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Tea & Herbal TeaCompliance in Canada
Louise Roberge
President, Tea and Herbal Association of Canada
AGENDA
1. Introduction
2. TEA 101: Basics
3. MRLs in tea
4. Monitoring
5. Strategies
MISSION & VISIONWe act on behalf of our members who include, Producing Countries,Importers, Packers, Allied Trade, Retailers and TAC TEA SOMMELIER®Professionals, to promote tea.
Our Mission is to be the absolute voice of the Tea and Herbal Industryresponsible for government relations, advocacy and providing PR &communication to consumers & industry.
Our Vision is to be the leading authority and industry voice on all thingstea in Canada.
FOUR PILLARS
Government Relations: Ensure industry stability by positively influencing the FederalLegislative Agenda to support the Canadian tea and herbal industry’s growth.
Communication: Deliver the “Tea is a Healthy Beverage Choice” message to consumers andpromote the benefits of drinking tea.
Membership Services: Serve as the number one source of information and research abouttea and offering a recognized certified Tea Sommelier program.
Networking: Bringing together all levels of the tea and herbal industry’s supply chain toprovide networking opportunities through annual conferences, government liaison and events.
TEA AND HERBAL ASSOCIATIONOF CANADA MEMBERS
• Producing Countries
• Importers
• Packers
• Allied Trade
• Growers
• Retailers
• TAC TEASOMMELIER® Professionals
Reciprocal membership agreements:
American Herbal Products Association
Herb, Spice and Specialty Agriculture Organizations
TEA 101TEA BASICS
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Shen Nong:
Legend has it that the EmperorShen Nong discovered tea in2737 BC while boiling water in theshade of a tree. A light breezecaused a few leaves to fall into hisboiled water, producing a delicateliquor and perfume. The legendsays that when the Emperortasted it he found it to be delicious.
The tree was a wild tea plant. Teawas born.
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http://www.china.org.cn/
LEGENDS
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TEA PRODUCING COUNTRIES
http://www.jfstea.com/en/products.html
CAMELLIA SINENSIS
Tea comes from the plantCamellia sinensis, awarm-weather evergreen.
WHITE GREEN OOLONG
BLACK PU-ERH HERBAL
TEA TYPES
WHITE TEA
Made entirely from leaf buds that are covered in whitish hairs andplucked prior to opening, this tea produces a mild flavour with naturalsweetness.
PREPARATION: 80OC / 185OF (steep 2-5 minutes)
GREEN TEA
These leaves are immediately steamed or heated to prevent oxidationand then rolled and dried, creating a delicate taste that is a light greencolour and very refreshing.
Japanese GreenTea
Chinese Green Tea
PREPARATION: 80OC / 185OF (steep 1-3 minutes)
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JAPANESE GREEN TEA
Leaves are cleaned, sorted,steamed, dried in a hot air tunnel,then rolled into a needle shapeand dried again.
Bright liquor in color, with a cleanfinish, and a taste somewhatreminiscent of seaweed.
JAPAN
JAPAN
JAPAN
JAPAN
JAPAN
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JAPAN
JAPAN
CHINESE GREEN TEALeaf is withered, steamed, rolledand dried
Strong smoky flavour
Unforgiving liquor when over-steeped becoming bitter.
CHINA
CHINA
OOLONG TEA
With partly oxidized leaves, these teas are extremely flavourful andhighly aromatic as they combine the taste and colour qualities of blackand green tea. The flavours of Oolong can vary tremendouslydepending on the length of oxidation – from soft floral and peach notesto fuller toasty nutty flavours.
oxidization range from 20% to 90%
PREPARATION: 80OC / 185OF (steep 2-3 minutes)
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BLACK TEA
CTC(cut, tear, curl)
Orthodox
PREPARATION: 100OC / 212OF (steep 4 minutes)
Made from fully oxidized leaves, these leaves produce anessential oil that determines its aroma, creating a deeprich flavour in a coloured amber brew.
KENYA
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PU-ERH
This tea is produced in the Yunnan province of China and is buriedafter oxidization. It is the only tea that is aged. The tea is full bodiedwith earthy notes.
PREPARATION: 100OC / 212OF (steep 3-5 minutes)
HEALTH
Tea is more than just a refreshingand relaxing drink, its…
• Calorie-Free
• All-natural
• Low in caffeine
• Naturally rich in antioxidants
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HEALTH RESOURCES
TEA SOMMELIER®CERTIFICATION PROGRAM
• 1000+ students in colleges & online
• ONLINE: Delivered by the Academy of Tea
• COLLEGES: Algonquin College, Fanshawe College, MohawkCollege, Niagara Community College, Nova Scotia CommunityCollege, Seneca College and Vancouver Community College
• 197 Certified TAC TEA SOMMELIER® Professionals
• October 2016 received and Award of Distinction from CanadianSociety for Association Executives
TEA,HERBAL TEA &COMPLIANCE
CONSUMPTION VS. PRODUCTION
84%
HOW IT STARTED
The residue of a pesticide detected in dried tealeaves must not exceed the Canadian MRL forthat pesticide or, if an MRL has not beenestablished, the default level of 0.1 ppm
Revocation was announcedin 2003 but no officialtarget date. Default
0.1ppm
CANADA MRL SETTING
ChemicalCompanies
Minor UseProgramme
US
PMRA
Adoption ofCodex MRLs
(EU)
FAO-IGGWG MRLs
Tea ResearchBodies
Field trialdata
Tea Association Canada
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WHAT HAVE WE LEARNED
Chemical Companies• They do not always want to make submissions because of
liability issues on the label
• Do not want to register in certain countries as there is noIntellectual Property protection
• Need to better communicate the risk or benefits of usingchemicals
Growers• They do not use pesticides if they do not need it , it is costly,
they will use it because they can lose their crop.
