China Food Flavoring Regulation
Sep 12, 2019
Yilia Ye
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The regulatory scope of food flavorings in China refers to a group of substances that are added to food to impart, modify, or enhance the flavor of food. Food flavorings exclude substances which serve to impart sweet, sour or salty taste to foods, such as sugar, salt, vinegar, as well as food additives like sweetening agent. Based on source and manufacturing method, flavorings are classified into two categories, which are natural flavoring substance and synthetic flavoring substance.

Currently GB 2760, GB 30616, GB 29924 are the three most important Chinese national standards related to regulation of food flavoring. GB 2760 is the fundamental standard for all food additives, including food flavoring. It specifies the usage principle in Appendix B and includes a positive and negative list of foods in which flavoring can/cannot be used. GB 30616 is the national standard for food flavoring, involving technical requirements, labeling requirements, list of auxiliary materials etc. GB 29924 stipulates general rules for the labeling of food additives.

1. Dosage of food flavoring

Appendix B of GB 2760 stipulates that “Food flavoring should be used in moderation according to manufacturing demand”, meaning that there is no strict dosage limit for food flavorings. However, due to the inherent characteristics of flavoring agents and the impact on the sensory qualities of a food, food flavoring use is often self-limiting. On one hand, flavors often have a strong fragrance which can negatively impact sensory qualities; on the other hand, for manufacturers, excessive food flavoring use incurs increased costs.

GB 2760 also requires that “Food flavorings are not allowed to be added in foods listed in Table B.1 of GB 2760 as there is no necessity, unless otherwise stipulated by laws, regulations and national food safety standards.” The list includes vegetable and animal oil, fresh fruit and vegetables, eggs, water etc. Though infant formula is included as well, vanillin, ethyl vanillin and vanilla extract (extractive) could be used in older infant formula (stage 3) with maximum level of 5mg/100ml, 5mg/100ml.

2. Food flavoring substances with multiple regulated secondary functions

Some food flavorings may have multiple functions in food, like benzoic acid, guarana extract, etc. The use of this category of flavorings shall comply with relevant provisions of GB 2760. If use of this ingredient is specified as a food additive and processing aid, then it should conform to requirements of Appendix A and C in GB 2760. If it is not listed in the table of Appendix A and C but used as other food additives, then extra approval is required.

In addition, if other food additives are used as food flavoring, requirements of Appendix B in GB 2760 should be followed. For example, when benzoic acid is used as a food flavoring, it is not allowed to be added in excess with the goal of increasing its secondary function as a food preservative.

3. Auxiliary materials

Auxiliary materials are used during food flavoring production, storage, application, etc. Actually, solvent and other auxiliary materials are used in manufacture of the majority of food flavoring and GB 30616-2014 lists permitted auxiliary materials. Auxiliary material shall not carry over into finished products and they are not permitted to be used as a food additive.

4. Label

GB 29924-2013 stipulates that detailed names are not necessary when labeling flavoring substances and the use of the designation “flavoring substance” (in Chinese character) can be used on the label. However, food additives like sweetening agent, coloring agent added in food flavoring require detailed labeling according to requirements in GB 2760. In addition, GB30616-2014 stipulates that the label of food flavoring need to comply with requirements of GB 29924.

Example ingredient list: Figure 1


                                                              Figure 1

A name with fragrance type is also acceptable, such as “strawberry flavor”, “apple flavor”. For food flavoring containing ingredients from marine products, this information should be labeled on the package as well. The label of food flavoring should be correct and true.

5. Comparison to CODEX Flavoring Standards

The current food flavoring standards are CAC/GL 66-2008 Guidelines for the Use of Flavorings, CODEX STAN 107-1981 General Standard for the Labeling of Food Additives, CODEX STAN 192-1995 General Standard for Food Additives, CAC/MISC 6-2015 List of Codex Specifications for Food Additives. Similar to GB 2760, GSFA (CODEX STAN 192) is the fundamental standard which regulates the use of food additives. However, there’s no rule for using food flavorings. CODEX has set forth a series of rules for the use of food flavorings in CAC/GL 66. Food flavorings may consist of flavoring substances, natural flavoring complexes, thermal process flavorings or smoke flavorings and mixtures of them and may contain non-flavoring food ingredients. In China, there’s no concept of smoke flavoring. Food flavorings can be used provided manufacturers adhere to good manufacturing practice, which includes limiting the quantity used in food to the lowest level necessary to accomplish the desired flavoring effect. Specification and safety of food flavoring should be evaluated by JECFA. Food flavorings should comply with CAC/RCP 1-1969, CAC/GL 21-1997, CODEX STAN 107-1981 and CODEX STAN 1-1985

The labeling requirements of CODEX are quite similar to that of China, including the product name, ingredients, instructions on keeping and use, net contents, name and address, country of origin, lot identification.  Table 2 of CAC/MISC 6 has listed all of the approved food flavorings by CODEX. The specifications of food flavorings are available on