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<strong>Helvetas</strong> Vietnam Swiss Association for International Cooperation<br />

CB GEM – Community based Governance, Extension and Market project in <strong>Cao</strong> <strong>Bang</strong><br />

<strong>Cao</strong> <strong>Bang</strong> Office: N003 Ly Tu Trong, Hop Giang Qr.,<strong>Cao</strong> <strong>Bang</strong> Town, Vietnam<br />

Tel: ++84 (0) 26 853 263 / 26 858 111, Fax: ++ 84 (0) 26 856 944<br />

<strong>Feasibility</strong> <strong>study</strong> for<br />

Organic Bitter Tea Production and Marketing<br />

in <strong>Cao</strong> <strong>Bang</strong> Province<br />

a collaboration between CB GEM and the <strong>Cao</strong> <strong>Bang</strong> Bitter Tea Company<br />

Koen den Braber (External Consultant)<br />

Hoang Thi Thu Huong (CB GEM staff)<br />

December 2007


TABLE OF CONTENTS<br />

<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

LIST OF ABBREVIATIONS AND NAMES v<br />

SUMMARY vi<br />

1. INTRODUCTION 1<br />

2. BACKGROUND 1<br />

2.1. Context of <strong>Cao</strong> <strong>Bang</strong> Province 1<br />

2.2. Background information on <strong>bitter</strong> <strong>tea</strong> 1<br />

2.3. Current status of <strong>organic</strong> agriculture in Vietnam 3<br />

3. WHY ORGANIC BITTER TEA FROM CAO BANG 3<br />

3.1. Assessment of the Bitter Tea Market 3<br />

3.2. <strong>Feasibility</strong> <strong>study</strong> 4<br />

4. BITTER TEA VALUE CHAIN 5<br />

4.1. Supply Chain 5<br />

4.1.1. Producers 5<br />

4.1.2. Input supply 6<br />

4.1.3. Collectors 6<br />

4.1.4. Bitter <strong>tea</strong> company (BTC) 6<br />

4.2. Inputs 6<br />

4.2.1. Variety and planting material (including nursery management) 6<br />

4.2.2. Fertilizers 7<br />

4.2.3. Pesticides 7<br />

4.3. Production 8<br />

4.3.1. Field selection and preparation 8<br />

4.3.2. Collecting, yield, timing, etc. 9<br />

4.3.3. Biodiversity 9<br />

4.4. Collection and transport 10<br />

4.5. Processing 10<br />

4.6. Marketing 11<br />

5. ORGANIC PRODUCTION AND MARKETING REQUIREMENTS 16<br />

5.1. What regulations to follow when exporting? 16<br />

5.1.1. Food Safety Regulations 16<br />

5.1.2. Product traceability 17<br />

5.2. Organic regulation and procedures 17<br />

5.2.1. EU <strong>organic</strong> regulations and procedures 17<br />

5.2.2. Japanese <strong>organic</strong> regulations and procedures 18<br />

5.2.3. Korean <strong>organic</strong> regulations and procedures 18<br />

5.2.4. Group Certification 19<br />

iii


<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

6. COST BENEFIT ANALYSIS 20<br />

6.1. Costs of external certification 20<br />

6.2. Costs of operating the ICS 20<br />

6.3. Cost - benefit analysis 21<br />

7. SUMMARY AND CONCLUSIONS 21<br />

7.1. Production and processing requirements 21<br />

7.2. Certification and ICS 22<br />

7.3. Market development for <strong>organic</strong> <strong>bitter</strong> <strong>tea</strong> 22<br />

7.4. Conclusions 23<br />

8. ADDITIONAL LITERATURE USED 24<br />

ANNEX 1 - LIST OF PEOPLE INTERVIEWED 25<br />

ANNEX 2 - NOTES FROM DANIEL V.'s FIELD VISIT 27<br />

ANNEX 3 - MAIN ORGANIC STANDARDS CONSIDERED 31<br />

iv


LIST OF ABBREVIATIONS AND NAMES<br />

ACT Organic Agriculture Certification (Thailand)<br />

ADDA Agriculture Development Denmark Asia<br />

BT Bacillus thurengiensis<br />

BTC Bitter Tea Company (<strong>Cao</strong> <strong>Bang</strong>)<br />

CB Certification Body<br />

DOST Department of Science & Technology<br />

EFA Environmentally Friendly Agriculture (Japan)<br />

EM Effective Micro-organisms<br />

EU European Union<br />

GEM Governance, Extension, Marketing project<br />

GMO Genetically Modified Organisms<br />

<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

GTZ Gesellschaft für Technische Zusammenarbeit (Germany)<br />

ICEA Istituto per la Certificazione Etica e Ambientale (Italy)<br />

ICS Internal Control System<br />

IFOAM International Federation of Organic Agricultural Movements<br />

JAS Japan Agricultural Standard<br />

MAFF Ministry of Agriculture, Forestry and Fisheries (Japan)<br />

MARD Ministry of Agriculture and Rural Development (Vietnam)<br />

MDG Millennium Development Goals<br />

NAQS National Agricultural Product Quality Management Service (Korea)<br />

NPK Nitrogen - Phosphorus - Kalium (chemical fertiliser)<br />

PPSD Plant Protection Sub-Department<br />

RMA Rapid Market Assessment<br />

VND Vietnam Dong (1 USD = 16,020 VND)<br />

v


SUMMARY<br />

<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

Bitter <strong>tea</strong> (Ilex kaushue) is an evergreen tree species that grows in the natural forests in <strong>Cao</strong><br />

<strong>Bang</strong>. Because of its potential as a healthy and unique beverage, the <strong>Cao</strong> <strong>Bang</strong> provincial<br />

authorities started a <strong>bitter</strong> <strong>tea</strong> plantation project program and set up the <strong>Cao</strong> <strong>Bang</strong> Bitter<br />

Tea Company (BTC) for <strong>bitter</strong> <strong>tea</strong> processing and marketing. In 2006, the <strong>Cao</strong> <strong>Bang</strong> <strong>bitter</strong><br />

<strong>tea</strong> market chain was assessed using the Rapid Market Appraisal approach (RMA) as part<br />

of a project supported by <strong>Helvetas</strong>. One of the topics of the action plan identified by the<br />

RMA is to focus on product diversification. Since some foreign companies, mainly from<br />

Korea, have shown interest in <strong>organic</strong> <strong>bitter</strong> <strong>tea</strong>, <strong>Helvetas</strong> and the BTC agreed to carry out<br />

a feasibility <strong>study</strong> of <strong>organic</strong> <strong>bitter</strong> <strong>tea</strong> production in <strong>Cao</strong> <strong>Bang</strong>. An external consultant<br />

specialised in <strong>organic</strong> agriculture and certification and one <strong>Helvetas</strong> staff conducted the<br />

<strong>study</strong>. The <strong>study</strong> included a document review and a field trip to <strong>Cao</strong> <strong>Bang</strong> (November 6-10,<br />

2007). The results of this <strong>study</strong> should then be used by the decision makers to decide if it<br />

would be worth to start a certified <strong>organic</strong> production for specifically identified markets.<br />

Technically there do not seem to be any obstacles for <strong>organic</strong> <strong>bitter</strong> <strong>tea</strong> production.<br />

However, a number of measures have to be taken to conform to the <strong>organic</strong> standards.<br />

Although there is no immediate demand for <strong>organic</strong> <strong>bitter</strong> <strong>tea</strong> (since the Korean buyer is<br />

more interested in "low chemical" than <strong>organic</strong>) it would be useful to consider conversion<br />

to <strong>organic</strong> at an early stage. Since some chemical inputs are being used in the current <strong>bitter</strong><br />

<strong>tea</strong> production, a conversion period of two years has to be considered before the product<br />

can be sold as <strong>organic</strong>.<br />

Organic <strong>bitter</strong> <strong>tea</strong> should be seen as part of the diversification process of the BTC so that a<br />

larger variety of clients can be reached. It would therefore not be recommended to convert<br />

the entire production of the BTC to <strong>organic</strong>. It would be easiest (and most simple to<br />

manage) if for example a certain area will be converted completely and a processing unit<br />

set up there which is dedicated to the <strong>organic</strong> products. Since the processing of <strong>bitter</strong> <strong>tea</strong> is<br />

relatively simple and no expensive machinery is being used, the investment for this second<br />

processing unit would be rather low. A good area for <strong>organic</strong> production would, for<br />

example, be The Duc commune of Nguyen Binh district.<br />

In terms of certification it would be easiest to select one certification body that could<br />

provide all necessary certificates through one inspection visit. To further reduce costs a<br />

certifier with local or regional inspectors should be chosen. To eliminate the need for an<br />

inspection visit to all <strong>organic</strong> producers (and thereby greatly reducing the certification<br />

costs), a group certification system should be set up. This would require an Internal Control<br />

System (ICS), which, if managed by the BTC, would have the added advantage of<br />

providing a good tool for managing the <strong>organic</strong> supply chain and the training of farmers.<br />

Furthermore, the responsible staff of the BTC should develop a good understanding of<br />

concepts related to food safety and certification requirements. This would include <strong>organic</strong><br />

production and certification but also GAP, HACCP, etc. Secondly, the existing overseas<br />

contacts, particularly from Korea and Japan, should be approached to find out what their<br />

requirements are in terms of adherence to specific standards.<br />

To develop a market for <strong>organic</strong> <strong>bitter</strong> <strong>tea</strong> it is essential to develop some <strong>organic</strong><br />

production. This will allow potential clients to check the product and its specifications.<br />

vi


<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

Having some <strong>organic</strong> production (with an ICS) already will also speed up the process of<br />

certification since the conversion period could be reduced at least for the pilot area.<br />

As mentioned in section 4.6, it would be interesting to also explore the possibilities of<br />

creating some new products on the basis of (<strong>organic</strong>) <strong>bitter</strong> <strong>tea</strong>. In many markets <strong>organic</strong><br />

products are successfully introduced as new products and not just to replace a traditional<br />

product. This could really attract new customers who would otherwise not take <strong>bitter</strong> <strong>tea</strong> in<br />

its original form.<br />

vii


1. INTRODUCTION<br />

<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

<strong>Cao</strong> <strong>Bang</strong> province is known as being a poor, remote, mountainous area with 77% of its<br />

total area covered by forest. 86% of the area’s population earns its livelihood from<br />

agriculture and forestry. However, <strong>Cao</strong> <strong>Bang</strong> has a favourable climate and forest area<br />

suited to the development of <strong>bitter</strong> <strong>tea</strong>, a high value medicinal plant.<br />

In the frame of its community based Governance, Extension, Marketing project in <strong>Cao</strong><br />

<strong>Bang</strong> (CB-GEM), <strong>Helvetas</strong> Vietnam supported the Bitter Tea Company in <strong>Cao</strong> <strong>Bang</strong> to<br />

carry out a rapid market appraisal which identified many strengths and weaknesses of the<br />

<strong>bitter</strong> <strong>tea</strong> market. The CB-GEM project then supported the company to establish an action<br />

plan to improve the <strong>bitter</strong> <strong>tea</strong> market situation. One of the identified topics of this action<br />

plan is to carry out a feasibility <strong>study</strong> of <strong>organic</strong> <strong>bitter</strong> <strong>tea</strong> production in <strong>Cao</strong> <strong>Bang</strong>. The<br />

results of this <strong>study</strong> should then be used by the decision makers to decide if it would be<br />

worth or not to start a certified <strong>organic</strong> production for a specifically identified market.<br />

2. BACKGROUND<br />

2.1. Context of <strong>Cao</strong> <strong>Bang</strong> Province<br />

<strong>Cao</strong> <strong>Bang</strong> is a mountainous province with diversified agro-ecological conditions located in<br />

the North of Vietnam. It borders China along more than 300 km. It has a total area of some<br />

6700 km², in which about 77% is covered by forested hills and low mountains (500–1000<br />

m, with some reaching 1900 m). Therefore, <strong>Cao</strong> <strong>Bang</strong> possesses great potential for the<br />

development of natural resources and high-value agricultural and forestry products.<br />

