• December 2020

    General development

    This year, unfortunately, there was no possibility for our staff to visit Wulongshan farm. The strict travel restrictions in China, especially for foreigners, made this impossible. Nevertheless, in addition to the usual EU organic audit, there was again a Fairbiotea inspection by the organic control body CERES this year, which confirmed Wulongshan's compliance with the Fairbiotea requirements.

    Certification, security, sustainability

    The occurrences during the certification process in 2019 had Wulongshan properly shaken up, and had far-reaching consequences. Therefore, we would like to start with a review. During the 2019 organic inspection, an employee of Wulongshan was found to have violated the EU organic regulation, whether intentionally or through ignorance could not be definitively determined. The concerned area was accordingly downgraded to the first year of conversion. Fairbiotea did not purchase any tea from this area. Due to this violation, the integrity of other plots was also questioned, it was prohibited to market the 2019 harvest of some of the plots as organic. The background to this was that the control body doubted the relatively high yield claims for these areas on the part of Wulongshan.

    There are again and again cases of disagreements between farms and control bodies about the yield per hectare that can be achieved. The control bodies, which carry out the EU organic certification in China, basically have no reliable method to determine the yield on a certain area, which is also subject to seasonal and weather-related fluctuations, because no research is carried out on this and no useful statistical data is available. If the yield is set too high by the control body, it opens up space for producers to sell more organic goods than actually can be produced on their certified area. There are companies which then purchase additional quantities from non-certified sources. In this way, producers save the cost of certification and evade inspections, because many practices banned in organic farming can no longer be detected in the final product, which moreover may have been mixed. In China, there is systematic organic fraud with over-certified yields. Fairbiotea has made the control bodies aware of this problem. On the other hand, if the control body sets the yield figures too low to prevent fraud with goods from non-certified sources, the farms feel unfairly treated and disputes arise. Some farms simply change their control body then. Until now, it was not possible to determine an objective quantity for an average yield per hectare of a tea farm in China, and thus to clarify who is right here.

    One more reason for this is the fact that in many places no documentation of the quantity of the freshly harvested tea leaves is done. This additional work of documenting the exact quantity was not considered necessary at Wulongshan either, since the entire quantity comes from the company's own fields and is harvested by hired workers.

    Actual traceability does not exist either; the factual origin of a quantity of tea cannot be determined because there is no objective method for doing so. After appropriate research, it would be possible to determine the geographical origin of a product with reasonable accuracy using elemental and isotopic analyses. Unfortunately, the EU control system in all aspects does not feel responsible to establish such safeguards measures and to initiate the necessary processes. All the more the trade and private organizations like Fairbiotea have to take responsibility to unveil deficits of the control system and to compensate them as good as possible. The research project on provenance determination by means of elemental and isotopic analysis, which Fairbiotea has initiated, is currently waiting to get financed by research funds. For more information on this, see our 2019 newsletter in the archive below.

    Therefore, in 2019 Wulongshan was left with the income from the export of only 60 tons of organic tea. The rest of the harvest, for which the control body revoked the organic status, had to be sold as conventional goods.

    Further investments in safety and sustainability were thus hampered for the time being. The very good analysis results of the 2020 harvest show that the investments made so far in modernizing the factories have been worthwhile.

    Fairbiotea's minimum requirements concerning product safety go beyond organic legislation. Hence, the equipment of the pre-processing factories of two new plots of Wulongshan, that would have finished their conversion period in 2019, did not meet our requirements. The conditions there cannot protect the tea from contamination with environmental toxins, especially due to the extensive use of coal as fuel in the various machines. These plots were planned by Wulongshan as an expansion of the farm, but without direct consultation with Fairbiotea. However, the plots are also too far away from the more modern factories, such as in Guanqiao, for the tea leaves to be processed there.

    For the above reason, these two plots could not be included in Fairbiotea in 2019. Furthermore, Wulongshan was not aware beforehand that a separate certification would have been necessary for these two farms due to a legal requirement, because they are located in a different administrative district than the other plots of Wulongshan. As a result, certification costs would have been significantly higher than if they had been located in the same district, as the basic fee for certifying a farm would have been incurred twice.

