A needless bar: How mandatory radiation test hurts importers, consumers

Summary:

• Radiation test certificates increase import costs, delaying shipments and raising prices
• Testing costs range from Tk5,000 to Tk100,000 per consignment
• Feed production costs rise, affecting livestock, aquaculture, and commodity prices
• Most countries have relaxed radiation testing requirements; Bangladesh has not
• Delays and costs harm Bangladesh's competitiveness in exports like aquaculture

The mandatory radiation test certificate for all imported agricultural products significantly increases feed production costs. This is due to shipment delays resulting in port demurrage charges and testing fees, which ultimately drive up food prices in the domestic market, according to sector insiders.

Importers are required to obtain a radiation test certificate for every consignment of agricultural products, specifying the level of Cesium-137 in each kilogram of goods. Cesium-137, a soft metal that emits beta and gamma radiation, is a common byproduct of uranium-235 nuclear fission.

The certificate is mandatory for submission to customs to release shipments, importers say. Obtaining it from the Bangladesh Atomic Energy Commission takes at least seven days, causing shipment delays and resulting in demurrage costs, which are ultimately passed on to consumers. 

Moreover, importers say, they have to spend a minimum of Tk5,000 to Tk100,000 for each test certificate, depending on the value of the imported products.

According to experts, radiation testing directly affects livestock and aquaculture production because most feed inputs in Bangladesh are imported.

"The testing and certification costs increase production costs for farmers and producers," Michael J Parr, project director of Land O'Lakes Venture37, a US-based organisation focusing on food security and sustainable agriculture, told TBS.

"Even more costly are the shipping demurrage charges at ports, as shipments await clearance for testing, which can take weeks. Ultimately, this increases the prices of essential commodities like eggs and chicken, which have traditionally been affordable protein sources for people with marginal incomes," he said.

"It also makes aquaculture exports from Bangladesh less competitive," he added.

Maize, soybean meal, rice husk, fish meal, and flour are some of the main raw materials for feed, most of which are imported.

The Feed Industries Association Bangladesh (FIAB) has long demanded the removal of the mandatory radiation test to reduce import costs and associated hassles.

Nazrul Islam, general secretary of FIAB, said the test certificate increases import costs, ultimately affecting production expenses. Therefore, the relevant regulations should be removed, especially for the import of feed raw materials from SAARC countries, Southeast Asia, and the Asia-Pacific regions.

The radiation test was made mandatory under the Nuclear Safety and Radiation Control Rules of 1997 and the import policy order following the Fukushima nuclear disaster in 2011, to monitor the presence of radioactive isotopes in food.

However, over the past few decades, no excessive levels of radiation have been detected in any imported agricultural products, according to the Bangladesh Atomic Energy Commission.

Of the 55 countries that made radiation testing mandatory after the Fukushima nuclear disaster, 48 have since lifted or relaxed the requirement based on scientific analysis. Some countries now mandate test certificates only for specific products.

However, Bangladesh has continued to enforce the test requirement despite no negative test results being found in the past few decades, leading to unnecessary costs for importers.

This factor, among others, also contributes to Bangladesh lagging behind other South Asian countries, including Pakistan, Sri Lanka, and Vietnam, in the Ease of Doing Business Index. In 2020, Bangladesh ranked 168th out of 190 countries in the World Bank's Doing Business report.

Md Mokabbir Hossain, senior secretary at the Ministry of Science and Technology, told TBS that the ministry is open to lifting the provision if necessary, though they would first need to review the list of products that could be excluded from the mandatory radiation test.

Feed industry bears the burden

According to the import policy order, all agricultural products, processed food items, plant and plant products, poultry, fish and fish products, milk and milk products, meat and meat products, eggs, fish feed, poultry feed, poultry meat, fish meal, and raw materials for the feed industry derived from livestock and fisheries products are required to obtain a radiation test certificate for shipment release.

