy sector since 2000 and investigates how this has affected food safety. The ongoing problems caused by melamine contamination are linked to the rapid and unregulated development of this sector. Currently, China is faced with demands – both from home and abroad – to improve its food safety record. This will necessitate it upgrades its regulatory framework to meet the standards of Codex Alimentarius and the EU. A serious restructuring of the dairy sector as well as of the public food safety control agencies is called for. The costs and benefits to be accrued by these reforms are the subject of this article. Ó 2011 Elsevier Ltd. All rights reserved.

Article history: Received 16 February 2010 Received in revised form 20 January 2011 Accepted 3 March 2011 Available online 8 April 2011 Keywords: Safety Melamine Dairy China EU Regulations

Introduction Fewer than three years ago, melamine was a term known only to chemists. This changed almost overnight in 2006 when the pet food scare broke out. In 2008, the much more serious milk powder contamination scandal followed. Since then it has been known that melamine can lead to serious or even fatal renal and kidney failure under specific conditions and for specific forms of metabolism. In the long term, melamine contamination will probably be remembered mostly for bringing about a comprehensive reform of the Chinese food safety regime. Reforming the Chinese food sector is, however, no small undertaking by reason of the country’s size. Clearly, China should opt for the reform pathway which guarantees the best results with respect to food safety without seriously endangering the country’s economic development course and its approximation to Western standards and trade relations. The present article aims to contribute to this reform process by offering a systematic overview of the Chinese dairy sector and food regulatory system in juxtaposition with the situation within the European Union, and in individual European countries. The latter are taken as benchmarks, against which China can take its bearings and measure the progress of its reforms. From the European per⇑ Corresponding author. Address: Salesianergasse 25/1/6, A-1030 Vienna. Tel.: +43 664 1325950. E-mail addresses: xxpei@sina.com (X. Pei), a.tandon@iccr-international.org (A. Tandon), a.alldrick@campden.co.uk (A. Alldrick), iliana.giorgi@gmail.com, L.giorgi@iccr-international.org (L. Giorgi), xxpei@sina.com (W. Huang), xxpei@sina. com (R. Yang).
0306-9192/$ - see front matter Ó 2011 Elsevier Ltd. All rights reserved. doi:10.1016/j.foodpol.2011.03.008

spective, the article is an interesting study on compliance with higher food safety standards. The paper is structured as follows. The first section deals with problem identification reporting on the hazardous nature of melamine, the case of milk contamination with melamine and the Chinese dairy sector. The subsequent section entitled ‘Benchmarking the way towards greater food safety’ explains the use of the benchmarking approach to address the main issues of compliance with food safety regulations. ‘Regulatory issues’ looks at the first of these issues, i.e. the regulatory framework, and compares the situation in China with that of the EU. A similar format is followed in the next two sections: ‘Official controls’ compares the systems of official controls in the EU and China, whilst ‘Private standards and the role of the dairy industry’ looks at the dairy industry and private standards in the two countries. Against this background, the final section, ‘Assessment and comparisons’ considers the advantages and disadvantages of different policy options for reforming the Chinese food safety regime. Problem identification Melamine as a health hazard Melamine is a nitrogen-rich organic compound and an intermediate chemical frequently used for the manufacture of fertilizers, plastics, laminates, paints and adhesives. Studies carried out on rats in the mid-1940s indicated that melamine was not toxic (Lipschitz and Stokey, 1945). However, in 1953, a follow-up study on

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Table 1 Production, domestic consumption and exports (in million tonnes) of cow’s milk. Sources: China Ministry of Agriculture, Dairy Yearbooks & China Dairy Association (for 2007and 2008). 1995 Production Consumption Exports 5.7 6.8 0.03 1996 6.3 7.4 0.031 1997 6.6 7.8 0.039 1998 6.4 7.5 0.037 1999 7.1 8.4 0.04 2000 8.2 9.6 0.048 2001 10.2 11.5 0.043 2002 12.9 14.7 0.051 2003 17.4 n.a. 0.049 2004 22.6 n.a. 0.060 2005 27.5 15.9 0.070 2006 31.9 n.a 0.075 2007 35.2 17.5 0.12 2008 36.5 n.a. 0.12