<strong>Cao</strong> <strong>Bang</strong> has a total population of 513,700, where ethnic minority communities make up<br />

more than 95% of the total population across seven different ethnic groups (<strong>Cao</strong> <strong>Bang</strong><br />

Statistics Office, 2005). It is one of the poorest provinces in Vietnam, ranked 60th in the<br />

Millennium Development Goal (MDG) index and the 50th in the poverty index out of 64<br />

provinces of Vietnam (UNDP, 2005). Agricultural production is the most important and<br />

dominant economic sector. It provides the main livelihoods of the population and it is<br />

considered that it will be the province’s economic foundation for the next 20 years (IFAD,<br />

2006).<br />

2.2. Background information on <strong>bitter</strong> <strong>tea</strong><br />

Bitter <strong>tea</strong> is the name for a beverage obtained from various species of the plant genus Ilex.<br />

In Vietnam, <strong>bitter</strong> <strong>tea</strong> (or "cha dang") is obtained from Ilex kaushue, which is distributed in<br />

the North of Vietnam, mainly in <strong>Cao</strong> <strong>Bang</strong> province but also in Ha Giang and a few other<br />

provinces. In China, two groups of plants were traditionally being utilized for <strong>bitter</strong> <strong>tea</strong> (or<br />

"Ku Ding Cha"): several Ilex species and the wax tree (Ligustrum robustum). Today, it is<br />

estimated that more than 90% of the Ku Ding Cha used in China is from an Ilex, mainly<br />

Ilex kudingcha (though other Ilex species, such as Ilex latifolia, may be used), while several<br />

species of Ligustrum are substituted in Sichuan Province and in Japan. (Dharmananda,<br />

2002). Both in Vietnam and China the leaves of <strong>bitter</strong> <strong>tea</strong> are prepared and consumed in a<br />

way similar to green <strong>tea</strong>.<br />

In South America many species of Ilex are used for several popular <strong>tea</strong>-like beverages. Ilex<br />

paraguariensis is used to make yerba mate. Drinking mate with friends from a shared<br />

hollow gourd is an extremely common social practice in many South American countries<br />

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<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

but also in Syria and Lebanon. Ilex guayusa is used both as a stimulant and as an admixture<br />

to the hallucinogenic <strong>tea</strong> "ayahuasca". The leaves of I. guayusa have the highest caffeine<br />

content of any known plant in the world. In North and Central America, Ilex vomitoria was<br />

used by the Native American Indians as a ceremonial stimulant and emetic known as the<br />

"black drink". As the name suggests, the <strong>tea</strong>'s purgative properties were one of its main<br />

uses, most often ritually. (Wikipedia)<br />

Research at the Triet Giang Agriculture University in China found that there are 16 amino<br />

acids belonging to saponin compounds in fresh <strong>bitter</strong> <strong>tea</strong> leaf. These amino acids strengthen<br />

the metabolic process in the human body and are closely related to the body’s nutrition<br />

structure. Other scientific investigations defined that leaves and buds from <strong>bitter</strong> <strong>tea</strong> contain<br />

many ingredients that can effectively:<br />

reduces blood lipid and cholesterol levels<br />

regulates blood pressure<br />

enhances bile excretion<br />

has a tranquillizer effect<br />

assists heart function, and inflammation relief<br />

has a detoxifying effect, and alcoholic toxin relief<br />

stimulates digestion<br />

have a diuretic effect<br />

In China, Ku Ding Cha has been known for hundreds of years and was first described in<br />

1765 in the "Bencao Gangmu Shiyi". One of the main growing locations for Ilex is in<br />

Guangxi Province of south-western China. The oldest Ilex tree is found growing there: it is<br />

about 30 meters high and has grown for centuries. Guangxi has about 1,400 hectare of Ilex<br />

kudingcha trees under cultivation. In 1997 an Institute was established in Guangxi to<br />

research and develop Ku Ding Cha and other local medicinal plants (Dharmananda, 2002).<br />

Ilex kaushue is an evergreen tree species that grows in the natural forests in <strong>Cao</strong> <strong>Bang</strong>. Its<br />

height varies from 20-30m and the diameter is up to 0.6m. The moist, limey and rocky<br />

mountain areas above 600m are suitable for <strong>bitter</strong> <strong>tea</strong> growing. In 1996, Chinese buyers<br />

purchased a vast quantity of fresh <strong>bitter</strong> <strong>tea</strong> leaves and young branches collected from the<br />

<strong>Cao</strong> <strong>Bang</strong> forests, and started intensive production campaigns in China oriented especially<br />

to local and export markets. In Vietnam, national and provincial researchers started<br />

investigations on the medicinal properties of <strong>bitter</strong> <strong>tea</strong>. Moreover, large cultivation and<br />

reforestation with this evergreen tree could help protect watershed areas, the soil and the<br />

environment. Since <strong>Cao</strong> <strong>Bang</strong> has large areas of forestland and a favourable climate for<br />

<strong>bitter</strong> <strong>tea</strong> growing, the tree has been considered as a potential cash crop to help <strong>Cao</strong> <strong>Bang</strong><br />

farmers escape from poverty.<br />

The Vietnamese government, particularly the <strong>Cao</strong> <strong>Bang</strong> provincial authorities,<br />

then started with a <strong>bitter</strong> <strong>tea</strong> plantation project program (under DOST) and the<br />

opening of a factory in <strong>Cao</strong> <strong>Bang</strong> (the BTC under DOST). The province has<br />

invested in the development of <strong>bitter</strong> <strong>tea</strong> plantation, processing and marketing.<br />

<strong>Cao</strong> <strong>Bang</strong> <strong>bitter</strong> <strong>tea</strong> has gradually become well-known particularly in the local<br />

market and apparently also has a high potential for the export market (EU,<br />

Japan and Korea). However, these markets have not been targeted very<br />

intensively yet, mainly because of a lack of <strong>bitter</strong> <strong>tea</strong> supply (which does not<br />

- 2 -


<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

even satisfy yet the domestic market) but also because of a lack of knowledge<br />

of these markets.<br />

2.3. Current status of <strong>organic</strong> agriculture in Vietnam<br />

Although it can be said that, as in all other countries in the world, all farmers were growing<br />

crops <strong>organic</strong>ally hundred years ago, <strong>organic</strong> farming according to the international<br />

understanding is quite new to Vietnam. Around 10 years ago some foreign companies<br />

started working with local companies and farmers to grow crops <strong>organic</strong>ally for export.<br />

After many years with only a few hundred hectares under <strong>organic</strong> management, there is<br />

presently an estimated 6,475 hectares of <strong>organic</strong> land (Willer & Yussefi, 2006). However,<br />

according to additional information collected by the consultant an additional 6000 - 7000<br />

ha has not been included in the report. The main <strong>organic</strong> products are herbs such as<br />

cinnamon, star anise and ginger, fruits, <strong>tea</strong>, cashew, shrimps and basa fish. These products<br />

are certified according to the standards of the importing countries, such as Europe and the<br />

USA, and foreign certification agencies carry out the inspection and certification work.<br />

The local market has not been developed at all, although one company tried to introduce<br />

<strong>organic</strong> vegetables to consumers in Hanoi some years ago. Few international and local<br />

organizations are supporting <strong>organic</strong> agriculture (main exceptions ADDA and GTZ). The<br />

Government also has no specific policies to support the development of <strong>organic</strong> agriculture<br />

in the country and as a result there is still little attention for <strong>organic</strong> farming from research<br />

and the extension service. However, in December 2007 the Ministry of Agriculture and<br />

Rural Development (MARD) issued national basic standards for <strong>organic</strong> production, which<br />

can now be used as a reference for producers, processors and others interested in <strong>organic</strong><br />

products for the local market. MARD is planning to set up a certification system for the<br />

local market but a timeframe for this activity has not been developed yet.<br />

3. WHY ORGANIC BITTER TEA FROM CAO BANG<br />

3.1. Assessment of the Bitter Tea Market<br />

In 2006, the <strong>Cao</strong> <strong>Bang</strong> <strong>bitter</strong> <strong>tea</strong> market chain was assessed using the Rapid Market<br />

Appraisal approach (RMA). The main objectives of the appraisal included:<br />

To analyse the actual state of the <strong>Cao</strong> <strong>Bang</strong> <strong>bitter</strong> <strong>tea</strong> market chain;<br />

To identify appropriate intervention actions in order to improve the <strong>Cao</strong> <strong>Bang</strong><br />

<strong>bitter</strong> <strong>tea</strong> market chain;<br />

To elaborate the concrete plan for the intervention actions.<br />

The RMA estimated that <strong>Cao</strong> <strong>Bang</strong> <strong>bitter</strong> <strong>tea</strong> has a share of about 10% of the domestic<br />

market, with the majority of <strong>bitter</strong> <strong>tea</strong> coming from China. With regards to the national<br />

production, the <strong>Cao</strong> <strong>Bang</strong> Bitter Tea Company (BTC) is the largest producer, with an<br />

annual return of around 1 billion VND per year (on a total turnover of around 4 billion<br />

VND). There are, however, also many smaller processors, who use the name (<strong>Cao</strong> <strong>Bang</strong>)<br />

<strong>bitter</strong> <strong>tea</strong> while allegedly they source their <strong>tea</strong> from China. (The shape of the BTC's <strong>bitter</strong><br />

<strong>tea</strong> is quite specific and very different from the shape of the Chinese <strong>bitter</strong> <strong>tea</strong>.)<br />

Market demand for <strong>bitter</strong> <strong>tea</strong> started to decline in 2004. As a result, the number of BTC<br />

outlets and distributors has declined across the country. Bud <strong>tea</strong> is still in high demand but<br />

the <strong>tea</strong> bags (using cut <strong>tea</strong> leaves and left-overs from the production of bud <strong>tea</strong>) are more<br />

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<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

and more difficult to sell. At the time of the feasibility <strong>study</strong> the production of <strong>tea</strong> bags was<br />

already stopped completely.<br />

According to the RMA, <strong>bitter</strong> <strong>tea</strong> is mostly bought as a gift, with the highest demand in<br />

winter, during holidays, festivals and in particular the Tet holiday. A small group of people<br />

buys <strong>bitter</strong> <strong>tea</strong> for personal consumption, mainly because of its health properties.<br />

Some of the reasons for the low sales volume include the fact that consumers are not<br />

convinced about the health qualities of the <strong>bitter</strong> <strong>tea</strong> or even have a negative feeling about<br />

the <strong>tea</strong> (since it has been reported that <strong>bitter</strong> <strong>tea</strong> has a negative effect on fertility and<br />

reproductive health) 1 . For the BTC in particular, the price of their products is relatively<br />

high while the packaging is not so attractive. However, despite the apparent health benefits,<br />

many people are not very interested in <strong>bitter</strong> <strong>tea</strong> because the product is just too <strong>bitter</strong> and<br />

they would prefer drinking green <strong>tea</strong> or some other beverage.<br />

The RMA concluded that the following solutions should be prioritised in order to improve<br />

the <strong>Cao</strong> <strong>Bang</strong> <strong>bitter</strong> <strong>tea</strong> value chain:<br />

To mark the boundaries of growing materials according to cultural and<br />

ecological conditions and habits of each region;<br />

To determine the origin of the <strong>bitter</strong> <strong>tea</strong> tree's origin;<br />

To invest in and protect existing growing areas continuously;<br />

To (set up strategies and implement research to) diversify the product;<br />

To change some products into functional products; and<br />

To design the product and its packaging in accordance with the targeted clients<br />

and in a more professional manner.<br />

(Pham, 2006).<br />

3.2. <strong>Feasibility</strong> <strong>study</strong><br />

In parallel with the RMA, <strong>Helvetas</strong> had some discussions with the BTC on activities to<br />

improve the <strong>bitter</strong> <strong>tea</strong> production and marketing. One of the topics of the action plan<br />

identified by the RMA is to focus on product diversification. Since some foreign<br />

companies, mainly from Korea, have shown interest in <strong>organic</strong> <strong>bitter</strong> <strong>tea</strong>, <strong>Helvetas</strong> and the<br />

BTC agreed to carry out a feasibility <strong>study</strong> of <strong>organic</strong> <strong>bitter</strong> <strong>tea</strong> production in <strong>Cao</strong> <strong>Bang</strong>.<br />

