Interpretation of the “Carry-over Principle” in GB 2760

What is the “Carry-over” Principle?

The term “carry-over” in the context of food regulation in China, can be understood as the presence of a food additive in a final product usually attributable to the usage of this food additive as a raw material during an upstream processing step. During both pre and post market product inspection and testing, Chinese authorities can flag additives unintentionally carried over into final products. Failure to provide adequate justification (i.e. evidence of acceptable carry-over) for the presence of this non-compliant food additive can result in consignments of imported foods being rejected by port authorities or products being banned, recalled or production halted during post market inspection by market regulators.

The “carry-over principle” was first put forward in GB 2760-2007. Interpretation and enforcement of this "carry-over principle" has been inconsistent and has led to numerous controversial cases in which Chinese port authorities (GACC) have deemed imported food to be non-compliant, or Chinese market regulators (SAMR) have deemed food circulating in the market as non-compliant and therefore illegal.

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Lennie Tao
ChemLinked Regulatory Analyst
Lennie Tao is a food regulatory affairs news editor working at ChemLinked. She graduated from Sichuan International Studies University with a master's degree. Lennie has a vast array of experience and is a regular attendee of China special food training programs and forums. Lennie has a broad range of experience in the food sector, and also has a great understanding of China infant formula regulatory requirements and China health food regulatory requirements.
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