dogs documented toxicity at higher intakes. Animal studies in the 1970s and 1980s showed that the danger of toxicity differed according to the age of the animal (Heck and Tyl, 1985; Newton and Utley, 1978). The first study to suggest that the toxicity of melamine was proportional to its metabolic output was performed by researchers in the former USSR during the 1980s. Their results suggested that melamine cyanurate (a salt formed between melamine and cyanuric acid, commonly used as a fire retardant) could be more toxic than either melamine or cyanuric acid alone (Babayan and Aleksandryan, 1985). The toxicity of melamine cyanurate crystals has since been linked to their inability to dissolve easily, and this can lead to chronic toxicity (Wilson, 2007). The combination of melamine and cyanuric acid can therefore lead to acute renal failure. This was confirmed by a toxicology study (Puschner et al., 2007) carried out following the recalls of contaminated pet food in the U.S. and Canada. In humans, the ingestion of melamine may lead to reproductive damage and bladder or kidney stones. As with animals, the danger is greatest among the very young, whose organs have yet to form fully and whose nutrition is more restricted. In China in 2008, the melamine contamination of milk powder led to the deaths of six infants and the hospitalization of 52,000. A further 250,000 children were estimated to have suffered mild kidney and urinary problems. The immediate cost to the health system was estimated at 58 million Euro. The EU tolerable daily intake for melamine in the context of the contact of food with packaging and other materials is 0.5 milligrams per kg of body mass. This was judged as sufficient also after the melamine crisis (EFSA 2008). In the United States, the threshold was set at 0.63 mg prior to the melamine crisis, but was revised downwards to 0.063 mg in the aftermath of the scare. According to the WHO, the tolerable daily intake (TDI) is 0.2 mg per kg of body mass. Melamine in milk The contamination of Chinese milk by melamine represented a case of fraud. Melamine was added to mask a dilution in protein. Specific tests for milk quality, e.g. freezing point depression, specific gravity analysis and fat content should have detected such fraud, but these tests were either not carried out properly or were ineffective. Rapid automated systems for testing the content of protein, fat and other ingredients were also not used properly, thus were ineffective for detecting fake protein. Two other factors contributed to the melamine scandal. The first was that melamine was not specifically listed as an illegal additive. The second was that many dairy giants in China, including the main distributor of the contaminated milk, Sanlu, were exempted from official controls. This is a point we return to later in this article. The Chinese dairy sector The Chinese dairy sector began to grow rapidly in 2000 following a more moderate growth rate between 1995 and 2000. It is highly likely that the problems currently being faced are due to this fast growth, which occurred largely in unregulated fashion.

In 2000, the annual production of cow’s milk amounted to just over 8 million tonnes. By 2008, this had increased close to fivefold to over 36 million. Similar growth rates were observed for dry milk products, which went up from less than one million tons in 2000 to close to four million in 2007 (China Ministry of Agriculture, 2008). This rapid growth is mainly driven by changes in domestic consumption patterns. The consumption of dairy products has been on the increase by an average of 15% annually since 1995. With increasing affluence, the Chinese food consumption patterns have tended to shift closer to those in the West. The Chinese government has also actively promoted the consumption of milk by children through a school milk scheme. China is also rapidly evolving as an export country for dairy products, and especially for dry milk products. Table 1 compares the changes in domestic consumption patterns with the changes in production and exports over the period from 1995 to 2008. In 2007, around 50 percent of milk produced was channelled into domestic consumption, whereas less than 0.5 percent was directly used for export. This also means that 40 to 50 percent of the total production of cow’s milk is channelled into the production of other dairy products, of which a large proportion is then also exported. China’s surging exports of milk products are to be explained by the increased demand in Hong Kong, Macao and Southeast Asia against the backdrop of decreasing supplies from the traditional milk producing countries, namely Australia, New Zealand and the European Union.1 By contrast, the dramatic shift in the domestic consumption of milk products was made possible by a major restructuring of the Chinese dairy sector in conjunction with rising per capita incomes. Throughout the 1990s and the first years of the new century, the growth of the dairy sector was actively supported by the Chinese government with various programs. These included allocation of farmland to raise cattle, improvement of grasslands and yields, economic incentives like wavering of landuse fees or the provision of discount loans to farmers or processing and packaging operators. As a result, the number of farm holdings has doubled in a very short period of time from 3098 in 2003 to 6478 in 2008. Similarly, the number of enterprises involved in dairy processing rose from 355 in 1998 to 717 in 2007 (China Ministry of Agriculture 2008). The main dairy producing areas are the regions of Hebei, Henan, Shandong, Heilongjiang, Guangdong, Sichuan and Shanxi, which together account for nearly 67% of farm holdings by reason of their climate and grasslands. The majority of the Chinese farm holdings (60% in 2007) are medium-size and organized as cooperatives with 100 to 200 cattle each. A total of 6478 holdings presently accounts for an employment of just over 7 million – still a comparatively small number which points to intensive agricultural production techniques, but also suggests that there is scope for growth. The 1990s also witnessed a renewal of interest in foreign investment in the Chinese dairy sector. Today, big corporate names such as Danone, Friesland and Nestle are all present in China.

