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Carcinogens in Muji Biscuits Provoke Public Debate in China

Carcinogens like acrylamide and 3-MCPD were detected in 51 food samples tested by Hong Kong’s Consumer Council during a routine inspection. Currently, no country or organization limits acrylamide levels in food. Food enterprise in China shall meet the inspection demands prescribed in Rules for the Sample Inspection of National Food Safety (Edition 2018).

On Jan. 15, 2019, Hong Kong Consumer Council detected carcinogens [1] like acrylamide and 3-MCPD in 51 of 58 food tested samples of biscuits and cookies, including the popular brand in China, MUJI. The Council also found traces of glycidol in 40 samples, acrylamide in 42 samples and 3-MCPD in 35 samples.

The day after the discovery, the topic “MUJI’s Biscuits Pose Cancer Risk” became one of trending topics online in China. The story is similar to what happened to Starbucks coffee [2] last year, let's take a closer look. 

What are these substances?

These substances are not additives but are substances produced naturally during the processing of food. The table below offers an overview of the basic characteristics of these foods, Source from Chemicals in food 2016, Overview of selected data collection, EFSA [3].

SubstanceFormationMainly found inHarm
AcrylamideA chemical compound that typically forms in starchy foods when they are baked, fried or roasted at high-temperatures (120-150℃)potato crisps, French fries, bread, biscuits and coffee, etc.It potentially increases the risk of developing cancer for consumers in all age groups, especially children.
GlycidolThe parent compound of GE; formed when vegetable oils are heated to temperatures in excess of 200℃Palm oil, other vegetable oils, margarines and processed foods, particularly pastries and cakes, infant formula products, etc.Both genotoxic and carcinogenic; it can damage DNA and may cause cancer.
3-MCPDEsters of 3-MCPD can form in vegetable oils during refining, but normal 3-MCPD may also form in baked goods, fish during smoking, barley during roasting and in hydrolyzed vegetable proteins and soy sauce.It has caused kidney and male reproductive organ damage in animal tests.
  • Average levels of acrylamide in selected products in μg/kg

  • Average/high levels of GE and 3-MCPD in selected products in μg/kg (collected 2012-2015)

Related Standards and Research

To limit the concentration of these substances, EU has prescribed the maximum level of 3-MCPD and glycidol but only in selected food products, according to the Commission Regulation (EU) 2018/290 of 26 February 2018 [4].
file:///var/folders/ll/xj745_m12gn3k6q47szbvzb40000gn/T/com.microsoft.Word/screenshot.pngHow about other food categories? We may take a look at the following data as a reference. According to research data from Food and Chemical Toxicology, 2010 [5], in regards to neurotoxic effects, the tolerable daily intake (TDI) for ACR was estimated to be 40 μg/kg-day. In regards to its carcinogenic properties the TDI was estimated to be 2.6 and 16 μg/kg/day for ACR and GLY levels, respectively.

Let’s estimate the risks posed by the acrylamide concentration in the samples detected by Hong Kong Consumer Council. One sample was found to contain 340 ug/kg acrylamide, meaning adults should limit their consumption of these cookies to 2 packages per day. If consumers are also eating other fried food, their exposure level will surpass the TDI and confer a clinically relevant risk for both neurotoxic and carcinogenic effects. 
The estimated form of the acrylamide hazard in some products

Value of acrylamide contentInvolved itemsChipsCookies
Cancer risk value2.6~16ug/kg.Bw/dDetected content240-280 ug/kg340 ug/kg
Source: CFDASource: HK Consumer Council
Product weight100g for a middle-sized package200 g
Content in per product24-28 ug68 ug
TDI for adults
(calculated as 60 kg)
About 156 ug/dRisk daily intakeAbout 5 packagesAbout 2 packages

China’s Stance on Toxic Byproducts in Foods

Keeping pace with the latest research, the former CFDA (now SAMR) also published the lists of carcinogenic substances [6] released by the International Agency for Research on Cancer in 2017. In the form, acrylamide, glycidol and 3-MCPD are regarded as group 2A carcinogens, group 2A carcinogens and group 2B carcinogens respectively. 
file:///var/folders/ll/xj745_m12gn3k6q47szbvzb40000gn/T/com.microsoft.Word/screenshot.png*Group 2A: "Probably carcinogenic to humans"; There is strong evidence that it can cause cancer in humans, but at present, it is not conclusive.
*Group 2B: "Possibly carcinogenic to humans"; There is some evidence that it can cause cancer in humans but at present, it is far from conclusive. (Definition from IARC)


Although China also considers these substances to be potentially carcinogenic in certain exposure scenarios, no related standards have been developed in Mainland China and Hong Kong. Why? Simple financial feasibility and cost/benefit concerns. Developing and implementing a new standard is expensive for the government in terms of increased supervision and testing requirements, and for the industry, in terms of their increased product compliance demands. The government needs to consider the risks posed by these substances, the content of it in food and people’s intake (i.e. exposure scenario). If the content of the substance is low in food or people don’t eat it frequently, then it is not necessary to set up a standard.

In 2018, the former CFDA (now SAMR) offered its opinion on the issue by releasing an article [7] quelling public concerns about the content of these substances in Starbucks coffee. 

Zhong Kai, vice director of CFIC stated, “Lots of food produce acrylamide at the temperature over 120℃. A cup of coffee only contains a tiny amount of acrylamide which does little harm to people. To Chinese people, fried dishes are the main source of acrylamide rather than coffees”.

How to avoid or lessen the intake of acrylamide? Here's his advice.

  • Try to boil, steam or stew food instead of baking, frying or roasting them. High cooking temperatures should be avoided.

  • Lessen the intake of fried food and high-fat food. Take more vegetables and fruits.

What Should Enterprises Do?

The government and enterprises should leverage the power of social media to give consumers an overall and scientific understanding of these substances. 

Although there are no relevant regulations, food enterprise can still try to reduce the acrylamide content of their food by improving production techniques. Indeed given the increased public awareness of this issue in China, pursuing a meaningful reduction could lend itself to a powerful marketing strategy.  

As a final parting tip, I’d like to remind food business in China, in order to build a positive reputation, they shall meet the inspection demands in Rules for the Sample Inspection of National Food Safety (Edition 2018) [8].

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