China’s Food Additive National Food Safety Standard System

The 2009 version of China’s Food Safety Law introduced the concept of National Food Safety Standard (NFSS) for the first time, aiming at building a unified and comprehensive standard system to regulate foods in China. This type of standard is compulsory and implemented at the national level. The NFSS system covers various aspects related to food, including food products, food additives, contaminants in foods, food contact materials, pesticide residue, etc. Meanwhile, NFSS can be classified into product standard, specification standard, labeling standard, testing standard, etc. The easiest wat to differentiate between a NFSS from another compulsory or local/industry standard is that the name of every NFSS contains the term “National Food Safety Standard”, such as GB 2760-2014 National Food Safety Standard for Uses of Food Additives. China NHFPC is the major department responsible for managing, formulating and publishing NFSS.

This article will focus on food additive National Food Safety Standards in China and will provide a comparison of the food additive standard system in China and other countries/regions. Problems in the current system are also listed with potential solutions and likely avenues of future development also offered.

1.      Scope Food additive NFSS

Food additive NFSS include food additive use standards, food additive quality specification standards as well as food additive labeling standards.

1.1  Existing food additive use standards

In China, food additives refer to synthetic or natural substances added in food to improve the quality, color, taste and flavor of food as well as meet the needs of corrosion prevention, refreshment and processing technology. Food flavorings, chewing gum bases and processing aids are also considered as food additives.

There are three food additive use standards:

• GB 2760-2014 National Food Safety Standard - Standard for Uses of Food Additives

• GB 14880-2012 National Food Safety Standard - Standard for the Use of Nutritional Fortification Substances in Foods

• GB 29987-2014 National Food Safety Standard - Food Additive Gum Bases and Its Ingredients

Table 1: List of National Food Safety Standards for Use of Food Additives and Their Main Contents

1.2  existing food additive quality specification standards

The food additive quality specification standards are also called food additive product standards, which mainly stipulate quality and safety requirements for existing food additives.

They are divided into two types:

• standard for a specific food additive, such as GB 1886.62-2015 National Food Safety Standard - Standard for Food Additive Magnesium Silicate;

• general safety standard for multiple food additives, such as

• GB 26687-2011 National Food Safety Standard General Standard for Blended Food Additives

• GB 29938-2013 National Food Safety Standard General Rules for Flavorings

• GB 25594-2010 National Food Safety Standard Enzyme Preparations for Food Industry

• GB 29987-2014 National Food Safety Standard Food Additive Gum Base and its Ingredients

• GB 30616-2014 National Food Safety Standard Food Essences

Table 2: Status and Main Contents of Food Additive Quality Specification Standards

1.3  Food additive labeling standard

The food additive labeling standard is GB 29924-2013 National Food Safety Standard General Standard for the Labeling of Food Additives. It mainly specifies requirements for labeling food additives used by food manufacturers, operators and consumers including the names, ingredient list, application scope, dosage and use methods, date, storage conditions, net content and specification, name and address of manufacturer or distributors, product standard code, series number of production license, warnings, etc.

2.      Characteristics of food additive NFSS system

China’s food additive NFSS system is now completed but has not been comprehensively optimized. The current framework has taken years of concerted effort by the NHFPC in collaboration with CFDA, involving the systematic reform of hundreds of food additive standards, the overhaul of the food additive NFSS system and redevelopment of use standards, quality specification standards and labeling standard. The majority of food additives in use now have corresponding product standards. In the previous system many standards were extremely outdated and were unable to meet the requirements of food safety supervision and management. The current updated system is more comprehensive, up-to-date and better designed to meet the requirements and advancements in the food additive industry. Below is a comparison with the frameworks of other important regions:

Table 3. Comparison of food additive standard system of China with CAC, EU, Japan, USA and Australia

3.      Problems with China’s food additive NFSS system and future avenues of development

3.1  GB 2760-2014 needs further improvements regarding the use of food flavorings and essences. Normally food flavorings will be added to food after being made into essences but part of flavorings can also be added into foods directly. However, GB 2760-2014 doesn’t further specify which flavorings can be added into foods directly, which is very confusing for food additive manufacturers. Regarding the use of processing aids, for those that are applied according to the stipulated functions and application scopes, GB 2760-2014 doesn’t further stipulate their residue limits. Only one vague requirement is introduced which mandates that “processing aid should be removed in the final product; if it cannot be removed completely, the residue level should be reduced to the minimum, which should not do harm to human health and should not function in the final product”.

3.2  According to the Table 2, a certain number of food additives don’t have defined quality specification standards yet. Therefore additional standards should be formulated to meet the regulatory gap. For example, GB 2760-2014 contains 1870 food flavorings in total but only 12.8% have separate product standards. Most of them have to follow one general standard GB 29938-2013 National Food Safety Standard General Rules for Flavorings, which cannot compare with separate standard with more detailed requirements.

3.3  For use and storage of food additives, secondary food additives may be added but currently there is not any regulation available to control the safe use of secondary food additives.

3.4 The results of risk assessment of food additives is the scientific basis underpinning the formulation of NFSS but the ability to carry out risk assessment is underdeveloped. China doesn’t formulate guidance on how to carry out risk assessment of food additives by referring to international practice. For most cases, the government often carries out the evaluation of acceptable daily intake of food additive by referring to existing international safety evaluation results, such as ADI set by JECFA and residents consumption data, rather than assessing in a systematic and comprehensive way according to procedures and methods of RA. There is also no publically available processed food consumption database and usage status database of food additives in foods. In addition, the number of institutions and experts capable of conducting full RA of food additives cannot meet the actual need.

3.4  In addition to assessing new food additives, existing additives with a long history of use which are subsequently applied in a different usage situation should be reassessed according to the new use. However, China has no plan to initiate such a reevaluation system.

3.5 China’s current system of assessing the compliance of food additives against national standards is overly reliant on testing results and necessitates a refinement in approach to encompass assessment of manufacturing and production conditions and reinforce the supervision on food production process.