1 This has also led to significant milk price rises in New Zealand and the United States. In the European Union, milk prices could be kept low through providing subsidies to farmers.

414 Table 2 EU Regulations on Food Safety in Dairy Products. Regulation (EC) No 852/2004 Regulation (EC) No 853/2004 Regulation (EC) No 854/2004 Regulation (EEC) No 2377/90 – as amended Regulation (EC) No 1881/2006

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Lay sdown hygiene rules for food (852) and feed (853), in addition to defining requirements for raw milk and dairy products Sets out rules for official controls on products of animal origin Sets maximum levels for veterinary drugs in animal products, including milk Sets the maximum levels for number of chemical contaminants in foods

Table 3 Responsibilities of China’s food regulatory agencies under the 2009 law. Source: New Food Law China 2009. Regulation agency New food safety commission under the State Council Ministry of Health (MOH) under which is the State Food and Drug Administration (SFDA) Administration for quality, supervision, inspection and quarantine (AQSIQ) State Administration for Industry and Commerce (SAIC) Ministry of Agriculture (MoA) Main food safety problems in the link Co-ordinate and oversee the new food supervision apparatus Assess food safety risk, set national standards of food safety, release information relating to food safety, regulate food safety testing, and investigate serious food safety incidents Supervision of food production and food export/import Supervise the domestic wholesale and retail food sectors Responsible for non-processed farm products

Benchmarking the Way towards Greater Food Safety How should China improve its regulatory framework towards greater food safety? And what are the costs and benefits of this reform process? This is the main theme of this paper. As discussed above, China has recently enacted a new legislative framework for upgrading its food safety standards. However, the enactment of legislation is only the first step in a long process of implementation (Hong-Gang and Hui, 2009). Therefore, the present study considers regulatory issues (see ‘Regulatory issues’), to then examine the practical steps that would need to be undertaken at the levels of official controls (see ‘Official controls’) and the dairy industry (see ‘Private standards and the role of the dairy industry’) for effectively implementing the new legislation. In order to assess the costs of this process, we follow a comparative benchmark study design comparing the Chinese dairy sector in its present form with the Austrian dairy sector. The two countries differ quite significantly and not least with respect to the size of the food production sector and the size of the country as such. Still, Austria was considered a good benchmark for three reasons:  First, for being an EU Member State, hence following the EU regulatory framework on which China has modelled its recent reforms.  Second, for displaying a dairy sector with high levels of quality and food safety.  Third, for having a dairy sector structurally organized in cooperatives – a model also favoured by the Chinese dairy industry in view of the large number of small farm holdings delivering to large dairies. With respect to the regulatory framework of official controls, we also consider the examples of the UK and Germany. This is because official controls are organized differently, depending on the political structure of the country and its public administrative history. In reforming its system of government oversight and official controls, China may therefore have to consider different institutional models – each entailing different assets and liabilities.

