Background Information
Not long ago we received an inquiry from an Australia wine exporter outlining that a number of shipments had been either destroyed or rejected entry to China due to excessive amount of manganese.
According to Wine Australia’s official statement in March of this year, in the past 12 months 14 Australian wines have encountered the same problem. Despite the fact that manganese will never be added to wines produced in any traditional wine making countries, its presence in wines is sometimes hard to avoid since certain regions have manganese rich soils. “Of course the Chinese standard applies to all wines sold in China, not only Australian wine, so this matter is not one that only concerns Australia” says Steve Guy, General Manager of Regulatory Services at Australian Wine and Grape Association (AGWA, formerly named Wine Australia).
Legal Basis
One thing to note is that potassium permanganate, a chemical compound of manganese, is regulated as a food additive in alcoholic products. The maximum level of potassium permanganate permitted for addition and the maximum residue of manganese in alcoholic products are stipulated in GB 2760-2011 National Food Safety Standard Standards for Uses of Food Additives:
| Food Category No. | Food Name | Maximum level(g/kg) of Potassium Permanganate to be added | Remark |
| 15.0 | Alcoholic Products | 0.5 | The amount of residue in alcoholic products is calculated by the amount of manganese, which shall not exceed 2mg/kg |
Besides, there are also specifications of additives different from those abroad that are the major causes of inspection failures with AQSIQ and CIQs. For instance, while fumaric acid is allowed to be added in wines in some countries, similar levels of this additive detected in China will result in non-compliance issues.
So far China seems to have been the only country that imposes such a level on the content of manganese which is in fact a natural nutrient. This problem is a source of great concern among the industry and has had a significant financial impact on several exporters. The problem allows occurs for domestically produced alcoholic products which are often recalled due to manganese problems.
Relevant Testing
Many wine makers believe that this national standard should be canceled for the benefits of both exporters and importers. Steve also mentioned, “We (AGWA) will continue to work through this issue.” Nevertheless before this issue is resolved the safest way is to have relevant testing carried out before shipment.
It is generally accepted that the level of manganese in soil naturally varies between soil type and region. But experts believe that contents of manganese in a particular region are not only defined by soil. There can be variations in a single site from one year to the next depending on climatic conditions. For this reason, contents of manganese from the same region but different vintages are likely to vary from each other.
The testing methods for manganese under the Chinese regulatory framework are specified in GB/T 5009.90-2003 Determination of Iron, Magnesium and Manganese in Foods. Suggestions have been made by experts that it is best to have such tests conducted in a Chinese lab.
“Since we made the recommendation (that Australian producers test their wine for manganese in order to ensure the Chinese standard is not breached) we have not been informed of any shipments that have been found to breach the limit on arrival in China” added Steve Guy.
REACH24H Food Compliance Service Team
Located in the beautiful city of Hangzhou China, The REACH24H FCS Team is a multidisciplinary and multilingual team composed of food technologists, nutritionists, chemists and regulatory analysts. Years of regulatory compliance experience and close ties with authorities has made the FCS team China’s foremost private agency on China food import regulatory compliance issues. If you are planning to launch a food business in China or encounter any problems during food exportation to China, please feel free to contact us for compliance solutions.
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