Interpretation of Shanghai's Open Roasted Coffee Production License Review Guidelines: Must-Read for Home Roasters!

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Shanghai Roasted Coffee Open Production Licensing Regulations

Source: Shanghai Food and Drug Administration

To all district market supervision bureaus and the Shanghai Food and Drug Administration Certification and Evaluation Center:

The "Shanghai Roasted Coffee Open Production Licensing Review Regulations" were approved at the 17th Bureau Affairs Meeting on September 12, 2017, and are hereby promulgated. These regulations will be implemented starting from October 25, 2017. Please comply accordingly.

Shanghai Food and Drug Administration

September 25, 2017

(Scope: Publicly disclosed)

Shanghai Roasted Coffee Open Production Licensing Review Regulations

Chapter I General Provisions

Article 1: These regulations apply to the review of licensing conditions for open production of roasted coffee.

Roasted coffee as referred to in these regulations refers to food products made from coffee beans through processes such as cleaning, blending or non-blending, roasting, cooling, and packaging.

Open production refers to a processing method that does not use walls or separate rooms for isolation, allows consumers to view the production facilities and equipment of roasted coffee, while setting up continuous transparent protective facilities between the production area and non-production area to prevent non-food processing personnel from entering the production area.

Article 2: The licensing category for open production of roasted coffee is cocoa and roasted coffee products, with the category name: roasted coffee, and category number: 2002. The food category, category name, variety details, definition, and remarks for open production licensing of roasted coffee are shown in Appendix 1.

Article 3: Sub-packaging of this type of product is permitted.

Article 4: The documents and standards referenced in these regulations become part of these regulations through reference. For all referenced documents and standards, their latest versions (including all amendment sheets) apply to these regulations.

Chapter II Production Site

Article 5: The site selection, ceiling, walls, floor, laboratory setup, and external warehouse setup of the production area shall comply with the relevant provisions of the "Food Production Licensing Review General Rules" regarding production sites.

Article 6: The area and space of the production area shall be appropriate for the product varieties and quantities. The production area and non-production area shall be separated by continuous transparent protective facilities with a height of not less than 1.05 meters to effectively prevent non-food processing personnel from entering the production area.

Article 7: Raw materials, auxiliary materials, finished products, and other materials should be stored in separate warehouses or areas according to their different properties. Cleaning agents, disinfectants, pesticides, lubricants, fuels, and other materials should be placed in dedicated cabinets. Materials stored in warehouses or areas should be kept at an appropriate distance from walls and floors, and clearly identified to prevent cross-contamination.

Chapter III Equipment and Facilities

Article 8: Water supply and drainage, cleaning and disinfection, waste storage, lighting, and inspection facilities shall comply with the relevant provisions of the "Food Production Licensing Review General Rules" regarding equipment and facilities.

Equipment used for monitoring, controlling, and recording, such as pressure gauges, thermometers, recorders, etc., should be regularly calibrated and maintained.

Article 9: Production equipment appropriate for the product varieties and quantities should be equipped, including magnetic screening, roasting, cooling, destoners (optional), product pipeline transportation, packaging, X-ray quality testing equipment, etc. If nitrogen packaging is used, nitrogen generators or other nitrogen filling equipment should be equipped.

The performance, precision, and materials of production equipment shall comply with the relevant provisions of the "Food Production Licensing Review General Rules" regarding production equipment.

Article 10: The distance between the raw coffee bean feeding port and the ground should not be less than 45 centimeters, equipped with a dedicated cover. A protective device should be installed above the cooling tray for roasted coffee beans to prevent foreign objects from entering.

Article 11: A changing area should be set up at the entrance of the production area, equipped with changing and shoe changing (or shoe cover wearing) facilities or shoe and boot disinfection facilities. Work clothes should be stored separately from personal clothing and other items. Non-manual hand washing, drying, and disinfection facilities matching the number of production and processing personnel should be installed at the entrance of the production area.

Article 12: The production area should be equipped with primary and medium efficiency air purification system facilities and equipment, and automatically monitored.

Article 13: Video surveillance facilities and equipment capable of monitoring the entire production process should be installed in the production area.

Article 14: Facilities suitable for monitoring temperature and humidity and controlling room temperature and humidity should be equipped according to production needs.

Chapter IV Equipment Layout and Process Flow

Article 15: Comply with the relevant provisions of the "Food Production Licensing Review General Rules" regarding equipment layout and process flow.

Article 16: Production equipment should match the production process. If a production process different from those listed in Appendix 2 is used, production equipment suitable for the production process should be available.

Article 17: Identify key processes or points affecting product quality through hazard analysis methods, implement quality control, and establish electronic information recording systems for information formed by key processes or points, which can be set as baking, cooling, etc.

Chapter V Personnel Management

Article 18: Comply with the relevant provisions of the "Food Production Licensing Review General Rules" regarding personnel management.

