Ensuring almond quality and safety for consumers around the world
California Almonds are enjoyed by many around the world, and Almond Board of California (ABC) is committed to helping provide a safe and wholesome product. To take a closer look at how ABC pursues this goal, Beth Van Meter, senior specialist, Global Technical & Regulatory Affairs, ABC, sat down to discuss the Pre-Export Check (PEC) program. The PEC program is a systems-based approach to aflatoxin testing in California, which has been accepted by the EU as equivalent to their regulatory requirements.
Q: What is the purpose of the Pre-Export Checklist (PEC) program? How did it come about?
BVM: The purpose of the PEC program is to have a best practice in place to ensure that California Almonds going into the European market are in line with EU requirements related to their regulatory limits for aflatoxins. The EU has been very strict in their aflatoxin maximum limits, and this program facilitates a pre-test and certification step prior to shipment to the EU. Consignments with PEC certificates are subject to less than 1% testing upon entry to the EU.
The PEC program replaced the Voluntary Aflatoxin Sampling Plan (VASP), which originated following an increased number of almond consignment rejections due to elevated aflatoxin levels. Prior to VASP, California Almonds were placed on under Special Measures, which called for mandatory testing at the border. The VASP program introduced a pre-test for aflatoxins and was highly successful. The program helped build up trust among the EU Commission and import authorities, effectively removing California Almonds from Special Measures. The California Almond industry then transitioned to the PEC program to build upon the successes established by VASP.
Q: How does one join the PEC program? What are the requirements?
BVM: In order to participate in the PEC program, handlers should reach out to Bryce Spycher or Sabrina Poth. The program covers almonds being shipped to the EU and only covers almonds that fall under CN codes 0802.11 and 0802.12. The program does not cover other processed almond commodities, such as almond butter. Additional requirements to participate are:
- California Almond handlers must sign an annual Memorandum of Understanding (MOU) with ABC.
- Participants are given a PEC Program Manual and are trained in how to use the ePEC system, a web-based management system, by ABC staff.
- Loads must be pre-tested for aflatoxin at a USDA-approved lab prior to being shipped and demonstrate they are below EU aflatoxin tolerances (10 ppb total / 8 ppb B1).
- Once the load is cleared for shipping, a PEC certificate will be granted. The certificate must be signed off by the USDA within 7 days (non-business days) of departure.
Q: Has the PEC program been successful? Is there a lot of almond handler participation?
BVM: The PEC program has been widely successful in securing almond handler participation and establishing a high level of trust among members of the EU Commission and import authorities. ABC invests in its relationships with the European officials and has brought port authorities over from Belgium, Bulgaria, Poland, Spain and the United Kingdom for educational sessions on how the PEC program works throughout the entire supply chain. Since the inception of the VASP and PEC programs, the California Almond industry has gone from mandatory checks at port to less than 1%, which is outstanding.
Recently, however, we’ve started to see an increase in Rapid Alerts for almond consignments that are shipped outside the PEC program, which is concerning.
Q: What if I am exporting lower grade product? Is there a different process?
BVM: Almonds that are not ready for immediate consumption do not qualify for the PEC program and would instead be subject to additional controls at the border. ABC has developed background information for shippers to ensure they are properly testing and labeling these consignments.
Q: Can you explain what a PEC addendum letter is and why it’s needed?
BVM: Often, there are fields on the PEC certificate that handlers may not know how to fill out, such as which country/customer a product is destined for, who will be receiving the shipment, etc. This had caused some PEC certificates to be sent with incomplete information, resulting in delays at customs upon arrival.
The PEC addendum letter was designed to be sent in conjunction with the PEC certificate, to incorporate the additional information without replacing or changing the outcome of the aflatoxin analysis or Annex II (USDA signature). The letter has been well-received by EU officials and reduced the number of delays.
Q: Is the PEC program mandatory for almond handlers? What might be the alternatives to a PEC program (i.e. non-voluntary regulation)?
BVM: The PEC program is voluntary and very well-utilized by almond handlers. In most cases, if an almond handler is exporting California Almonds to the EU without a PEC certificate, it is likely due to an issue such as not getting the certificate signed by the USDA in time or simply losing the certificate. We always remind handlers that if this does happen, it doesn’t mean their product will not be accepted into the country. It may be subject to additional controls at the border.
Q: Where can I go to learn more?
BVM: You can learn more online by going to Almonds.com/processors/processing-safe-product/aflatoxin.