the application of good safety practices and controls at each and every point in the food chain and the obligation for food to be traceable right back to the original source. This was followed by several new regulations and directives on official controls or the testing and analysis of specific contaminants in specific food commodities. In addition, the last decade has seen major institutional reforms at EU and national levels, including the establishment of a European Food Safety Authority (EFSA) and equivalent bodies at national level and the introduction of the Rapid Alert System for Food and Feed (RASFF).2 Table 2 summarizes those regulations or directives of specific relevance for the dairy sector. EC Regulation 852/2004 Lays down general rules for food business operators on the hygiene of foodstuffs. This requires the application of the HACCP system by food operators (Article 5) and recommends its use also at the primary production level. In recognition of the possible nonfeasibility of the application of HACCP to primary production (preamble, 11), the regulation recommends using appropriate hygienic practices and suggests Member States develop national guides to good practice for food operators along the food chain and in accordance with the codes of practice of Codex Alimentarius (Article 8). Annex I lays down the general hygienic provisions for primary production and Annex II lays down the hygienic provisions for all food business operators. EC Regulation 853/2004 Lays down specific rules on the hygiene of food of animal origin. The regulation is justified with reference to the specific hazards to human health represented by food of animal origin, in which microbiological and chemical hazards have frequently been reported (preamble, 2). Section IX of Annex III specifies the requirements for raw milk and dairy products. EC Regulation 854/2004 Lays down specific rules for the organization of official controls on products of animal origin intended for human consumption. Such controls can only be carried out by certified establishments (Article 3) and must include an audit of good hygienic practices and HACCP and official controls specified for each product category (Article 4). For raw milk and dairy products, the specific
2 A brief description of the EU regulatory framework is provided by Giorgi and Lindner, 2009. A more detailed overview of the legislative acts is provided by Alemanno 2007.

Regulatory issues Food safety in the dairy sector – the EU framework In 2002, the European Union introduced a General Food Law (Regulation 178/2002) based on the ‘farm to fork’ principle, i.e.

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Table 4 Comparison of official controls in Austria, Germany and the UK. Source: Food safety regulations in Europe, Vos and Wendler (eds.), www.dairyUK.org +, http://www.dairyUK.org +, DG (SANCO)/7713/2008 – Country profile of the United Kingdom, Germany and Austria on food &feed safety, animal health, animal welfare and plant health, 2008, http:// www.bmg.gv.at/cms/site/thema.html?channel=CH0835. Austria 2682 47,500 525 Yes (8) Yes Yes (ALIAS) 444a Depends on risk assessment of enterprise HACCP guidelines 900+ 1768+ Germany 27,681 99,000 4087 Yes Yes Yes, Information platform (FIS-VL) 12,293b Depends on risk assessment of enterprise HACCP guidelines N.A. 38,656# UK 13,647 14,400 1977 No (public analysts) Yes Under implementation 8841 (national and local) Depends on risk assessment of enterprise HACCP guidelines 11,000 13,981++

Wholesale production of raw milk (‘000 tonnes)° Farm numbers° National herd (‘000 head) Official laboratories Control plans Quality and data management system Provincial and district level staff resources (food, feed, animal health, animal welfare and plant health)+ Frequency of checks – dairies Private sector control Average number of on-site controls (yearly) Average number of laboratory tests (yearly) a b + ++ #

204 are food inspectors, 75 veterinary services and 150 administrative authorities. Information for Bremen and Mecklenburg-Vorpommern not available. Based on the Auditing and Sampling Plan for 2008 in Austria. Number of formal samples taken in 2006/2007. For 2006/2007 the sample plan for milk and milk products.

requirements are spelt out in Annex IV and include criteria for control of milk production holdings and control of raw milk upon collection (see Table 4), which has to be in accordance with Annex III, Section IX, Chapter I, Part III, to Regulation 853/2004 (which sets out the plate count, somatic cells count and checks for antibiotic residues).

The Chinese regulatory system on dairies The melamine contamination of milk powder has triggered a comprehensive reform of the Chinese food safety regime. A new law enacted in February 2009, which entered into effect in June 2009, foresees the adoption of the ‘farm to fork’ food chain principles also governing the EU regulatory framework. In consecutive steps, and following UN recommendations, the Chinese government is expected to adopt the Good Agricultural Practices (GAP) as well as the Good Manufacturing Practices (GMP) across all food sectors and proceed with the implementation of the HACCP at firm level. Until recently, the Chinese food sector was governed by the ‘Food Hygiene Law of the Peoples’ Republic of China’, dating from 1995. The Chinese Food Standard3 set out the institutional and supervisory food controls. As in Europe in the 1980s, prior to the BSE scandal, the Chinese food safety regime was characterized by institutional fragmentation with responsibilities spread out across several ministries (Chen, 2009; Tam and Yang, 2005). In order to overcome these difficulties, the new law tries to restructure the responsibilities and provide a clearer division of powers (Table 3). Under the previous regime, several large dairy companies were granted inspection-free status on the basis of their past food safety record and in an effort to increase production with the view to boost demand at home and abroad. As a result, the Chinese food safety system was characterized by insufficient co-ordination, lack of resources, and a significant imbalance of the number of official controls between urban and rural areas (UN, 2008). According to Chen (2009), ‘China’s current food safety supervision system is doomed to making the supervision passive and ex-post, leaving redress as the only route’ (737). Prior to the melamine scandal there was more emphasis placed on supporting the dairy industry. Following the melamine scandal, the government has shifted gears, and is now laying more empha3