Sector insiders say Bangladesh's feed industry relies heavily on imports for most of its feed ingredients. The devaluation of the local currency against the dollar has made imports more expensive, compounded by high international prices.

They say the radiation test certificate, which is seen as "unnecessary", adds additional costs, further driving up the cost of feed production.

The price of the dollar is likely to rise this year amid the ongoing foreign currency crunch, which will keep key ingredients for the poultry industry expensive, they said.

Therefore, they believe this is the best time to consider removing the radiation test provision, as the government is currently reviewing the import policy for amendments.

A manager of a poultry feed importing company, speaking on the condition of anonymity, said they have been importing feed ingredients from the same supplier, yet are required to obtain a radiation test report for every consignment, even for partial shipments of the same product.

He said this practice increases their costs. He shared that they have experienced port demurrage multiple times due to delays in obtaining the test report.

He also mentioned that they have raised this issue for a long time, arguing that requiring a test report for every consignment from the same supplier is unnecessary. However, the government has continued to overlook their concerns.

What international bodies recommend

The US Department of Agriculture (USDA)-funded Land O'Lakes works on the Bangladesh Trade Facilitation (BTF) project to help the Bangladesh government improve trade in agricultural products. It also recommended removing the mandatory test certificate to streamline the shipment release process and make it more business-oriented.

The recommendation includes amending both the import policy order and the Nuclear Safety & Radiation Control Rules, based on scientific analysis derived from test report findings and practices in other countries.

Michael J Parr, project director of Land O'Lakes Venture37, said, "Radiation testing procedures are not logical because they are not based on evidence or scientific analysis of food safety risks. For about 30 years, there have been no irregularities or adverse reports on tested products, yet the frequency of tests has not decreased."

"Moreover, the practice is not applied consistently. For example, there are exceptions where testing is not required for products from several Asia-Pacific countries, some of which use nuclear power; however, tests are mandatory for products imported from New Zealand, which is 100% nuclear-free," he said.

He added, "I recommend that the government rationalise the testing of imports and exports in line with international trade practices. The government can implement a risk-based compliance protocol, requiring an assessment of the risk based on the country of origin, analysing evidence related to food safety or biosecurity risks, and tracking data on the importer's/supplier's history of compliance or non-compliance."

According to the International Atomic Energy Agency (IAEA), all food contains natural radionuclides, which are transferred from the soil to crops on land and from water to fish in rivers, lakes, and the sea.

However, the levels of natural radionuclides in food and drinking water are generally very low and safe for human consumption. While natural radiation levels can vary significantly depending on local geology, climate, and agricultural practices, from a public health standpoint, these levels are mostly insignificant, as per the IAEA.

What other countries do

Countries like India, Thailand, Indonesia, Malaysia, Sri Lanka, Vietnam, Cambodia, and Pakistan have no provision for mandatory radiation tests on imported food, according to their import policies.

The US issued an import alert for food from Japan following the Fukushima nuclear disaster in 2011. However, it lifted the alert after finding no evidence of excessive radiation levels in imported food from Japan, based on 10 years of test report analysis.

The EU made radiation tests mandatory for some select countries affected by the Chernobyl incident in 1986. However, there is no provision for radiation tests on imported food from other countries, according to their import policies.

The EU also took cautious measures for imported fish and poultry feeds from Japan after the Fukushima accident. Under these measures, imported products were tested randomly, but the policy was lifted in 2022 after a risk analysis and scientific findings.

In Australia, there is no provision for a radiation test certificate at the port for releasing imported food products. 

While there were concerns after the Fukushima incident, the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) and the Australian government's health department closely observed the situation and concluded that radiation tests were unnecessary after a final assessment.

In New Zealand, there is no requirement for a mandatory radiation test certificate for imported food products. While radiation tests were conducted on a sample basis for food products from Japan after the Fukushima incident, the radionuclide levels were found to be within acceptable limits.