Main objectives of the feasibility <strong>study</strong>:<br />

To review the existing <strong>bitter</strong> <strong>tea</strong> value chain (inputs, production, processing,<br />

marketing) by emphasising the most important topics in regard to the<br />

conversion to the <strong>organic</strong> farming system;<br />

To review the standards for <strong>organic</strong> products for some of the main markets<br />

(Japan, Korea, and EU)<br />

To make a cost benefit analysis to assess whether or not a conversion to the<br />

<strong>organic</strong> standard is profitable<br />

To analyse the changes or modification in the <strong>bitter</strong> <strong>tea</strong> value chain (inputs,<br />

production, processing, marketing) necessary to met the standards and propose<br />

approaches and strategies on how to do it<br />

1 : A more recent <strong>study</strong> has, however, demonstrated that this in unfounded and there is no negative effect of <strong>bitter</strong><br />

<strong>tea</strong> on fertility and reproductive health. (Bui and Bui, 2006)<br />

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<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

An external consultant specialised in <strong>organic</strong> agriculture and certification and one <strong>Helvetas</strong><br />

staff conducted the <strong>study</strong>. The <strong>study</strong> included a document review and a field trip to <strong>Cao</strong><br />

<strong>Bang</strong> (November 6-10, 2007). The field trip, in which staff from the BTC also participated,<br />

included visits to:<br />

Nguyen Binh district: meet farmers planting <strong>bitter</strong> <strong>tea</strong> on sloping land, local<br />

collectors, and district authorities.<br />

Na Giang village, Ha Quang district: meet farmer households planting <strong>bitter</strong> <strong>tea</strong><br />

in paddy field and on sloping land, meet Mr. Nhan – specialist on <strong>bitter</strong> <strong>tea</strong><br />

Visit <strong>Cao</strong> <strong>Bang</strong> Bitter Tea Company: meet company management and visit<br />

<strong>bitter</strong> <strong>tea</strong> processing workshop and nursery at Km 3, <strong>Cao</strong> <strong>Bang</strong>.<br />

Debriefing with <strong>bitter</strong> <strong>tea</strong> company management and product quality<br />

management office in DOST<br />

Visit market places selling <strong>Cao</strong> <strong>Bang</strong> and Chinese <strong>bitter</strong> <strong>tea</strong> and interview<br />

clients<br />

Note: the visit to Dong Khe district to see the <strong>bitter</strong> <strong>tea</strong> processing workshop and to meet<br />

farmer households planting <strong>bitter</strong> <strong>tea</strong> in the forest was cancelled due to bad road conditions.<br />

A list of the persons met is given in Annex 1.<br />

4. BITTER TEA VALUE CHAIN<br />

4.1. Supply Chain<br />

The <strong>bitter</strong> <strong>tea</strong> supply chain in <strong>Cao</strong> <strong>Bang</strong> is relatively straightforward, with a limited number<br />

of actors involved. The supply chain is summarized as follows (distributors are not<br />

included since they were not part of this <strong>study</strong>):<br />

Inputs<br />

(NPK, seedlings)<br />

Producers<br />

Collectors<br />

Processing<br />

(km 3 unit)<br />

Packaging<br />

(BTC head office)<br />

4.1.1. Producers<br />

Bitter <strong>tea</strong> production in <strong>Cao</strong> <strong>Bang</strong> takes places throughout the entire province. A total of<br />

around 4000 households is currently producing <strong>bitter</strong> <strong>tea</strong>, with a total area of 1380 ha..<br />

Originally, <strong>bitter</strong> <strong>tea</strong> was harvested from wild stands growing in the forest. However,<br />

currently production is almost entirely from cultivated <strong>bitter</strong> <strong>tea</strong>. The older <strong>bitter</strong> <strong>tea</strong><br />

gardens (around 1000 ha in the whole province) are characterised by a low density of<br />

planting, with some 3,200 trees/ha. There was not much investment in these fields and, as a<br />

result, production was low. Farmers harvested mostly leaves.<br />

In 2007 the provincial <strong>bitter</strong> <strong>tea</strong> project started to encourage farmers to intensify<br />

production. The density of planting was increased to 10,000 trees/ha and the level of inputs<br />

was also increased. Both seedlings and fertilisers was subsidized by the project. Farmers<br />

are now mostly harvesting buds (or better said "two leaves and a bud", just as in "normal"<br />

<strong>tea</strong>).<br />

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<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

Farmers from all districts in the province supply to the BTC. Focus of production is<br />

currently on three districts, in particular Nguyen Binh. Farmers are not organised but sell<br />

directly to the BTC as individuals.<br />

Total production sold to the BTC during 2007 was nearly 10 tons of fresh leaf (bud). Farm<br />

production is in the order of 1 - 1.5 ton of buds/ha/year for the low density plantings. For<br />

the high density plantings this is higher, up to 3 - 4 ton/ha/year. Prices received by the<br />

farmers from the BTC for one kg of buds is 15,000 VND/kg.<br />

4.1.2. Input supply<br />

Limited external inputs are used in <strong>bitter</strong> <strong>tea</strong> production. From data collected in the survey<br />

it seems that these inputs (mainly chemical fertilisers and planting materials) are also<br />

almost entirely provided by the BTC. Planting materials is coming from the nursery set up<br />

as part of the provincial <strong>bitter</strong> <strong>tea</strong> development project. Input support to farmers is only for<br />

the first year. After that, farmers are supposed to buy all inputs at full cost price .<br />

4.1.3. Collectors<br />

Farmers deliver the <strong>tea</strong> directly to the BTC or through a collector. In each of the districts<br />

there is one collector. BTC staff estimated that 60% of the <strong>tea</strong> delivered to the company<br />

goes through the collectors.<br />

4.1.4. Bitter <strong>tea</strong> company (BTC)<br />

The BTC has a head office in <strong>Cao</strong> <strong>Bang</strong> town and a processing unit at km 3 in <strong>Cao</strong> <strong>Bang</strong>.<br />

Previously, there was also a processing unit at Dong Khe but at the time of the feasibility<br />

<strong>study</strong> this unit was being closed down and equipment was moved to the BTC head office.<br />

Processing of the <strong>tea</strong> is being done at km3, while packaging is done at the head office.<br />

The BTC collaborates with the local extension service to contact farmers and to get<br />

information which farmers are interested in planting <strong>bitter</strong> <strong>tea</strong>. Training and other support<br />

to <strong>bitter</strong> <strong>tea</strong> growers is done by the BTC directly and here the extension service does not<br />

play a major role.<br />

4.2. Inputs<br />

The following section focuses on the use of inputs in the <strong>bitter</strong> <strong>tea</strong> production, with<br />

particular reference to their application under the <strong>organic</strong> standards considered for this<br />

report (EU, Japan and South Korea). This section is based on information collected during<br />

the survey as well as on data from the field visit by Daniel Valenghi to <strong>Cao</strong> <strong>Bang</strong> in May<br />

2007 (see Annex 2). A summary of findings is given in Table 1 at the end of this chapter.<br />

4.2.1. Variety and planting material (including nursery management)<br />

There are no specific varieties for <strong>bitter</strong> <strong>tea</strong>. However, the material used by the farmers<br />

supplying to the BTC is rather uniform since it for a large part originates from the nursery<br />

set up under the <strong>bitter</strong> <strong>tea</strong> project.<br />

Under the <strong>organic</strong> standards considered, seeds and planting material used for <strong>organic</strong><br />

production should be from <strong>organic</strong> origin. This requirement can easily be met once <strong>bitter</strong><br />

<strong>tea</strong> is being grown <strong>organic</strong>ally. Nurseries could be set up that produce planting material<br />

from <strong>organic</strong>ally grown "mother" trees.<br />

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<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

In the current nursery a number of chemical inputs are being used. Fungicides are regularly<br />

applied to control diseases. Also, a growth hormone is being used to stimulate root<br />

formation of the cuttings taken from the "mother" plants. It could not be established<br />

whether this hormone was of a synthetic or natural origin. In <strong>organic</strong> farming natural plant<br />

hormones such as gibberellic acid (as long as it is made from the fermentation process<br />

without the use of GMOs and has not been fortified with prohibited synthetic substances),<br />

indole acetic acid (IAA), and cytokinins are generally allowed as long as they do not<br />

contain prohibited synthetic substances (WSDA, 2006). However, gibberellic acid is not<br />

allowed under the EU <strong>organic</strong> standards.<br />

4.2.2. Fertilizers<br />

During establishment of the seedlings, most farmer use chemical fertilisers (NPK) and<br />

animal manure. The BTC has the following recommendation to the farmers for the planting<br />

and establishment of seedlings:<br />

Year 1: Apply NPK and manure at planting, followed by a second NPK application<br />

later in the year<br />

Year 2: Apply NPK two times<br />

Year 3: Apply NPK two times<br />

From Year 4: Apply NPK one time + weeding<br />

The <strong>bitter</strong> <strong>tea</strong> project provides the NPK (5-10-3) at a subsidized rate to the farmers during<br />

the first year and farmers are expected to buy the fertiliser at the full cost price from the<br />

second year onwards. Most farmers interviewed did not continue to apply the NPK when<br />

they had to pay it fully themselves and applied manure only.<br />

In <strong>organic</strong> agriculture, synthetic (chemical) fertilisers are not allowed. Organic soil fertility<br />

management should include a variety of materials, for example compost, aged animal<br />

manure, green manure and possibly additional mineral inputs from natural sources. Mineral<br />

fertilizers may only be used as a supplement to other practices implemented to ensure longterm.<br />

Compost may be difficult to apply on sloping land but here green manures will be<br />

very effective, also to control erosion.<br />

Animal manure can only be used when it is aged or hot composted. Ageing and hot<br />

composting are normally not used for manure applied in the current <strong>bitter</strong> <strong>tea</strong> plantations.<br />

Some farmers say that their manure is composted but not by hot composting. In some<br />

cases, EM is used in the composting. EM is allowed in <strong>organic</strong> but not an essential input.<br />

4.2.3. Pesticides<br />

Some farmers use insecticides (Trebon, Bassa) to control pests in the <strong>bitter</strong> <strong>tea</strong> plantations.<br />

Pests targeted were aphids and some kind of leaf rolling caterpillar. Diseases do not seem<br />

to pose a problem in the field, but fungicides are regularly applied to control diseases in the<br />

nursery. One farmer was observed to have used a herbicide in his <strong>bitter</strong> <strong>tea</strong> plantation.<br />

In <strong>organic</strong> agriculture, chemical plant protection chemicals are prohibited. Organic pest and<br />

disease management should be based on growing a healthy crop and the application of a<br />

variety of preventive measures. In emergency situations, botanicals or biological sprays<br />

could be used, for example Bacillus thurengiensis (BT) against caterpillars.<br />

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4.3. Production<br />

<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

4.3.1. Field selection and preparation<br />

Bitter <strong>tea</strong> is normally planted as a single crop in a field. Sometimes, maize is grown among<br />

the small <strong>bitter</strong> <strong>tea</strong> plants during the first year. In cases where other crops are grown in the<br />

same field as the <strong>organic</strong> <strong>bitter</strong> <strong>tea</strong>, then these other crops should also be grown <strong>organic</strong>ally.<br />

Most farmers have also other crops then <strong>bitter</strong> <strong>tea</strong> and these normally grow in separate<br />

fields. In these other crops (rice, maize, fruit trees, vegetables) farmers commonly use some<br />

chemical inputs, such as urea fertilizer and pesticides, although the level of use is not very<br />

high. The use of chemicals in these fields could contaminate the <strong>organic</strong> fields.<br />

Bitter <strong>tea</strong> fields with adjacent rice fields. Use of chemicals in the rice field would pose contamination risk to <strong>organic</strong><br />

production of the <strong>bitter</strong> <strong>tea</strong>. (Picture left at The Duc, Nguyen Binh. Picture right at Nam Tuan, Hoa An.)<br />

According to the <strong>organic</strong> standards, if prohibited substances are used on adjacent fields, the<br />

