“If we look at any event by itself then we have only the context of that single event. If we look at all events we can look at trends, and if it’s a trend we like, we can work to further that trend. If it’s a trend we don’t like, we can work to stop it,” McGuffin told NutraIngredients-USA.
“We intent to compile and collate information from the industry and then what is observable,” he said.
AHPA is calling for submissions from industry in the form of a simple questionnaire. The approach is a distillation of an earlier attempt, when the organization was seeking more detailed information about import interruptions. In this case, AHPA elected not to let the perfect get in the way of the good, and has slimmed down the data input questionnaire to an online tool that can be completed in a couple of minutes.
“We first produced this questionnaire five or six years ago. It was multiple pages and we didn’t get a lot of response. People were telling us they didn’t have the 20 minutes or so it would take to fill it out,” McGuffin said.
Getting at the root of problems
McGuffin said AHPA deliberately chose the term “interruptions” to capture as many of the issues surrounding import and export of herbal ingredients and finished products as possible. The problems can take several forms from brief delays and longer detentions to outright seizures and destruction of goods. Sometimes these events can be the result of a simple misunderstanding on the part of an inspector.
“A real life example is the case of one of our members who was trying to import willow bark from Eastern Europe,” McGuffin said. “The agent at the border misunderstood the regulation. There is a restriction against importing willow bark in a mulch form because it could harbor beetles that could infest willows here in North America. But willow bark as an herbal ingredient never comes into contact with beetles. We got a copy of the instructions the border agent used and we got the authorities to agree that they were confusing, and we were able to get that changed.”
McGuffin said having a big enough data set will allow AHPA to see if these sorts of problems are common with certain ingredients. The goal would then be to work in a non confrontational way with the authorities to get the situation remedied.
“We are going to do that quietly. This is what we did with the willow case. We were able to call up someone we’ve spoken with before who could direct us to the people in charge of that particular operation,” McGuffin said.
Long experience in import/export trade
The import landscape is liable to get increasingly complex as the rules pertaining to the Food Safety Modernization Act (FSMA) come into full force over the next couple of years. McGuffin said AHPA and its members are uniquely positioned to understand these developments because the herbal business has been an import/export business by its very nature.
“There is big demand abroad for herbs that originate in North America just as there is a big demand here for herbs from the rest of the world. Our experience in dealing with import restrictions would go back to CITES (Convention on International Trade in Endangered Species). North American ginseng was listed in 1978, and ginseng exporters have been dealing with CITES their entire careers. Goldenseal is another example. So we’ve had to learn those issues,” McGuffin said.
AHPA also has experience in parsing out trends from long-term data. The organization offers its NDI Database that has compiled the results of notifications dating back almost a decade.
Companies can submit an AHPA import detention report online here.