sis on strengthening the regulatory framework and quality control. The new Food Law of 2009, which contains 104 rules in 10 chapters, foresees better co-ordination between national and provincial authorities, anticipates a significant increase in institutional and monitoring capacity through certified laboratories and plans the introduction of a food recall system modelled on the European RASSF. As in the EU, the primary responsibility for food safety will lie with food producers and operators. A weak point of the Chinese food safety system resides in the lack of trained personnel. In order to remedy these shortcomings, the Chinese government plans to reinforce its training schemes. Under the new law introduced in 2009, China’s State Council will establish a national food safety commission that will co-ordinate and oversee the new food supervision apparatus. The MOH will be in charge of elaborating uniform national standards for food safety, including standards for food inspection. New enforcement guidelines require enforcement agencies to conduct periodic or random test checks for food safety and prohibit the granting of exemptions from such checks or inspections. Within the dairy sector, the MOA and AQSIQ will be responsible for quality control, whereby the MOA will have jurisdiction over the farm holdings and the AQSIQ over food operators. Comparison EU-China The decision by the Chinese government to embark on a major reform of its food safety regime is a step in the right direction. The new Chinese Food Law from earlier in 2009 displays a number of positive elements, especially with respect to establishing the principle of the responsibility of food producers and operators for food safety and the decision to upgrade the official control infrastructure and introduce a recall system. There remain, however, significant differences between the EU and the Chinese food regulatory system which are worth highlighting. It is not unlikely that these are being anticipated by subsequent legislation and regulatory initiatives already in-the-making as a follow-up of the new Chinese Food Law:  Within the European Union, the General Food Law is principally just that – a general legal framework created to establish the main principles to guide subsequent legislation or regulatory activity. The ‘thickness’ of the EU food safety regulation derives

GBT478912008, GB19301-2003, GBT6914-86 and GB5009.

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rather from the subsequent more detailed regulations on specific aspects of the food safety system across the food chain. In the case of the dairy sector, for instance, the General Food Law is at best a reference point of constitutional value; far more important are the regulations on official controls and hygienic rules. In China, we have yet to see the elaboration of legislation or guidance in these more detailed areas of food safety.  A problem which we will see recurring with respect to official controls, but which is also evident at the regulatory level, is that of centralization. In this respect, it is revealing that even under the new law China specifies two bodies for monitoring implementation in the dairy sector – the Ministry of Agriculture for the production side and the AQSIQ for official controls. Within the EU, implementation and oversight rest with the Member States, which, in turn, share this responsibility with regional authorities and various agencies. Admittedly, the better co-ordination with authorities at regional level, and especially those active in the dairy sector, is explicitly mentioned as a goal in the Chinese General Food Law. However, considering that China, unlike the EU or the United States, does not have any tradition in federalism and/or decentralization, operationalizing this goal represents a real challenge. Addressing these basic shortcomings will require the introduction of additional reforms and a streamlining of the legislative framework to present and future institutional capacities. Official controls Official controls in the Austrian dairy sector The implementation of the EC legislation in Austria is governed by the National Food Safety and Consumer Protection Act (LMSVG) BGBI. I No 13/2006 modelled according to the EU General Food Law. In Austria, there is a federalized system of monitoring and supervision of food safety. The standards are set in accordance with European regulations by the Federal Ministry of Health, Family and Youth (BMGJF) and are implemented and monitored by the federal provinces (Länder). The BMGFJ is also in charge of defining the so-called integrated multi-annual control plans or the MIK, which specify inspection and sampling plans for each food sector. The execution of food controls is delegated to food inspectors working for provincial food inspectorates. The control plans cover sampling and inspection issues and concern all facilities dealing with food including food of animal origin. These plans are prepared on the basis of risk categories (RIK).4 Those sectors considered as at higher risk for contamination are the targets of more frequent official controls. The procedures to be adhered to in controls are specified by the ALIAS system, which additionally serves as an internal audit system and a clearing-house for controls. Laboratories are expected to enter the results of controls into ALIAS and the data are then transferred to the Ministry of Health. Meetings between all relevant stakeholders are organized twice a year. In Austria, there are eight laboratories with accreditation for testing samples for the purpose of official controls. All federal provinces but one (Burgenland) host an official laboratory. All laboratories work under the jurisdiction of the national Agency on Food Safety AGES and have ISO 17025 accreditation. These laboratories employ their own technical staff for laboratory tests in addition
4 A category of risk in a scale from 1 to 9 has been attributed to each type of establishment and in the plan is foreseen to carry out at least one inspection every year for the establishment falling in the two highest category, if risk (8 and 9). Information confirmed in interview with Food Inspector from lower Austria – Mr. Neugschwandtner.