<strong>organic</strong> field must have a buffer area to prevent chemical contamination. Since most of the<br />

<strong>bitter</strong> <strong>tea</strong> field observed during the survey are quite large, this requirement should not pose<br />

any problems, except that farmers may have to cut down some <strong>bitter</strong> <strong>tea</strong> trees that are too<br />

close to the field border. Alternatively, farmers could always decide to stop using<br />

chemicals also in their other fields.<br />

Another important aspect of <strong>organic</strong> production is the prohibition of parallel production,<br />

which means that it is not allowed for a farmer to grow a crop in one field <strong>organic</strong>ally and<br />

in another field with chemicals. The emphasis is on the field, which means that even when<br />

a crop is grown <strong>organic</strong>ally but other crops in<br />

the same field not, then this plot cannot be<br />

considered as <strong>organic</strong>. Therefore, farmers<br />

should not be allowed to convert only part of<br />

their <strong>bitter</strong> <strong>tea</strong>. If they convert, they should<br />

convert all their plots with <strong>bitter</strong> <strong>tea</strong> and, where<br />

applicable, grow all the crops in those plots<br />

<strong>organic</strong>ally.<br />

Clearing primary forest for <strong>organic</strong> farming is<br />

prohibited as well as the burning of stalks,<br />

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<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

straw and other materials. During the survey, it was observed in one plot that trees were cut<br />

to plant <strong>bitter</strong> <strong>tea</strong> and that the field was burned. (See picture on the right.)<br />

No forest should be cut for <strong>bitter</strong> <strong>tea</strong> planting and burning should not be practised.<br />

Available plant material should be composted or used as mulch.<br />

Farmers in The Duc commune of Nguyen Binh district mentioned that in their commune a<br />

lot of land was available for <strong>bitter</strong> <strong>tea</strong> planting. The soil in large areas of the commune is<br />

too poor to grow food crops but still suitable for <strong>bitter</strong> <strong>tea</strong>. However, it was also noted that<br />

there is now not enough maize in the commune because the land is used for <strong>bitter</strong> <strong>tea</strong>. To<br />

compensate for the loss of income from maize farmers now have to go and work sifting soil<br />

in the gold mine.<br />

Two remarks have to be made here. First is that <strong>bitter</strong> <strong>tea</strong> planting should not go at the cost<br />

of planting food crops. Although there is no <strong>organic</strong> standards specifically forbidding this<br />

practices, it is definitely against the spirit of <strong>organic</strong> production. Therefore, care should be<br />

taken in selecting what land to use for <strong>bitter</strong> <strong>tea</strong> planting. Secondly, the river that flows past<br />

the gold mine and through the commune seems very polluted. This river is a major source<br />

for irrigation of the commune. No water samples were taken during the survey but the<br />

water is very muddy and full with soil. Farmers also said that the water is very polluted. If<br />

this water is to be used for irrigating <strong>organic</strong> <strong>bitter</strong> <strong>tea</strong>, it should be tested and not contain<br />

any contaminants in the form of heavy metals, pesticides or other chemicals.<br />

4.3.2. Collecting, yield, timing, etc.<br />

Farmers collect buds by hands regularly during the year. Farmers interviewed said that they<br />

use new bags (bought in the market) to bring the <strong>tea</strong> to the BTC. There is almost no storage<br />

at the farm since the <strong>tea</strong> has to be at the processing unit within 24 hours after plucking.<br />

Bags and container used for transporting and storing <strong>organic</strong> product must be clean or new.<br />

Synthetic fertilizer bags are not allowed.<br />

4.3.3. Biodiversity<br />

Bitter <strong>tea</strong> is originally a plant from the forest. However, cultivated <strong>bitter</strong> <strong>tea</strong> is mostly<br />

grown as a monocrop. Conservation of biodiversity is an important aspect of <strong>organic</strong><br />

production, although few regulations have specific rules on how to conserve biodiversity.<br />

However, the IFOAM Basic Standards (which serves as the reference for many national<br />

and private <strong>organic</strong> standards) requires relevant measures to be taken for the provision and<br />

improvement of biodiversity.<br />

Improving biodiversity should, however,<br />

not only be seen as a requirement for<br />

<strong>organic</strong> farming alone, but also as<br />

something to enhance the "natural" image of<br />

<strong>bitter</strong> <strong>tea</strong> which may be appreciated by a<br />

number of customers. (As already expressed<br />

to the BTC by a Japanese company<br />

interested in buying <strong>bitter</strong> <strong>tea</strong> from <strong>Cao</strong><br />

<strong>Bang</strong>.)<br />

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<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

In South America, <strong>bitter</strong> <strong>tea</strong> (mate) specialists claim that the taste of <strong>bitter</strong> <strong>tea</strong> grown under<br />

shade in the rainforest is much better than <strong>tea</strong> made from plants grown in full sunlight as it<br />

has more flavour, vitality and nutrition (www.guayaki.com, accessed December 8, 2007).<br />

Biological diversity could be improved through the use of various practices, such as:<br />

Establishment or preservation of non-agricultural areas, such as hedgerows and<br />

woodlands, adjacent to or adjoining the <strong>organic</strong> field;<br />

The planting of plants, adjacent to or between cropped areas, that provide<br />

habitat for beneficial organisms;<br />

Introduction of diverse species into any field or farm parcel planted with a<br />

perennial crop;<br />

Cover cropping; and<br />

Soil building practices.<br />

Good examples for enhancing biodiversity would be growing a green manure in the <strong>bitter</strong><br />

<strong>tea</strong> field (which is also beneficial for maintaining soil fertility) or to plant <strong>bitter</strong> <strong>tea</strong> in a<br />

banana field as done by one farmer visited during the survey.<br />

(See picture.)<br />

4.4. Collection and transport<br />

Farmers bring <strong>bitter</strong> <strong>tea</strong> to the factory themselves or through a collector. In some situations,<br />

staff of the BTC will come to the farmer's house to pick up the <strong>tea</strong>.<br />

As described by one collector the process is as follows: Farmers bring <strong>tea</strong> in the afternoon,<br />

the leaves will be taken out of the bags and put in a layer on the bed (to keep the <strong>tea</strong> cool),<br />

the following morning the <strong>tea</strong> will be packed in bags again and put on the bus for<br />

transportation to the factory.<br />

Farmers use their motorbike for transportation or send the <strong>tea</strong> by bus. The collectors also<br />

mostly make use of the bus service to bring the <strong>tea</strong> to the factory and there is no control<br />

over what is happening during transportation.<br />

Bag and container used for transporting and storing <strong>organic</strong> product must be clean or new.<br />

Synthetic fertilizer bags are not allowed. Care should be taken that during transportation<br />

the <strong>organic</strong> products are not contaminated or mixed with non-<strong>organic</strong> products. As<br />

mentioned under 4.2.3 farmers could use new bags for transporting the <strong>tea</strong>. However,<br />

transportation by bus is risky since there is no control over what happens with the <strong>tea</strong><br />

during the time on the bus or during loading and unloading.<br />

Materials used in or produce from <strong>organic</strong> production must not be stored in the same area<br />

as materials/produce from conventional production. Therefore, appropriate measures<br />

should be taken to avoid mixing in the case when a collector handles both <strong>organic</strong> and non<strong>organic</strong><br />

<strong>tea</strong>.<br />

4.5. Processing<br />

The processing of <strong>bitter</strong> <strong>tea</strong> is quite a simple process. It includes the following steps:<br />

Washing of leaves and cleaning out bad quality leaves<br />

Boiling of the leaves in a wok<br />

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<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

Drying in the open air (for up to 4 days, until dry enough)<br />

Spraying water on the leaves (so that it can be rolled)<br />

Rolling (by hand)<br />

Drying<br />

Quality check (remove badly shaped or coloured <strong>tea</strong><br />

No additives are used in the process, which will make the processing conform to most<br />

<strong>organic</strong> standards.<br />

However, basic sanitation of the<br />

processing unit is limited. Besides, there<br />

is a risk of contamination from the outside<br />

environment. Most of the steps in the<br />

processing take place in the open air and<br />

there is a risk of contamination with dust<br />

and dirt. Also, motorbikes of staff are<br />

parked right next to the drying area, which<br />

also poses a risk. This problem could<br />

easily be solved with some investments to<br />

create separated drying areas, use of<br />

drying tables, etc.<br />

In <strong>organic</strong> production and processing care should be taken not to mix <strong>organic</strong> and non<strong>organic</strong><br />

products in case the processing unit processes both products. The simplest solution<br />

would be to set up a separate processing unit just for the <strong>organic</strong>. Alternatively, one has to<br />

create separate storing areas for <strong>organic</strong> and non-<strong>organic</strong> and to create a system to<br />

physically separate processing of the <strong>organic</strong> and non-<strong>organic</strong> materials, for example by<br />

processing them on separate days. However, this would require the routine cleaning of all<br />

equipment and machinery before starting the processing of the <strong>organic</strong> batches.<br />

4.6. Marketing<br />

Currently, the BTC sells almost exclusively bud <strong>tea</strong>. The production of <strong>tea</strong> bags and instant<br />

<strong>tea</strong> have stopped due to the lack of a market. Organic production is one way to diversify the<br />

product range offered by the BTC through which a larger range of customers could be<br />

reached. Organic <strong>bitter</strong> <strong>tea</strong> is already being offered by some Chinese companies as well as<br />

from South America (mate). There are several companies selling <strong>tea</strong> through the internet.<br />

One of these companies offers an <strong>organic</strong> <strong>bitter</strong> <strong>tea</strong> from China for 26 USD/lb (or around<br />

57 USD/kg) (www.twohills<strong>tea</strong>.com, accessed on November 23, 2007). Below are some<br />

pictures of <strong>organic</strong> <strong>bitter</strong> <strong>tea</strong>s from China sold in the USA:<br />

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<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

However, it would be interesting to also explore the possibilities of creating some new<br />

products on the basis of <strong>bitter</strong> <strong>tea</strong> and this could be especially interesting when combined<br />

with the <strong>organic</strong> product. In many markets <strong>organic</strong> products are successfully introduced as<br />

new products and not just to replace a traditional product. This could really attract new<br />

customers who would otherwise not take <strong>bitter</strong> <strong>tea</strong> in its original form.<br />

The South American mate <strong>bitter</strong> <strong>tea</strong> is sold <strong>organic</strong>ally by one company both in flavoured<br />

form and traditional (unflavoured). Mate is commonly flavoured with mint, orange and<br />

grapefruit skin, etc. Tereré is an infusion similar to mate but prepared with cold water<br />

(rather than with hot water). The vast majority of people in Paraguay take their tereré with<br />

water infused remedial herbs such as mint or lemongrass. When not prepared with plain<br />

cold water, citrus or pineapple fruit juices are usually used (http://en.wikipedia.org/,<br />

accessed November 16, 2007).<br />

Examples of other interesting products are "Materva", a mate soft drink produced with<br />

herbs and <strong>bitter</strong> <strong>tea</strong> chewing gum from the China Hangzhou Tearrow Foodstuff Company.<br />

The Materva Soft Drink Company was founded in Matanzas, Cuba, in 1920. There is also a<br />

diet brand called Diet Materva.<br />

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<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

Table 1. Assessment of improvements to be made to comply with <strong>organic</strong> standards in comparison with the current situation<br />

Applicable Organic Standard Current Situation Improvement to be made<br />

1. Synthetic fertilizers are prohibited. NPK is being used by farmers who planted <strong>bitter</strong><br />

<strong>tea</strong> in their fields as well as in the nursery<br />

2. Chemical plant protection chemicals are<br />

prohibited.<br />

Some farmers use insecticides (Trebon, Bassa) to<br />

control pests in the <strong>bitter</strong> <strong>tea</strong> plantations.<br />

