The letter, sent to China’s International Inspection and Quarantine Standards and Technical Regulations Research Center, indicated the U.S. groups’ concern that the testing procedures are a thinly disguised attempt to limit the amount of foreign-grown cotton entering the People’s Republic of China.

Last month, the Chinese government notified the World Trade Organization that it intended to include testing for short fiber content (SFC) and nep count in its national standard for imported cotton.

Chinese officials said the test for short fiber content would be conducted according to its GB/T6098.1-1985 Test Method of Cotton fiber Length using Roller Analyzer. Test of neps, they said, would be conducted according to GB/T6103-1985 Test Method for Raw Cotton Trash.

“The national standard for cotton is revised in order to improve the quality of cotton, to satisfy the needs of textile enterprises for high quality cotton, to prevent fake and bad quality cotton from flowing into the market and to fight deceptive practices in trade,” Chinese officials said.

In their letter, National Cotton Council and affiliated group leaders said the tests listed by the Chinese government have not demonstrated the necessary levels of accuracy or repeatability.

“The undersigned organizations have serious concerns that mandatory application of the proposed standard 1) will fail to address China’s concerns for improvement in the quality of cotton; 2) relies on measurements that have not been demonstrated to be accurate; 3) has not been adequately discussed in appropriate international forums; and 4) would arbitrarily and unjustly limit imports of cotton into the China market,” the letter said.

It said the NCC and other organizations have a long history of efforts to develop accurate and reliable measurements for short fiber content and neps under an appropriate standardizing body such as the International Textile Manufacturing Federation (ITMF) Committee on Cotton Test Methods.

“We will be happy to work with China, through the ITMF and directly, to address concerns about SFC and neps,” the letter said. “However, the sampling methods indicated in the draft “Cotton-Upland Cotton” revision no. 1 modification to GB-1103-1999 and the testing methods contained in these notices will not provide Chinese mills with accurate results.

“Further, it is unclear from all the documents thus far examined by the National Cotton Council whether these standards will be mandatory or voluntary and whether they will be applied equally to domestic and imported cotton fiber.”

Because these proposed standards cannot be reasonably interpreted as effectively addressing China’s stated concerns, the letter said, the U.S. cotton industry is concerned they will function as a barrier to trade, instead of a meaningful way to improve cotton quality in China.

“The WTO Agreement on Technical Barriers to Trade points out that standards should not create unnecessary obstacles to international trade,” it said. “Merchants will be reluctant to offer cotton for sale and buyers will also be hesitant in planning their purchases with such impracticable standards in effect.”

Equally important, NCC leaders said, “were China to invoke such standards, its own exports of raw cotton would most certainly be subject to its arbitrary and unreliable proposed standards by other importing countries thereby rendering them unmarketable in world trade.”

The NCC letter said that fiber quality experts in the United States have reviewed the proposed standards and have concluded that the methods are not suitably accurate or reliable.

“Given the inadequate evidence of accuracy of the tests and uncertainty of test repeatability the proposed standards will provide no practical data to textile processors,” it noted.” “The addition of these standards are likely to create uncertainty in world markets and will have a negative impact on China’s access to cotton from other origins as well as its internal efficient marketing of cotton.”

For the past five years, USDA, through the efforts of the Agricultural Research Service (ARS) laboratories in New Orleans, La., and Clemson, S. C. and the Agricultural Marketing Service, has been involved in research efforts to develop accurate and reliable methods for the measurement of short fiber content and neps.

“As a result of these efforts it has been determined that the Roller Length Analyzer could not be used to accurately test for fiber length,” the letter said.

It said researchers from the USDA, ARS laboratories in New Orleans studied variability within and among laboratories measuring short fiber content. In this study, four laboratories participated in evaluating short fiber content using various methods including the Suter-Webb Array method (ASTM Test Method 1440).

Results showed that the variation of short fiber content was very high, as were level differences (average value) among Suter-Webb test results from different laboratories. Researchers demonstrated that while the Suter-Webb method may be a suitable reference method for length measures, its accuracy and precision is not suitable for determining short fiber content.

“As part of this research project, ARS obtained the Roller Length Analyzer (the same device in the proposed China National Standard BG/T6098.1-1985) to determine if this device and method could accurately and precisely measure cotton short fiber content,” the letter said. “It concluded that the Roller Length Analyzer could not accurately and precisely measure cotton short fiber content and was less accurate than the Suter-Webb Array Method.”

The NCC also questioned the sampling procedures listed in the new Chinese standard.

Any new standard should not be implemented without consultations with other countries, the letter said.

“More than 20 years ago, the international textile manufacturers, as represented by the ITMF headquartered in Zurich, Switzerland, instituted the International Committee on Cotton Test Methods,” the letter said. “Its purpose is to evaluate cotton test methods, to stimulate developments in cotton testing technologies and their application, and to develop reference methods suitable for cotton production, trade and processing.

“A development for reliable measurements for short fiber and neps is a high priority of the ITMF committee. Among other issues, the committee biennially reviews developments in measurements of short fiber content and neps.”

The letter said it does not appear that China’s proposed standards for short fiber content or neps have ever been submitted or evaluated by the ITMF.

“It is our understanding that the standard GB1103-1999 is currently a voluntary standard in respect to imports and exports of cotton to and from China,” the letter said. “We note, however, an official from the State Fiber Inspection Center has been quoted in the press as stating that China ‘will ask foreign cotton suppliers to submit certificates attesting the cotton cargoes have passed the two tests before being unloaded at the Chinese ports.’” If the status of the standard GB1103-1999 were to be modified, from voluntary to mandatory with respect to imports of cotton into China, the proposed testing standards would prove to arbitrarily and unjustifiably restrict cotton imports into China, according to the letter.

“Further, under its WTO obligations China must give notification if it is making standard GB1103-1999 mandatory, provide information on implementation requirements and seek comment on these regulations through the WTO,” the letter said.

Signing the letter were the following:

National Cotton Council, American Cotton Producers, American Cotton Shippers Association, Atlantic Cotton Association, Southern Cotton Association, Texas Cotton Association, Western Cotton Shippers Association, American Cotton Exporters Association, World Cotton Exporters Association, National Cotton Ginners Association,

StaplCotn Cooperative Association, Southern Rolling Plains Cotton Growers Association, Delta Council, Cotton and Grain Producers of the Lower Rio Grande Valley, Southern Cotton Growers, Inc., Virginia Cotton Growers Association, Cotton Growers Cooperative, New Mexico Pecos Valley Farmers Association, Alabama Farmers Federation, South Texas Cotton and Grain Association,

Georgia Cotton Commission, Louisiana Cotton Producers Association, Louisiana Independent Cotton Warehouse Association, Agricultural Council of Arkansas, California Cotton Growers Association, California Cotton Ginners Association North Carolina Cotton Producers Association, Plains Cotton Growers, Inc.,

Arizona Cotton Growers Association, Supima Association of America, Southwestern Irrigated Cotton Growers Association, Rolling Plains Cotton Growers, Inc., Southern Cotton Ginners Association, Southeastern Cotton Ginners Association, Inc. California Cotton Ginners Association, Calcot, Ltd., Arizona Cotton Ginners Association, Arkansas-Missouri Cotton Ginners Association, El Paso Valley Cotton Association, Mississippi Cotton Ginners Association, Oklahoma Cotton Growers Association, Tennessee Cotton Ginners Association, Virginia Farm Bureau, AMCOT, Cotton Warehouse Association of America, Plains Cotton Cooperative Association, Cotton Growers Warehouse Association.

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