Article 19: Food safety knowledge training should be conducted for employees before and during employment, and training records should be established. Food safety management personnel, key process operators, and other relevant employees should be assessed. Those who fail the assessment shall not be allowed to work.

Chapter VI Management System

Article 20: Comply with the relevant provisions of the "Food Production Licensing Review General Rules" regarding management systems.

Article 21: Refer to Appendix A of the "National Food Safety Standard General Hygienic Regulations for Food Production" (GB14881) to establish environmental and process microbial monitoring procedures appropriate for the product.

Article 22: Establish production area protection management and patrol recording systems, prohibiting non-food processing personnel from entering the production area. In special cases, entry should comply with the same hygiene requirements as food processing personnel.

Article 23: Establish raw material control systems, and raw coffee bean materials should be pre-cleaned.

Article 24: Establish pest control program management systems to prevent pest intrusion.

Article 25: Establish electronic information traceability systems to achieve information traceability from raw coffee beans to finished coffee batches.

Article 26: Establish production quality management systems appropriate for the food produced, regularly conduct self-inspections of their operation status, ensure effective operation, and form self-inspection reports.

Chapter VII Inspection

Article 27: According to the licensing category name of roasted coffee declared by the enterprise, provide qualified third-party inspection reports for trial-produced food. The inspection items should include the coffee bean inspection items specified in the "National Food Safety Standard Maximum Contaminant Levels in Food" (GB2762), "National Food Safety Standard Maximum Pesticide Residue Limits in Food" (GB2763), and all items specified in enterprise standards.

Article 28: Factory inspection and type inspection items shall comply with the relevant provisions of the "Roasted Coffee Production License Review Regulations".

Enterprises may use rapid detection methods and equipment for product inspection, but should ensure the accuracy of detection results. When using rapid detection methods and equipment for factory inspection, they should be regularly compared or verified with the inspection methods specified in national standards. If rapid detection results are unqualified, the inspection methods specified in national food safety standards should be used for confirmation.

Chapter VIII Supplementary Provisions

Article 29: Other requirements related to the open production process of roasted coffee not mentioned in these regulations should be implemented in accordance with the "Roasted Coffee Production Licensing Review Regulations".

Article 30: These regulations shall be interpreted by the Shanghai Food and Drug Administration.

Article 31: These regulations shall be implemented starting from October 25, 2017, and are valid for 5 years.

Appendices:

1. Food Category List for Open Production Licensing of Roasted Coffee

2. Basic Processes and Equipment for Open Production of Roasted Coffee

Personal Preliminary Interpretation:

After reviewing the above regulations, experienced industry professionals should already have a certain understanding of the scope.

Overall, the rules have been relaxed and will not constrain artisanal coffee roasteries like the QS factory requirements did in the past.

1. The open production in the regulations refers to not using separate rooms or walls for visual isolation, allowing consumers to view the roasting process.

However, isolation settings are required between the production area and non-production area. The minimum requirement is continuous transparent protective facilities not less than 1.05 meters high to prevent non-food processing personnel from entering the production area. (Therefore, open production does not mean consumers can freely enter the roasting area.)

2. Raw materials, auxiliary materials, finished products, and other materials should be stored in separate warehouses or areas according to their different properties.

Cleaning agents, disinfectants, pesticides, lubricants, fuels, and other materials should be placed in dedicated cabinets. (This basically eliminates the possibility of opening a small current roasting shop the size of a takeout window.)

3. A changing area should be set up at the entrance of the production area, equipped with changing and shoe changing (or shoe cover wearing) facilities or shoe and boot disinfection facilities. Work clothes should be stored separately from personal clothing and other items.

Non-manual hand washing, drying, and disinfection facilities matching the number of production and processing personnel should be installed at the entrance of the production area. (This requirement is similar to that of bakery shops, so there will be minimum requirements for the operating area of artisanal coffee roasteries.)

4. The production area should be equipped with primary and medium efficiency air purification system facilities and equipment, video surveillance facilities and equipment capable of monitoring the entire production process, and facilities suitable for monitoring temperature and humidity and controlling room temperature and humidity according to production needs. (Dust removal equipment companies have new business targets.)

5. The distance between the raw coffee bean feeding port and the ground should not be less than 45 centimeters, equipped with a dedicated cover. A protective device should be installed above the cooling tray for roasted coffee beans to prevent foreign objects from entering. (Now you can understand why the roasting machine at Shanghai Starbucks Reserve Roastery has a glass cover.)

6. Production equipment appropriate for the product varieties and quantities should be equipped, including magnetic screening, roasting, cooling, destoners (optional), product pipeline transportation, packaging, X-ray quality testing equipment, etc. (This depends on the scale of roasting. Some are sky-high equipment that general coffee shops will not use. Everyone can refer to the basic processes and equipment listed in the appendix. Raw beans need magnetic screening, but roasted beans don't need destoners, which puzzles me somewhat.)

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