Fungicides are regularly applied to control<br />

diseases in the nursery. One farmer was observed<br />

to have used a herbicide in his <strong>bitter</strong> <strong>tea</strong><br />

plantation.<br />

3. Synthetic hormone is prohibited. A rooting hormone is used in the nursery. It<br />

could not be established whether this hormone is<br />

of a synthetic origin.<br />

4. Farmer must maintain records of sources of<br />

all farm inputs as well as of harvested<br />

products. Records include sales records.<br />

Annual production plans are also required..<br />

5. Parallel production is not allowed: crops in<br />

<strong>organic</strong> fields must be different from crops in<br />

conventional fields.<br />

6. If prohibited substances are used on adjacent<br />

fields, the <strong>organic</strong> field must have a buffer<br />

area to prevent chemical contamination.<br />

At present, farmers do not keep any records.<br />

However, the BTC has a quite detailed system<br />

for keeping records of farmers it is supporting<br />

with establishing new plantations.<br />

Most farmers grow <strong>bitter</strong> <strong>tea</strong> as monoculture,<br />

with a limited number of plots.<br />

Many <strong>bitter</strong> <strong>tea</strong> plantations border fields with<br />

maize, vegetables or rice. Especially in rice and<br />

vegetables chemical fertilisers and pesticides are<br />

being used.<br />

- 13 -<br />

Soil fertility management should include a<br />

variety of materials for example compost, aged<br />

animal manure, green manure and possibly<br />

additional mineral inputs from natural sources.<br />

Compost may be difficult to apply on sloping<br />

land but here green manures will be very<br />

effective, also to control erosion<br />

Organic pest and disease management should be<br />

based on growing a healthy crop and the<br />

application of a variety of preventive measures.<br />

In emergency situation, BT could be used against<br />

caterpillars.<br />

Seedling production without use of synthetic<br />

growth hormone should be studied.<br />

Once farmers start <strong>organic</strong> conversion, they<br />

should start to keep records. BTC's current<br />

system of record keeping could provide good<br />

basis for and ICS.<br />

Farmers should not be allowed to convert only<br />

part of their <strong>bitter</strong> <strong>tea</strong>. If they convert, they<br />

should convert all their plots with <strong>bitter</strong> <strong>tea</strong>.<br />

Farmers should create buffer zones and plant<br />

border crops where required.


<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

7. Clearing primary forest for <strong>organic</strong> farming In one plot it was observed that trees were cut to No forest should be cut for <strong>bitter</strong> <strong>tea</strong> planting<br />

is prohibited.<br />

plant <strong>bitter</strong> <strong>tea</strong>.<br />

8. All farm inputs containing GMOs are<br />

prohibited.<br />

This appears not to be a big issue. None at the moment.<br />

9. If available, <strong>organic</strong> seed and plant material Not an issue at present. Once <strong>bitter</strong> <strong>tea</strong> is being grown <strong>organic</strong>ally, plant<br />

should be used.<br />

material can be taken from these trees.<br />

10. Organic fertilizers should include a variety of Presently only manure is being used by most Organic fertilisers used in <strong>organic</strong> production<br />

materials for example compost, aged animal farmers.<br />

should include compost, green manures, animal<br />

manure, green manure and possibly<br />

manure, mulches and, in certain situations,<br />

additional mineral inputs from natural<br />

sources.<br />

allowed mineral fertilisers.<br />

11. Animal manure can only be used when it is Ageing and hot composting are normally not All animal manure should go through an aging or<br />

aged or hot composted. When manure is not used for manure applied in the plantations. Some hot composting process. (Hot composting would<br />

composted before use, it should be applied at farmers say manure is composted (but not by hot be easier to check and manage.)<br />

least 120 days before harvesting.<br />

composting). In some cases, EM is used for the<br />

composting.<br />

12. Burning of stalks and straw is prohibited. Although this was not observed during the <strong>study</strong>,<br />

it is a common practise among Vietnamese<br />

farmers.<br />

Just follow the rule.<br />

13. Night soil and urban compost are prohibited. Not an issue at the moment. Just follow the rule.<br />

14. For brought-in poultry (ducks, chicken and Some farmers buy in poultry manure from Since in Vietnam there is no commercial free-<br />

birds) manure only the manure from poultry outside.<br />

range poultry production, this means that it is not<br />

raised in free-range farms is allowed.<br />

possible to use poultry manure from outside<br />

sources.<br />

15. Farmer must have measures to prevent top No particular measures against erosion are In areas sensitive to erosion, hedgerows could be<br />

soil erosion and soil salination.<br />

currently being taken.<br />

planted.<br />

16. Measures shall be taken for the provision and Bitter <strong>tea</strong> mostly planted as a single crop. For example, grow green manure in <strong>bitter</strong> <strong>tea</strong><br />

improvement of landscape and biodiversity<br />

fields, grow <strong>bitter</strong> <strong>tea</strong> with other crop, such as<br />

banana, or plant hedgerows and border crops.<br />

17. Bag and container used for transporting and Farmers visited used new bags. However, Establishing processing unit close to production<br />

- 14 -


storing <strong>organic</strong> product must be clean or new.<br />

Synthetic fertilizer bags are not allowed.<br />

18. Materials used in or produce from <strong>organic</strong><br />

production must not be stored in the same<br />

area as materials/produce from conventional<br />

production<br />

19. Spraying of prohibited pesticides in storage is<br />

prohibited.<br />

transport itself is mostly by bus and farmer has<br />

no control over what is happening during<br />

transportation.<br />

Not an issue at the moment.<br />

- 15 -<br />

<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

site makes it possible for producers to deliver<br />

themselves so that the process can be controlled.<br />

Set up separate processing unit for <strong>organic</strong> <strong>tea</strong> or<br />

create separate storage areas for <strong>organic</strong> and non<strong>organic</strong><br />

when only one processing unit used for<br />

both.


<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

5. ORGANIC PRODUCTION AND MARKETING REQUIREMENTS<br />

One of the observations of the survey was that the BTC has a limited understanding of the<br />

requirements and standards related to food safety in overseas markets, including <strong>organic</strong><br />

production. The reason for this survey was an apparent interest from a Korean buyer in<br />

<strong>organic</strong> <strong>bitter</strong> <strong>tea</strong>. However, during our interview with the BTC management it became<br />

clear that this was merely an interest in "clean" production, not in <strong>organic</strong>. This confusion<br />

was caused because the BTC management was of the impression that "clean" production<br />

(which is production with limited use of chemicals) was similar to <strong>organic</strong> production.<br />

Therefore, before going into more detail on the requirements for <strong>organic</strong> production, some<br />

more general information will be given on international for food safety regulations;<br />

5.1. What regulations to follow when exporting?<br />

When exporting agricultural products, either as raw material or processed, to another<br />

country the exporter has to be aware of two main areas where the importing country will<br />

have regulations for the exporter to follow. The first are food safety regulations and the<br />

second requirements on product traceability (FAO, 2007). For the main markets,<br />

European Union, Japan and Korea, which are considered for this report these regulations<br />

are compulsory and have to be followed by exporters or producers who want to sell their<br />

products into these markets. These are the basic regulations to follow for any product to be<br />

exported.<br />

On top of these compulsory standards, additional requirements will apply when the<br />

exporter wants to sell the product under a specific label required in the importing country,<br />

such as <strong>organic</strong> or "low pesticide". These standards are usually called voluntary standards<br />

since they only need to be followed in case an exporter wants to sell under that specific<br />

label (FAO, 2007). Voluntary standards are normally specific for a country. For example,<br />

Korea has a label for "low pesticide" products but a similar label does not exist in the EU<br />

nor are there any international "low pesticide" standards. Also, there is no system for<br />

recognition between "low pesticide" standards of different countries that have such<br />

standards, for example between Vietnam's "safe" vegetables standards and the Korean "low<br />

pesticides" standards. On the other hand, Korea, Japan and the EU have standards for<br />

<strong>organic</strong> products but these are not the same for the three countries. However, there exist<br />

some system for mutual recognition of <strong>organic</strong> certificates between the different countries.<br />

5.1.1. Food Safety Regulations<br />

Producers need to ensure the quality and safety of their produce and avoid all potential<br />

hazards such as risks from contaminated water or from other microbial or chemical<br />

contaminants. Regulations on the maximum residue limits (MRLs) of pesticides an<br />

herbicides are effective both at national and international levels. Producers and exporters<br />

must comply with both the regulations of their own country (in this case Vietnam) and the<br />

regulations of importing countries. They may only use chemicals that are registered for use<br />

on a particular crop and must strictly follow the directions indicated in the instructions<br />

leaflet or on their containers (boxes and bottles) (FAO, 2007).<br />

In the European Union, there are now common limits for many pesticides that apply to the<br />

entire European Union. However, for some pesticides the residue limits vary from country<br />

to country. Each country verifies that regulations are met (usually through the Ministry of<br />

Agriculture) at its point of entry. When European Union countries have not set up<br />

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<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

maximum limits, exporters are required to obtain an import tolerance. It should be noted<br />

that the EU continues to lower the maximum limits of pesticide residues permitted in<br />

products (FAO, 2007).<br />

In Japan, the Ministry of Health, Labour and Welfare and the Environmental Department<br />

are responsible for establishing and testing residue limits. These limits are based on the<br />

Food Sanitation Law (FAO, 2007).<br />

5.1.2. Product traceability<br />

In response to recent problems about food safety (e.g. mad cow disease) and global<br />

terrorism, many governments are increasing control over all stages of food production,<br />

processing and distribution to protect consumers against the biological, chemical and<br />

environmental contamination of food. Traceability (product tracing) is the ability to follow<br />

the movement of food through specified stages of production, processing and distribution.<br />

They also enable efficient recall in case of the products' contamination. Furthermore, they<br />

help determine the origin of a food safety problem, comply with legal requirements and<br />

meet consumers' expectations for the safety and quality of purchased products (FAO,<br />

2007).<br />

The EU regulations on traceability entered into force in January 2005. In order to comply<br />

with these rules, it is important that EU importers identify the origin of products. As a<br />

consequence, the latter could require exporters to comply with traceability requirements<br />

even if the exporter in trading partner countries are not legally required to fulfil the<br />

traceability requirement imposed within the EU. No traceability requirements for exporters<br />

exist in Japan yet (FAO, 2007).<br />

5.2. Organic regulation and procedures<br />

5.2.1. EU <strong>organic</strong> regulations and procedures<br />

In 1991 the EU passed a regulation about <strong>organic</strong> farming. This regulation EEC Regulation<br />

2092/91 contains the legal provisions regarding farming, labelling and monitoring of<br />

<strong>organic</strong> farming for the whole European Community. The Regulation provides the basic<br />

standard for <strong>organic</strong> plant and livestock production and, at the same time creates specific<br />

requirements regarding farming, processing and importation from third countries. All farms<br />

and processing units are submitted, at least once a year, to a programmed inspection. As<br />

well, unannounced random inspections are carried out. The costs of inspection and<br />

certification are to be paid by the company requesting the service.<br />

A European logo for <strong>organic</strong> products exists since February 2000.<br />

However, the use of this label is not mandatory and for now is still not<br />

commonly used.<br />

If an operator in a country outside the EU wants to export <strong>organic</strong><br />

products to the EU, then a certification body (CB) must perform on-site inspections. In the<br />

case of Vietnam, where local <strong>organic</strong> certification bodies do not exist, an international<br />

certifier has to be selected. This could either be one based in Europe or one with a branch<br />

office in Vietnam. Currently, there is only one CB with an office in Vietnam, while several<br />

other CBs use local or regional inspectors.<br />

The EU does not have specific environmental or "low pesticide" food labels and<br />

regulations (although some regulations exist at the national level of the individual EU<br />

- 17 -


<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

member states). However, major EU importers are increasingly using more general food<br />

safety regulations, such as EurepGAP.<br />

5.2.2. Japanese <strong>organic</strong> regulations and procedures<br />

Environmentally friendly agriculture (EFA) is a concept used in<br />

Japan. It encompasses more than <strong>organic</strong> agriculture and this, to<br />

some extend, creates some confusion. The total of EFA certified<br />

farms comprises 22 % of all farm households in Japan. In 2002, <strong>organic</strong> farmers accredited<br />

under the Japan Agricultural Standard law represented only 0.7 % of EFA farmers.<br />

Organic regulations took effect in Japan from 2001. The regulation was revised in 2005<br />

and this new regulation became effective on March 01, 2006. Organic production is<br />

regulated as part of the new Japanese Agricultural Standards (JAS) under MAFF.<br />

