Wednesday, October 27, 2021

EU, US markets beckon for morula products but entry will be unusually difficult

With hundreds of millions of customers, the European Union and United States markets are very lucrative and having ratified the Nagoya Protocol on Access to Genetic Resources and the Fair and Equitable Sharing of the Benefits Arising from their Utilisation, Botswana can now sell some of its morula products to these markets. The not-so-good news though is that selling morula products to the EU will be a million times more difficult than setting up a vendor stall at the Gaborone main mall. The latter can be illustrated by the experience of Bronpro, a South African company that sought to sell morula juice to a German company. The company ran into a serious of bureaucratic roadblocks over a protracted period of time until the green light came. “The way is however finally clear for morula juice to be exported into Europe, based on organic certification ÔÇô and the German order still stands. Now a US company has expressed interest, and it’s the US Food and Drug Administration that will have to be tackled next – with another couple of years and more legal fees on the agenda before export to the US is feasible. Meanwhile, the South African market continues to grow,” says a desktop study on morula that was prepared by the Private Sector Development Programme under Business Botswana. Some of the things that the study set out to do were to identify key players in the European market for consideration as distributors of morula products and determine minimum required quality standards set in the European market for imported goods. In actual fact, there is nothing minimum about EU quality standards. At this point in time, only the use of the berries of morula as food or food ingredient is established in the EU. Morula oil cannot be traded in the European Union as a food oil until Novel Food Regulations are complied with and approval granted by the European Commission. In order to trade morula oil as a cosmetic ingredient, the final processor of the oil has to be able to provide a technical data sheet that provides the following minimal information: botanical name and origin; grade of purity; production details; organoleptic parameters (colour, odour, taste, consistency); chemical and physical parameters (peroxide value, acid value, relative density); composition of fatty acids; residues and heavy metals; microbiological testing, aflatoxins and pesticides; storage; and shelf life. Another document that is required is the safety data sheet that contains information about product identification, relevant identified uses and uses advised against, details of the supplier of the safety data sheet, hazard identification, composition/Information on ingredients, first aid measures, firefighting measures, accidental release measures, handling and storage, exposure controls/personal protection, physical and chemical properties, stability and reactivity, toxicological information and  ecological information. There are also general toxicological requirements for cosmetic ingredients and the final processor of the oil ingredient is, when requested by any regulatory authority, required to provide information relating to acute toxicity, irritation and corrosivity, skin sensitization, dermal/percutaneous absorption, repeated dose toxicity, mutagenicity/genotoxicity, carcinogenicity, reproductive toxicity, toxicokinetics and photo-induced toxicity. While doing all these might seem a daunting task, the reward will be huge for those who make the grade. The study says that “Botswana will have to have processes in place to deal with compliance, including competent authorities and national focal points, as well as regulations detailing these.”

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