CFIA SURVEYS
2011-2012
• Testing of coffee, fruit juice and tea for pesticideresidues determines no health risk to consumers
2010-2011
• Of 267 samples, 100% of coffee, 99.6% of juice and75% of tea tested met Health Canada standards forpesticide residues
2009-2010
• 100 samples 59% compliant
MEDIA
Eight of the 10 brands CBCtested contained multiplechemicals, with one brandcontaining residues of 22different pesticides.
"Health Canada reviewed the information provided byMarketplace and for the pesticides bifenthrin,imidacloprid, acetamiprid, chlorfenapyr, pyridaben,acephate, dicofol and monocrotophos determined thatconsumption of tea containing the residues listed doesnot pose a health risk based on the level of residuesreported, expected frequency of exposure and
contribution to overall diet. Moreover, a personwould have to consume approximately 75cups of tea per day over their entirelifetime to elicit an adverse health effect."
MRLS IN TEA
• 17 MRLs set by PMRA
• 4 MRLs pending PMRA
• 3 priorities:
• acetamiprid
• cypermethrin,
• glyphosate
NEW MANDATE
In October 2016, the mandate of the Tea Association of Canadawas broadened to include herbal teas (tisanes) and theassociation became the Tea and Herbal Association of Canada
• There are well over 200 ingredients found in herbal teas
• Major herbal components by sales include Chamomile, Mint,Cinnamon, Citrus, Ginger, Ginseng
• Our work has increased substantially!
MONITORINGCFIA Compliance and Monitoring
“…Of the 715 dried and ready-to-drink tea and herbal teaproducts, 212 samples (29.6%) contained one or more violativepesticide residues…” CFIA 16 June 2016
• The most common pesticides detected in Tea (Camelia sinensis)included:
• bifenthrin*, acetamiprid, imidacloprid*, endosulfan, chlorpyrifos,carbendazim/thiophanate methyl, methomyl, pyridaben, tolfenpyrad*, fenpropathrin* (*denotes MRL existing or pending PMRA)
• The most common pesticides detected in Herbal Teas included:
• Chlorpyrifos, Carbendazim, Imazalil, Piperonyl butoxide, fludioxonil
• For herbal samples there were a total of 41 different violativepesticides detected and some of the samples had multiplepesticides detected per sample
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STRATEGIES TO OBTAINMRLS FOR HERBALS
• Many herbal tea components
• Are grown in Canada, e.g., Crop Group 19 Herbs and Spices
• Are minor crops
• Do not have registered pesticides available to growers in Canada
• Have registered pesticides available to growers in other countries
• An analysis of global compliance and monitoring data indicate thatcrop/chemical combinations may be priorities for minor use and/orMRL submissions, e.g.:
• Chamomile for carbendazim and chlorpyriphos
• Peppermint for carbendazim and propargite
WHAT CROP GROUPS ARE IMPORTANTFOR HIGH VOLUME HERBALS?
CROP GROUP 1: Root and Tuber Vegetables
ginger
CROP GROUP 10: Citrus Fruits
Orange
CROP SUBGROUP 19A: Herbs
CamomileLemongrass
CROP SUBGROUP 19B
Cinnamon & Spice
Peppermint – unknown – may be orphan like Tea
HOW CAN WE WORK TOGETHER?INDICATOR CROPS FOR MRLS
CROP GROUP 19: Herbs and Spices.
We need 4 indicator crops we could use chamomile, lemongrass, cinnamon and we need to find a fourth crop
• Need sufficient residue trial data
• If residue data on the two crops is consistent, then,
An MRL established for the Herbs and Spices Crop Groupwould cover all herbal commodities listed in this crop group
STRATEGY FOR TEA ANDHERBAL
• Work with companies to focus MRL establishment of herbals products
• Monitor PMRA, Codex and WTO for activities on herbal commodities
• Work with our sister organizations in the US (US Tea Association andAmerican Herbal Product Association) and EU to identify efficiencies andpartnerships in the regulatory process
• Partner with herbal commodity grower groups both domestic and import
• Continue to lobby for positive regulatory framework change such asencouraging:
• Canada to adopt international standards
• PMRA to adopt broader definitions for crop groups
Many of the herbal crops are grown in Canada and therefore the PestManagement Center and minor use will be very important
• This provides more opportunity for government assistance in establishing MRLs
HOW CAN WE HELP EACH OTHER?
Louise RobergePresident
416-510-8647
www.tea.ca