Standards are very similar to the EU standards, with main exception of the list of permitted<br />

products. One specific, and very important, requirement of JAS is for a "Grading Manager"<br />

who acts as quality assurance manager. Grading means that prior to authorizing the use of<br />

the JAS seal the person in charge (the Grading Manager) checks that for the respective lot<br />

the <strong>organic</strong> standards and internal instructions were followed. The result of this verification<br />

has to be documented in a checklist, which has to be filed during at least one year. Like the<br />

person responsible for production, the grading manager has to attend a JAS seminar, prior<br />

to first JAS inspection (www.ceres-cert.com/en_jas.html, accessed on October 15, 2007).<br />

MAFF officially recognized the equivalence of EU regulation (EEC) 2092/91 with JAS<br />

standards. Due to this agreement on equivalence, JAS certification can be issued without<br />

additional inspection when the operator is already EU certified. (This process is called "recertification").<br />

However, the JAS certificate should be issued by a certifier, which is<br />

accredited by MAFF.<br />

5.2.3. Korean <strong>organic</strong> regulations and procedures<br />

The Korean <strong>organic</strong> labelling system for fresh produce and grains is called<br />

“environmentally friendly” with four variations of an <strong>organic</strong> seal. The first is Organic<br />

(green), Transitional (light green), No Chemicals (blue), and Low Chemicals (orange).<br />

In terms of inspection and certification, there is an important difference whether a raw<br />

material/fresh product or a processed product is being imported into Korea.<br />

Organic raw materials need to be inspected in the country of production by a Korean<br />

inspector, foreign certifications are not accepted. The applying company pays all expenses<br />

for the inspector to travel to the farm. However, the applicant can be the importer and not<br />

necessarily the producer. The certification lasts one year and the time frame to receive<br />

certification is one to two months after the application is received (Llandry, 2004).<br />

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<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

For a processed product, the determination as to whether the product meets the Korean<br />

standards may be based on a certificate issued by an organization, which satisfies the<br />

qualifications to be a certifying entity under the relevant regulations of:<br />

a) the exporting country, or<br />

b) a reliable organization certified by a recognized international body, such as IFOAM.<br />

In the case of Vietnam, the second option would be the only one applicable.<br />

5.2.4. Group Certification<br />

Organic certification norms and regulations, e.g. the EU regulation, requires an annual<br />

inspection visit of every producer. However, for most smallholders in developing countries,<br />

it is impossible to pay for annual inspection visits by a foreign certification body (IFOAM,<br />

2004).<br />

To cope with this situation, smallholders in developing countries in co-operation with<br />

certification bodies have been developing systems to assure compliance to <strong>organic</strong><br />

standards for producers as a group. Different forms of quality assurance systems of smallholder<br />

groups have developed over time with respect to the nature of the operation and<br />

size, ranging from tens to thousands of individual producers. The systems have in common<br />

the following aspects (IFOAM, 2004):<br />

A central body responsible for marketing and the group's compliance to<br />

applicable standards: (This body can be the buyer, processor, or self organized<br />

cooperative/association.)<br />

One single certification for all individual production as well as processing and<br />

handling activities registered within the group. Individual operators within the<br />

group may not use the certification independently.<br />

Group members operate under contractual or binding membership requirements<br />

specifying the commitment to comply with applicable <strong>organic</strong> standards and<br />

permit inspection, etc.<br />

Presence of an internal control system (ICS), operated by the responsible<br />

central body or an external body contracted by the central body. The ICS<br />

normally maintains files on all members of the group and inspect each<br />

member's operation at least once a year. A list of all individual member<br />

producers is available.<br />

The ICS has two important components:<br />

Training the producers and anyone else who is responsible for processing or<br />

handling the <strong>organic</strong> product in their responsibilities for maintaining the<br />

<strong>organic</strong> integrity of the crop, and<br />

Setting in place the systems for measuring and inspecting the farmers,<br />

processors and handlers compliance to the <strong>organic</strong> standards.<br />

With an ICS in place, the external inspection process is then focused on evaluating the<br />

operation of the ICS and the inspection of a sample of farms not each individual farm<br />

(generally only 10% of the farmers in the group is inspected) as well as processing<br />

facilities.<br />

Coupled with an annual inspection of the operation cum evaluation of the ICS, group<br />

certification thus offers two tiers of control as opposed to just an external annual inspection<br />

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<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

visit. Furthermore, the flow of produce from individual producers is under greater control<br />

with centralised marketing as a group (IFOAM, 2004).<br />

Several ICS have been set up in Vietnam already, for example by the <strong>tea</strong> company Ecolink.<br />

This ICS includes over 200 farmers as well as a processing unit and several warehouses for<br />

<strong>tea</strong> storage. One staff of Ecolink is assigned to manage the ICS, while the ICS inspectors<br />

are government staff (from PPSD or extension service) that do the ICS inspections on a<br />

part-time basis. However, Ecolink is responsible for arranging training for these ICS<br />

inspectors. Some NGOs in Vietnam, such as ADDA, can provide training and assistance in<br />

setting up an ICS.<br />

6. COST BENEFIT ANALYSIS<br />

6.1. Costs of external certification<br />

The cost of certification generally consist of two parts, the first is the certification fee<br />

(based on the kind of certificate needed) and the second the actual cost for the inspection. If<br />

several certificates are required (for example, both EU and JAS) it is most economic to<br />

select one certification body that can issue both certificates through one inspection visit.<br />

Recently, a regional CB (ACT Thailand) set up collaboration with a well-established<br />

European CB (ICEA Italy), which offers a very interesting menu of certification options to<br />

operators in South East Asia, i.e. IFOAM Accredited and BioSuisse certification through<br />

ACT as well as EU, NOP and JAS certification through ICEA.<br />

The cost for certification though this arrangement ranges between 350 and 450 Euro,<br />

depending on the certificate required. The two partners also give a discount if more than<br />

one certificate is requested. Based on the certificate needed there could be some additional<br />

costs, for example for samples to be analysed for chemicals (300 Euro per sample). Total<br />

cost for three certificates: EU (direct) 400 Euro, JAS 440 Euro, Korea (through ACT<br />

private standards) 350 Euro. Total: 1190 Euro - 20% = 950 Euro, plus 300 Euro for the<br />

sample. Total costs 1250 Euro.<br />

Inspection fees are 150 Euro per day per inspector, plus all local and international travel<br />

and food and lodging. With 100 producers there are 10 producers to be inspected plus the<br />

processing unit (3 days), plus 1 day for ICS check. Adding 2 days for travelling to <strong>Cao</strong><br />

<strong>Bang</strong> makes a total of 6 days or 900 Euro (6 x 150 Euro). Finally, we need to add the travel<br />

from <strong>Bang</strong>kok (300 USD) as well as food and lodging for 6 days (240 USD, 6 days @ 40<br />

USD/day).<br />

Adding the costs for certification (1250 Euro or 1750 USD) and the inspection (900 Euro<br />

or 1260 USD) and the travel, food and lodging (540 USD) gives a total of 3,550 USD.<br />

(Please note that the current exchange rate of Euro to US dollar is quite unfavourable.)<br />

6.2. Costs of operating the ICS<br />

There are initial funds required for setting up the ICS and training producers, ICS<br />

personnel and inspectors. However, since most of the costs, including for trainers, are local,<br />

total funding needs are not high. An estimated initial expenditure of 500 - 1000 US dollar<br />

may be needed, which could maybe be requested from <strong>Helvetas</strong> or provincial funding.<br />

- 20 -


<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

Once the ICS has been set up, the annual running costs are mostly limited to payments for<br />

personnel and travel. When the ICS is being managed by the BTC, staff costs will be<br />

minimal and the only costs will be the fee for the inspectors. When working with local ICS<br />

inspectors travel costs will also be quite limited. The requirement for the number of visits<br />

to each farmer in the ICS is normally two per year.<br />

The operation of the ICS should in principle be funded out of the additional income from<br />

sales of <strong>organic</strong> products, unless there is a general fund available for training activities or<br />

so. Farmers could also contribute to the operation of the ICS. Ecolink, for example, has the<br />

agreement with its producers that they pay 5% of the price of the <strong>tea</strong> bought by Ecolink to<br />

the ICS.<br />

6.3. Cost - benefit analysis<br />

Since there are no market data available for <strong>organic</strong> <strong>bitter</strong> <strong>tea</strong>, the cost benefit analysis was<br />

made using a different approach. In discussion with the BTC, the director remarked that the<br />

Korean company interested in the (clean) <strong>bitter</strong> <strong>tea</strong> was willing to buy 1 ton for a price of<br />

250,000 VND/kg. However, the BTC was negotiating for a price of 300,000 VND/kg. So<br />

let us assume a premium of 50,000 VND/kg: possible for a better product, including<br />

<strong>organic</strong>. For an order of 1000 kg, this premium would generate an additional income of 50<br />

million VND or 3,100 US dollar. In section 6.1 the total costs for certification and<br />

inspection were estimated to be 3,550 US dollar annually.<br />

The break-even point for the cost of certification is as follows:<br />

1. With the three certificates required and at the current Euro - US Dollar exchange rate of<br />

1.40, the amount of <strong>tea</strong> required to recover the cost of certification would be 1,140 kg.<br />

2. When only two certificates would be required, for example only the Japanese and the<br />

Korean, then the break-even point would be at 995 kg.<br />

3. When the exchange rate would change in favour of the US dollar (for example, to 1.20)<br />

then the break-even point for three certificates would be at 1,000 kg.<br />

7. SUMMARY AND CONCLUSIONS<br />

7.1. Production and processing requirements<br />

Although there is no immediate demand for <strong>organic</strong> <strong>bitter</strong> <strong>tea</strong> (since the Korean buyer is<br />

more interested in "low chemical" than <strong>organic</strong>) it would be useful to consider conversion<br />

to <strong>organic</strong> at an early stage. Since a variety of chemical inputs is being used in the current<br />

<strong>bitter</strong> <strong>tea</strong> production, one has to consider a conversion period of some two years before the<br />

product can be sold as <strong>organic</strong>. However, during the conversion period all <strong>organic</strong><br />

requirements already have to be met.<br />

Technically there do not seem to be any obstacles for <strong>organic</strong> <strong>bitter</strong> <strong>tea</strong> production. As<br />

discussed in Chapter 4 a number of measures have to be taken to conform to the <strong>organic</strong><br />

standards.<br />

Organic <strong>bitter</strong> <strong>tea</strong> should be seen as part of the diversification process of the BTC so that a<br />

larger variety of clients can be reached. It would therefore not be recommended to convert<br />

the entire production of the BTC to <strong>organic</strong>. Thus, a system has to be developed to manage<br />

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<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

two types of production without threatening the integrity of the <strong>organic</strong> production. As<br />

mentioned in Chapter 4 no farmer should be allowed to convert only part of his/her <strong>bitter</strong><br />

<strong>tea</strong> production. However, managing two production systems will be most critical at the<br />

processing level.<br />

It would be easiest (and most simple to manage) if for example a certain area will be<br />

converted completely and a processing unit set up there which is dedicated to the <strong>organic</strong><br />

products. Since the processing of <strong>bitter</strong> <strong>tea</strong> is relatively simple and no expensive machinery<br />

is being used, the investment for this second processing unit would be rather low.<br />

A good area for <strong>organic</strong> production would, for example, be The Duc commune of Nguyen<br />

Binh district. There currently are 98 farmers registered with the BTC here and production<br />

conditions are quite similar among these farmers making it very suitable for setting up an<br />

ICS. Commune authorities are also quite positive about the <strong>bitter</strong> <strong>tea</strong> project and seem to be<br />

supportive to the idea of <strong>organic</strong> production. A small processing unit could be set up in the<br />

commune that is dedicated to <strong>organic</strong> processing. This number of producers will allow for<br />

the production of reasonably sized batches of <strong>tea</strong> (one ton). A processing unit close to the<br />

producers would also make it possible for the producers to bring their <strong>tea</strong> directly and<br />

personally to the processing unit, eliminating the use of the bus services during which there<br />

cannot be any control over what happened with the <strong>tea</strong>.<br />

7.2. Certification and ICS<br />

In terms of certification it would be easiest to select one certification body that could<br />

provide all necessary certificates through one inspection visit. To reduce costs a certifier<br />

with local or regional inspectors should be chosen. To eliminate the need for an inspection<br />

visit to all <strong>organic</strong> producers (and thereby greatly reducing the costs for certification), a<br />

group certification system should be set up. This would require setting up an ICS, which<br />

would have the additional advantage of providing an excellent tool for managing the<br />