    The loss of export revenue due to the restrictions by the control body, along with the higher certification costs, would have unfortunately put Wulongshan in financial difficulties. Wulongshan was forced to abandon both of these two plots and cancel their certification.

    Another development that was set off by the events in 2019 is that Wulongshan's refinery factory had to accept processing and packing orders from surrounding conventional farms. With the small remaining own quantities, it was no longer economical to operate the factory. In order to maintain a higher utilization rate and to be able to employ the permanent workers throughout the year, additional orders were accepted.

    Especially the first spring harvest, which is mainly sold in China, was processed in the refinery factory of Wulongshan, since there are no export goods at this time. This is perfectly legitimate with proper segregation and documentation. However, since Fairbiotea requires strict separation of conventional and organic processing as an extended requirement of the development plan for reasons of organic safety - laboratories today can detect smallest amounts of contamination in organic goods -, plans are underway at Wulongshan to completely separate the processing of conventional goods from organic production in terms of space.

    It is very difficult for small companies to invest in safety, sustainability and modern equipment, because such investments only pay off from reaching a certain production volume. The margin on the sale of organic tea is too low to achieve this already with small quantities. That’s why Fairbiotea gives purchase guarantees to ensure planning security, on the basis of which such investments are possible.

    After the intensive control in 2019, the control in 2020 passed without any noticeable problems. Currently, 38.67 hectares of cultivated area with a production volume of 125 tons of dried tea are certified. We have documented the current development status on our Wulongshan development page.

    Compost production

    In 2020, no compost was produced due to Covid-19 restrictions. For a long time, it was not possible to organize transports of the required ingredients such as manure, etc.. Therefore, Wulongshan has stopped compost production for this year, but plans to continue with it in the coming year 2021.


  • November 2019
    This year’s inspection caused several changes for Wulongshan. Due to a number of misunderstandings between the producer and the control body, the marketing of this year's harvest of some areas as organic goods was prohibited, one of the plots was even downgraded to first year of conversion.
    Mehr lesen ...

    Certification, security, sustainability

    On the initiative of Fairbiotea, in view of the new EU organic regulation 2018/848, the control body CERES reviewed and adjusted their processes. For example, new methods of measuring the cultivation area using Google Maps were applied. Furthermore, a test harvest including primary processing was supervised by several inspectors in order to obtain reliable harvest quantities. These new methods still need further improvement, at this point they are still not working completely satisfying. Here, the third country control body has to take responsibility to develop reliable methods.

    Traceability will play a major role in future. Above described measures were meant to obtain secure numbers for harvest quantities of different plots. A completely different way, namely the verification of origin by means of isotope and element analysis, is pursued by a research project, which is supported by Fairbiotea. Background of this project is the fact that isotopes and elements which are contained in the soil and the underlying rocks leave a measurable signature in plant material. If these signatures are compared to data from soil and rock samples, it’s possible to tell fairly accurate whether a plant had grown on this ground or not. This applies also to dried tea leaves.

    2018 Fairbiotea has accompanied a scientist to three of our partner farms, collecting there samples of the soil, rocks and tea leaves. In Wulongshan such a sampling was also conducted at several plots. The project is now waiting for the allocation of public research funds.

    Compost production

    A very encouraging message from Wulongshan is the construction of their first compost pile in June 2019. The areas available for tea cultivation in Wulongshan are not sufficient to harvest enough biomass for compost production. In addition, there are currently only a few animals in the tea plantation. That is why they had to buy biomass and dung for their first compost pile from exterior sources. For heaping up and turning the pile Wulongshan rented a frontloader.

    Expensive special-purpose machines are still missing, also a suitable semi-permeable foil to cover the compost protecting it against rain und too much moisture. For this purpose Wulongshan constructed a kind of straw roof on a rack above the pile.