to a total of 260 inspectors working on-site. The food inspectors are collectively in charge of controls in 140,000 enterprises.5 The comparatively low number of inspectors is attributed to the high levels of self-regulation within the industry. The official controls are organized in line with the HACCP principles. These are explained in Box 1. Box 1. HACCP and Critical Control Points in the Dairy Sector (Leitlinie über mikrobiologische Kriterien für Milch und Milchprodukte, Gutachten des Ständigen Hygieneausschusses, Bundesministerium für Gesundheit und Frauen, November 2006.) The main parameters controlled in the dairy industry are temperature and time of processing. Two critical control points (CCP) normally identified during the processing of milk are reception and the heat treatment step (pasteurization or sterilization) used to reduce to microbial load. In accordance with HACCP principles, the efficacy of these steps has to be verified on a periodic basis, among else through laboratory analyses of appropriate samples. Details are provided below: CCP for raw milk: upon delivery, before processing and following heat treatment CCP for milk powder: immediately after production, at end of production and MHD (Mindestenshaltbarkeitsdatum – expiration date) Tests carried out on raw milk: (a) microbial counts (upon delivery and before processing), (b) somatic cell counts (upon delivery) and (c) tests for Listeria and enterobacteria (following heat treatment). Tests carried out on milk powder: (a) Listeria (upon production), (b) Salmonella and mould (at MHD) and (c) staphylokokken and enterobacteria (at end of production process).

Following the HACCP guidelines, these tests are the responsibility of food operators. Official controls concentrate on establishing whether the HACCP system is in place (on-site inspections and laboratory tests) and on inspecting end products (laboratory tests). Official controls in other European countries The organization of official controls in Germany is similar to that in Austria. The main authorities for the implementation of the European food safety law is the Federal Ministry of Food, Agriculture and Consumer Protection (BMELV), the Federal Agency for Consumer Protection and Food Safety (BVL) and the Federal Institute for Risk Assessment (BfR). The implementation of laws is carried out by the federal states (Länder), which are also in charge of the registration and approval of establishments. The BMELV sets out the national control plan and on this basis the BVL defines a monitoring plan. The 16 federal states designate official laboratories for carrying out official controls. These also employ in-house personnel as well as food inspectors for carrying out on-site inspections. The main difference between Austria and Germany is that German official laboratories, unlike their Austrian counterparts, are not entitled to carry out work for commercial purposes. This ensures that no conflicts of interest emerge.
5 BM für Gesundheit, Familie und Jugend, Anfragebeantwortung ; GZ: BMGFJ11001/0102-I/A/3/2007; http://www.parlament.gv.at/PG/DE/XXIII/AB/AB.../ fname_085259.pdf.

X. Pei et al. / Food Policy 36 (2011) 412–420 Table 5 Controlling quality of raw milk in China and the EU – a comparison. Source: Authors’ analysis based on EU and Chinese regulations. Parameter Relative density (20 °C/4 °C) Protein Fat Nonfat milk solids (fat-free dry matter) Titratable acidity (measure of microbiological quality) Degree of impurity Aflatoxin M Lead Dioxins Inorganic arsenic China P1.028 g LÀ1 2.95% (m/m) >3.1% (m/m) >8.1% (m/m) 618 64 mg kgÀ1 60.5 lg kgÀ1 60.05 mg kgÀ1 0.05 mg kgÀ1 EU Regulation 2597/97

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C6H6Cl6 DDT Mesophilic bacteria (30 °C) Somatic cell count (raw milk) Antibiotics Streptomycin