<strong>organic</strong> supply chain, including the training of farmers.<br />

7.3. Market development for <strong>organic</strong> <strong>bitter</strong> <strong>tea</strong><br />

First of all, the responsible staff of the BTC should develop a good understanding of<br />

concepts related to food safety and certification requirements. This would include <strong>organic</strong><br />

production and certification but also GAP, HACCP, etc. Secondly, the existing overseas<br />

contacts, particularly from Korea and Japan, should be approached to find out what their<br />

requirements are.<br />

To develop a market for <strong>organic</strong> <strong>bitter</strong> <strong>tea</strong> it is essential to develop some <strong>organic</strong><br />

production. This will allow potential clients to check the product and its specifications.<br />

Having some <strong>organic</strong> production (with an ICS) already will also speed up the process of<br />

certification since the conversion period could be reduced at least for the pilot area.<br />

As mentioned in section 4.6, it would be interesting to also explore the possibilities of<br />

creating some new products on the basis of (<strong>organic</strong>) <strong>bitter</strong> <strong>tea</strong>. In many markets <strong>organic</strong><br />

products are successfully introduced as new products and not just to replace a traditional<br />

product. This could really attract new customers who would otherwise not take <strong>bitter</strong> <strong>tea</strong> in<br />

its original form.<br />

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7.4. Conclusions<br />

<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

The key conclusion from the feasibility <strong>study</strong> is that there is excellent potential for the<br />

production of <strong>organic</strong>ally certified <strong>bitter</strong> <strong>tea</strong> in <strong>Cao</strong> <strong>Bang</strong>.<br />

BTC management and local authorities, through the DOST, appear to be very supportive to<br />

<strong>organic</strong> production. The DOST also indicated that the province could support the<br />

conversion to <strong>organic</strong> provided that it can be demonstrated that <strong>organic</strong> production will<br />

bring benefit to the farmers.<br />

To achieve <strong>organic</strong> certification the <strong>bitter</strong> <strong>tea</strong> and any other crops should be grown to<br />

comply with <strong>organic</strong> standards.<br />

The use of fertilizer and pesticide inputs is relatively minimal and could be substituted with<br />

acceptable <strong>organic</strong> inputs and farming practices.<br />

In many cases the <strong>bitter</strong> <strong>tea</strong> and other crops are grown in such close proximity that the risk<br />

of contamination from the other crop to the <strong>tea</strong> is too great. If it is not possible to convert<br />

the entire farms to <strong>organic</strong>, appropriate measures should be taken (in the form of buffer<br />

zones) to avoid contamination of the <strong>organic</strong> <strong>bitter</strong> <strong>tea</strong> from chemicals used in the other<br />

crops.<br />

The most cost effective way to organize <strong>organic</strong> certification for small holders is through a<br />

group certification programme that requires all the farmers in a group to be farming all<br />

their crops <strong>organic</strong>ally.<br />

It is most practical to set up a unit that will only process <strong>organic</strong> <strong>bitter</strong> <strong>tea</strong>. All the farmers<br />

supplying to this unit must be certified <strong>organic</strong>. Otherwise a parallel production issue will<br />

arise which is difficult to manage in an ICS.<br />

Costs for external certification are relatively high when three certificates are needed.<br />

However, it seems possible to recover the investment through a reasonable increase in the<br />

export price for the <strong>bitter</strong> <strong>tea</strong> (20%). Volumes of <strong>bitter</strong> <strong>tea</strong> required to recover the cost of<br />

certification are between 1000 - 1150 kg based on the number of certificates needed and the<br />

Euro - US dollar exchange rate.<br />

Since the demand for <strong>organic</strong> <strong>bitter</strong> <strong>tea</strong> from the BTC is not very clear, it may be good to<br />

start with a trial on <strong>organic</strong> <strong>bitter</strong> <strong>tea</strong> production. Key aspects of the trial would be to test<br />

the use of <strong>organic</strong> fertilisers, particularly compost and green manure cover crops, and<br />

<strong>organic</strong> pest and disease management. It would also be worthwhile to test whether <strong>bitter</strong> <strong>tea</strong><br />

would grow well under shade.<br />

- 23 -


8. ADDITIONAL LITERATURE USED<br />

<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

Bui Thi <strong>Bang</strong> and Bui Thi Dieu An (2006). Nghiên cứu về hoá học, độc tính và sản phẩm<br />

mới từ lá chè đắng <strong>Cao</strong> Bằng”, Dec. 2006. (This research was presented in the National<br />

Workshop on medical materials held on 26 th October 2007 in HCM city and published as<br />

workshop material (page 131-140).)<br />

Dharmananda, Subhuti (2002). KU DING CHA. Itmonline article retrieved November<br />

23, 2007 (www.itmonline.org/arts/kudingcha.htm).<br />

IFOAM (2004). Smallholder Group Certification: Training Curriculum for Producer<br />

Organizations. International Federation of Agricultural Movements, Bonn, Germany. 2004.<br />

Landry consulting (2004). OTA Market Overview South Korean Organic Market. Landry<br />

consulting, llc., April 2004.<br />

Pham Tuan Khuong (2006). Rapid Market Appraisal on <strong>Cao</strong> <strong>Bang</strong> Bitter Tea Product.<br />

<strong>Cao</strong> <strong>Bang</strong> Bitter Tea Company and <strong>Helvetas</strong> <strong>Cao</strong> <strong>Bang</strong>. October 2006.<br />

Rundgren, Gunnar (2001). Organic Standards in importing countries: differences and<br />

similarities. FAO conference on Organic Horticulture, Trinidad and Tobago 8-10 October,<br />

2001.<br />

USDA (2004). Food and Agricultural Import Regulations and Standards - Republic of<br />

Korea, Country <strong>Report</strong>. GAIN <strong>Report</strong> - KS4039, USDA Foreign Agricultural Service. July<br />

2004.<br />

Willer, Helga and Minou Yussefi (2006). The World of Organic Agriculture. Statistics<br />

and Emerging Trends 2006. International Federation of Organic Agriculture Movements<br />

(IFOAM), Bonn Germany & Research Institute of Organic Agriculture FiBL, Frick,<br />

Switzerland.<br />

WSDA (2006). European Organic Verification Program Producer Additional<br />

Requirements. Washington State Department of Agriculture Organic Food Program,<br />

document AGR 2204 R/4/06 retrieved November 30, 2007 (http://agr.wa.gov)<br />

- 24 -


ANNEX 1 - LIST OF PEOPLE INTERVIEWED<br />

<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

Mr. Trieu Dao Son Farmer, Nam Un village, The Duc commune<br />

Mr. Dang Dao Phau Farmer, Nam Un village, The Duc commune<br />

Mr Hoang Bich Vien BTC staff responsible for The Duc commune<br />

Mr Say The Duc commune chairman<br />

Mr Cuong Chairman Farmer Union, The Duc commune<br />

Mr Van Head of Nam Un village, The Duc commune<br />

Mr Hoang Van Trang Husband of collector Mrs Nguyen Thi Phuong<br />

Mrs Nong Thi Hue Quality controller, BTC processing unit at km 3 <strong>Cao</strong> <strong>Bang</strong><br />

Mrs Nong Thi Huong Staff in charge of <strong>bitter</strong> <strong>tea</strong> nursery, km 3 <strong>Cao</strong> <strong>Bang</strong><br />

Mrs La Thi Hoa Staff of <strong>bitter</strong> <strong>tea</strong> nursery, km 3 <strong>Cao</strong> <strong>Bang</strong><br />

Mrs Nong Thi Thin Farmer, Na Giang village, Nam Tuan commune, Hoa An<br />

district<br />

Mr Nguyen Van Nhan Bitter <strong>tea</strong> expert and pioneer, former vice-director DOST<br />

Mr Chu Duc Ngoc Director BTC <strong>Cao</strong> <strong>Bang</strong><br />

Mr Hoang The Tung Vice-director BTC, in charge of production<br />

Mr Nong Trong Thang Head of Planning Section, BTC<br />

Mr Phuong Chinh Tuong Staff of Materials Section, BTC<br />

Mr Trieu Vice-director DOST<br />

Mr Hung Staff DOST, Intellectual Property Department<br />

Several <strong>bitter</strong> <strong>tea</strong> sellers at the <strong>Cao</strong> <strong>Bang</strong> central market were also interviewed.<br />

- 25 -


ANNEX 2 - NOTES FROM DANIEL V.'s FIELD VISIT<br />

<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

Meeting with Bitter Tea Company, in <strong>Cao</strong> <strong>Bang</strong> on 14.3.07<br />

• The meeting, attended by the director of the company accompanied by some staff was<br />

an occasion to review the main findings of the RMA which assessed many difficulties<br />

for the <strong>bitter</strong> <strong>tea</strong> (BT) from <strong>Cao</strong> <strong>Bang</strong><br />

• The BT Company, which is underway to become a joint stock company (Vina<strong>tea</strong> or<br />

Vinatobacco ?) counts on the <strong>Helvetas</strong> support to: diversify the product, introduce GAP<br />

or <strong>organic</strong> standards, and support for marketing<br />

• Mr Nien, one of the pioneers of the Bitter Tea promotion in <strong>Cao</strong> <strong>Bang</strong> also attended the<br />

meeting<br />

• China exported <strong>bitter</strong> <strong>tea</strong> some years ago from <strong>Cao</strong> <strong>Bang</strong> and started huge export<br />

oriented plantations<br />

• Bitter Tea became famous abroad via the Chinese marketing and received also an<br />

award in New York<br />

• The Vietnam Government wanted also to start the promotion of BT and opened a<br />

factory in <strong>Cao</strong> <strong>Bang</strong> (the BT company under DOST) and with a <strong>bitter</strong> <strong>tea</strong> plantation<br />

project program (under DOST)<br />

• The assessment is that the marketing is a problem and also the production is not well<br />

established (too much leave production and not enough buds)<br />

• The action plan of the company contains following:<br />

Plantation campaign with a density of at least 10,000 tree/ha (now 3000/ha)<br />

Higher density, higher bud production (closer plantation and cuttings of the<br />

trees)<br />

Research on planting material/varieties and launch info campaign among<br />

farmers<br />

Scientific and commercial promotion of BT on VTV<br />

Collaboration with Institutes and Medicine Departments to prove that BT has<br />

no negative effect on health and to repeat that BT has very good effects<br />

Reduction of <strong>bitter</strong>ness with mixture with another herbal medicinal plant (to be<br />

identified and tested)<br />

Need more capital (equitisation is underway)<br />

Re-organisation of the distribution channel (see RMA report)<br />

Develop marketing (design, size, form, etc.)<br />

Collaboration with elderly people organisation<br />

Knowledge on how to grow <strong>organic</strong>ally <strong>bitter</strong> <strong>tea</strong><br />

Developing clear technical guidelines for farmer<br />

Research and development on <strong>bitter</strong> <strong>tea</strong> growing, especially in regard to the use<br />

of Effective Micro-organism (EM)<br />

• Prices at farm gate: 15,000 VND/kg (buds) and 7,000 VND/kg (leaves)<br />

• Support for contracting farmers (95%): 65% of the price for seedlings and 50% for the<br />

chemical fertilizer prices<br />

• Cost for seedlings is 2362 VND/seedling (normal density is 3000/ha but now<br />

recommended should be 10,000 = 2362 x 10,000 = 23.6 millions/ha as initial<br />

investment !<br />

• Yield 3-4t/ha (?)<br />

• Production accessible for ethnic minorities? Yes (?) How?<br />

- 27 -


<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

Meeting and visit to Mr. Toan household in Na Giang village, Hoa An districton<br />

15.5.07<br />

• She is harvesting buds in this 3 years old plantation with BT trees at an average high of<br />

