Flavor & Fragrance Regulation in China

The 6th China International Flavor and Fragrance Summit 2018 concluded on May 18th of this year. During the two-day conference, Wang Huali, senior employee from CFSA National Food Safety Standard Review Board gave a speech titled “Current Situation and Progress in the Management of Food Flavors and Fragrances in China” in which she overviewed recent progress and outlined current and future regulation of flavor and fragrances in China.

In this article, flavoring essence refers to a mixture of fragrant ingredients and accessory materials. It is used for food processing and not direct consumption. Fragrant ingredient refers to the main component of flavoring essence, and its function is to promote food flavor/aroma indirectly.

Flavor & Fragrance Regulatory System in China

GB 2760-2014 is the general standard for all food additives, stipulating the usage principle of food additives in China as well as permitted varieties. As a kind of food additives, flavor and fragrances are also subject to the requirements in GB 2760. Additionally, appendix B of GB 2760 specifies:

• B.1 Prohibited flavoring essences and fragrant ingredients in food;

• B.2 Approved food natural fragrant ingredients (402 items);

• B.3 Approved food composite fragrant ingredients (1477 items).

Among various product standards, there are general rules/standard and more than 400 standards for individual products. GB 29938-2013 articulates terms, definitions, requirements for natural/composite/compound flavor and fragrance. GB 30616 lists permitted auxiliaries in food flavoring essence along with other requirements.

Latest Movements in Flavor & Fragrance Regulation

GB 2760-2014, GB 29938-2013 and GB 30616-2014 are currently in force, but they are now being revised as was proposed in 2016. The new drafts of GB 30616-2014 and GB29938 are likely to be open to pubic feedback in June or July. In addition mandatory GMP requirements are also likely to be implemented.

Amendments to flavor ingredient requirements in GB 2760

A negative list for food flavoring essence/ingredients will be compiled.

In appendix B.1, the term “relevant standard(s)” will be replaced by exact and accurate terms like “GB 30616” or “GB 29924”.

Currently appendix B does not make it clear that all infant supplementary food except for cereal ones shall not contain flavor and fragrance. The revised version will clearly stipulate “B.1 Prohibited flavoring essences and fragrant ingredients in food”.

In appendix B.2 and B.3, 8 items are removed from the list as 5 of them will be viewed as ordinary food and the other 3 have been phased out by industry. 2 former natural fragrant ingredients will be classified as composite ones. Some English names and FEMA codes are changed. New fragrance ingredients are numbered.

Amendments to GB 29938

Items that have their own single product standards will be removed from general standard. Some general methods will be added and descriptions will be adjusted according to revised GB 2760.

Basic Overview of Legal Hierarchy

Fragrant ingredients shall be listed in GB 2760, or

• New ingredients shall apply for approval.

Major regulations on application of new ingredients

Application procedure

Key Requirements for Using Flavor and Fragrance: Safety and Necessity

Safety: shall not damage consumers’ health

Necessity: shall achieve expected function in food

Tips

Single product standards have a clearly defined parameters stipulating permitted materials and processing techniques. When requirements change or a product is modified, relevant stakeholders will need to apply for new product approval Manufacturer/enterprise/individual can submit application materials at any time (no fixed time).