150-170 cm. She can harvest during all the year but the production is reduced during<br />

the summer (rainy season) because of the attacks of the aphids on the apical leaves<br />

• 40-60 kg/week in spring (50 x 10,000 = 500,000 x 4 = 2 millions per month x 10 = 20<br />

millions/year on 4000 m2). Per ha: 2.5 x 20=50 millions/ha (rice in <strong>Cao</strong> <strong>Bang</strong> is only<br />

10-12 million/ha)<br />

• Harvested leaves must be in the BT Company 24 hours after harvesting (transport!)<br />

• Sometimes she brings the leaves to the company sometimes the company picks up the<br />

leaves<br />

• She is the only in the village who tried BT because the other have not enough land<br />

• Before she made tobacco and rice<br />

• Capital 19 millions for seedlings (5 million own and rest from company)<br />

• No insecticide spraying<br />

• NPK (subsidy from BT Company during the first 3 years) plus compost<br />

• Income with BT is higher than before<br />

• Company pays cash: she made a 5 year contract 2004-2009<br />

• Plantation is for ever. The only labour is to cut the trees and to collect the buds. Wants<br />

to keep the contract when is finished and if company still pays<br />

• Irrigation 2-3 month a year<br />

• For marketing 100% dependent from company. There are no other market issues<br />

• Processing is complicated<br />

• Does not believe that BT can grow in the forest and on sloping land because it needs<br />

irrigation<br />

• Harvest during the first 3 year is very low<br />

• Replace chemical fertilizer by <strong>organic</strong> fertilizer is very difficult. She has compost but<br />

it’s not enough<br />

Visit of <strong>bitter</strong> <strong>tea</strong> nursery on 16.5.07<br />

• The nursery is owned by the BT company and is located in <strong>Cao</strong> <strong>Bang</strong> town<br />

• Production is around 1 million seedlings per year (10’000seddlings /ha =100ha)<br />

• The objective of the BT company is to increase the acreage of BT in <strong>Cao</strong> <strong>Bang</strong> by<br />

1000ha (need 5 years)<br />

• The farmer can grow BT via the participation in the project<br />

• Planting material:<br />

35-40 cm<br />

7-8 leaves<br />

Planting time is during rainy season (beginning is better)<br />

No need for irrigation (???)<br />

Nursery uses 2 chemical fertilizer, 1 hormone and 2 pesticide (Fugaran and<br />

Trebon)<br />

Transplantation rate is high (around 90%)<br />

Price is 2362 VND/seedling<br />

May is best planting season<br />

Farmer pays only 35% (800), not cash but can pay later<br />

• The production is concentrated in 4 districts: Nguyen Binh, Hoa An, Thach An & Tra<br />

Linh. Comparison between the <strong>Cao</strong> <strong>Bang</strong> and China BT origins: the VN grows faster,<br />

has red buds (China green), has higher saponin content<br />

- 28 -


<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

Visit of processing unit in <strong>Cao</strong> <strong>Bang</strong> (3km) on 16.5.07<br />

BT Company employs 10 staff in <strong>Cao</strong> <strong>Bang</strong><br />

• Processing consists in: washing, pre-heating, drying, curling, drying, packaging<br />

• Production is around 300 grams/day/person<br />

• Unit produces 3kg/day in a 6 day week<br />

Visit of processing unit in Dong Khe town. Thach Anh district on 16.5.07<br />

• Has the equipment to produce <strong>tea</strong> bags and instant <strong>tea</strong> but stopped production of both<br />

• Reasons: instant <strong>tea</strong> is too expensive to produce and for <strong>tea</strong> bags there is no market<br />

• Bud production is very same as in <strong>Cao</strong> <strong>Bang</strong> (12 people working)<br />

• Normally needs 5,3kg of fresh leaves to get 1 kg of processed buds<br />

• Price composition:<br />

10,000 of 12grams buds (packaged)<br />

830,000 /kg<br />

100,000 /packaging and handling<br />

100,000 /raw material (12% should be higher)<br />

100’,000 /labour<br />

100,000 /processing material and equipment<br />

430,000 /selling margins (50%)<br />

• The processing is simple and easy and could be decentralised. The BT company<br />

already started to decentralise (but which step exactly?)<br />

• Processing at HH level is possible but HH need to be trained and monitored<br />

• The BT Company has a list of the producers and registers all the purchases made by the<br />

processing unit (which information is registered?)<br />

• Normally farmers bring the buds to the processing station. Sometimes the collection is<br />

made at the district market and then the bulked production of different farmers is<br />

brought to the processing unit<br />

• Farmers normally are paid cash<br />

• BT Company has all 1300 farmers registered (data?): area, number of trees, villages,<br />

production, monitoring<br />

• The BT company has 7 technical staff<br />

• Visits to the farmers: 2 visits/year<br />

• Are there registration of farming techniques<br />

• Normally farmers are not using pesticides with the exception of some big farmers (7?);<br />

what is big? Farmer who has 7-10,000 trees<br />

• All the farmers are using NPK, but only because this chemical fertilizer is subsidized<br />

by the BT Company in the first year<br />

• After the first year only the big farmer keep buying NPK, not the smaller ones. Bt there<br />

is no experiences what happen to the trees with no NPK fertilizer application<br />

• There is no experienced farmers in <strong>organic</strong> techniques<br />

Visit of a second farmer in Dong Khe town, Thach An district on 16.5.07<br />

• Plantation on a smoothly slope land; 2-3000 trees but the trees are definitely too high<br />

for any bud collection (farmer needs now a ladder)<br />

• Plantation supposed to produce leaves, but now leaves aren’t anymore needed by the<br />

market<br />

- 29 -


<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

• Farmer has now to cut down all the trees and then wait again until the trees produces<br />

buds (will most probably loose one year)<br />

• There is a lack of technical guidelines on how to grow BT.<br />

- 30 -


ANNEX 3 - MAIN ORGANIC STANDARDS CONSIDERED<br />

<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

The following section, based on Rundgren (2001), outlines the main characteristics of the<br />

<strong>organic</strong> standards of the EU, the US (NOP) and Japan (JAS) and major differences between<br />

these three sets of standards. Some information is also given on the IFOAM basic standards<br />

since these are relevant for the Korean situation.<br />

Scope<br />

The <strong>organic</strong> regulations are typically regulating the marketing of a product with the claim<br />

"<strong>organic</strong>" or similar. That is the case both for the US and EU regulations. The Japanese rule<br />

is limited to labelling; other market claims (advertisements, etc.) are not regulated.<br />

Terminology<br />

The US rule is regulating the claim that the product is:<br />

"100 percent <strong>organic</strong>"<br />

"<strong>organic</strong>" (>95% <strong>organic</strong> ingredients)<br />

"made with <strong>organic</strong> ingredients" (70%-95% <strong>organic</strong> ingredients)<br />

The rule also regulates the use of the word "<strong>organic</strong>" in ingredients panel. Other words<br />

(ecological, etc.) are not regulated in the rule and therefore permitted to use.<br />

The EU regulation is regulating the claim that a product is:<br />

"Referring to the <strong>organic</strong> production method"<br />

Includes also synonyms like ecological, biological and diminutives bio and eco.<br />

"Organic" (>95% <strong>organic</strong> ingredients)<br />

"Made with x% <strong>organic</strong> ingredients" (70%-95% <strong>organic</strong> ingredients)<br />

No statement is allowed for products below 70% <strong>organic</strong> ingredients.<br />

Categories of production<br />

The EU regulation applies to:<br />

Unprocessed agricultural crop and livestock products<br />

Processed agricultural crop and livestock products for human consumption<br />

Feed stuff<br />

What is not covered under these categories, i.e. textiles, wild fish, wild animals etc. is not<br />

regulated, i.e. <strong>organic</strong> claims can be made.<br />

The Japanese regulation includes agricultural, marine and forest products and processed<br />

products thereof excluding liquors, drugs and cosmetics.<br />

The US regulation covers "crops, livestock and other agricultural products". Some<br />

categories of production are still missing detailed regulation, such as apiculture,<br />

aquaculture and mushrooms. Cosmetics are not included in the rule. Raw materials in<br />

textiles can be referred to as being <strong>organic</strong>.<br />

Conversion periods<br />

"Conversion" is the terminology used in the EU, while "Transition" is used in the US.<br />

Conversion requirements can be split in different parts:<br />

a. Length of the period<br />

b. Start of the period<br />

c. Verification of start<br />

d. Verification of period<br />

- 31 -


<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

a. Length of the conversion period<br />

US: a crop shall come from land that has been free from prohibited materials for 36<br />

months, no exception mentioned.<br />

Japan, EU: the principles shall normally have been applied for at least 2 year before sowing<br />

of annual crops, or 3 years before harvesting of a perennial crop. Exceptions are possible.<br />

b. Start of the period<br />

US: When last prohibited material was used.<br />

EU: <strong>organic</strong> management<br />

c. Verification of start<br />

US, EU: not specified, i.e. conversion can be retrospective.<br />

d. Verification of period<br />

EU, US: No specific requirement other than that an initial inspection must be made before<br />

certification.<br />

Approved inputs<br />

The US rule has a different approach than the EU, Japanese and IFOAM regulations. The<br />

principle in the US is that natural is OK unless specifically prohibited and that synthetic is<br />

not OK unless a positive listing.<br />

Japan and the EU: All inputs need positive listing<br />

The most controversial difference is that Sodium nitrate is allowed for up to 20% of the<br />

crops nitrogen requirements in the US rule. It is prohibited in IFOAM and EU rules.<br />

Manure<br />

EU has limitations on the origin of manure. Not composted conventional manure may be<br />

used if it originates from "extensive animal husbandry". Composted conventional manure<br />

may be used unless it comes from "factory farming".<br />

Japan requires that all manure to be composted.<br />

US NOP has requirements for composting (with some exceptions) of manure regardless of<br />

origin. No limitation of origin of manure.<br />

Seeds and planting materials<br />

Both the EU and US regulation as well as the IFOAM standards have a basic requirement<br />

for <strong>organic</strong> seeds and transplants.<br />

Genetically Modified Organisms (GMOs)<br />

JAS and EU prohibit the use of organisms or products derived thereof that are produced<br />

using recombinant DNA technology. The NOP states that recombinant DNA technology is<br />

considered not compatible with <strong>organic</strong> production.<br />

Parallel production<br />

The EU regulation is restrictive in relation to parallel production, i.e. production of the<br />

same crop both <strong>organic</strong> and not <strong>organic</strong> in the same holding. Only crops of different<br />

varieties may be grown, exception for perennial crops. Inspection must cover also the non<strong>organic</strong><br />

part of the holding.<br />

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<strong>Feasibility</strong> Study Organic Bitter Tea in <strong>Cao</strong> <strong>Bang</strong>: 2007<br />

The US rule does not address parallel production, i.e. there are no special restriction or<br />

limitations for this scenario. However the "<strong>organic</strong> plan" must relate the management<br />

practices to prevent "commingling".<br />

Contamination<br />

Contamination from outside<br />

The EU has no regulations regarding contamination from the outside. NB: it is proposed by<br />

the EU Commission to implement “zero tolerance” in the EU regulation.<br />

The US rule: Products may not contain prohibited substances (read pesticides) at levels<br />

greater than 5% of EPA tolerance. The rule requires defined boundaries and buffer zones.<br />

GMO contamination is not clearly regulated in any of the systems.<br />

Contamination within the farming system<br />

Heavy metals are regulated in a number of EU approved inputs (e.g. Cadmium in<br />

Phosphates). There is no such regulations in the US. Irrigation water is not regulated in EU<br />

and US regulations.<br />

Environmental aspects<br />

Conservation of biodiversity is mentioned in the definition of <strong>organic</strong> in the US rule and<br />

environment is mentioned in the preamble of the EU regulation. No specific rules exist in<br />

the regulations. IFOAM requires relevant measures for the provision and improvement of<br />

landscape and biodiversity.<br />

Social aspects<br />

Not regulated in EU, US or Japan standards. IFOAM has general provision, which are<br />

supposed to be considerably expanded in the new draft.<br />

- 33 -

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