China Consults on National Standards for Pasteurized Milk, High Temperature Pasteurized Milk and Sterilized Milk

As revealed by the official notice issued on December 11, 2023, China’s National Health Commission is soliciting public feedback on 21 national food safety standards, involving food contact materials (FCM), dairy products, Good Manufacturing Practice (GMP) for health food, food additives, etc. Feedback can be submitted in the online system prior to February 10, 2024. A whole list of the 21 national food safety standards can be read at: China Consults on 21 GB Food Standards, Involving FCM, Dairy Products and Food Additives.

Among the 21 national standards, there are 3 product standards for dairy products. Analysis to the three standards is as below.

1. GB 19645-XXXX National Food Safety Standard Pasteurized Milk

Scope of raw materials

Compared to the current effective version GB 19645-2010, the scope of raw materials is expanded from raw cow and goat milk to cover the milk from other species, following the definition revision of raw milk in GB 19301 Raw Milk. Milk from other species include buffalo milk, yak milk, camel milk, donkey milk, and horse milk.

Requirements for processing technique

For the first time, the standard clarifies the requirements for processing techniques, i.e., pasteurization and other equivalent thermal processing methods, that are used in the production of pasteurized milk. Details can be found in Annex A.

Test method for sensory inspection

In the current effective version, samples are required to be placed in a 50ml glass for evaluating the product's color, odor, taste, and texture. Considering the actual practice, the draft amends the requirement of the container to be "a glass not less than 50ml."

Physicochemical requirements and microbial limit

In line with the expanded scope of raw materials, the draft adds the physicochemical indicator and microbial limit for milk from species other than cow and goat. At the same time, some technical indicators (amended as below) and test methods for pasteurized cow milk and goat/sheep milk are revised. In addition, the draft newly clarifies that pathogen limits shall follow GB 29921 National Food Safety Standard Pathogen Limit in Prepackaged Foods.

Products	Revisions
Pasteurized cow milk	Fat content: ≥ 3.1 g/100g → 3.2 g/100g
	Acidity requirement: 12-18 ºΤ → 10-18 ºΤ
	Total bacterial count: m=50000 CFU/mL, M=100000 CFU/mL → m=5.0x10³ CFU/mL, M=2.5x10⁴ CFU/mL
Pasteurized goat/sheep milk	Acidity requirement: 6-13 ºΤ → 6-14 ºΤ

Labeling

In addition to the labeling of “Fresh X Dairy (Milk)”^*, this draft newly requires products to be labeled with “Pasteurized X Dairy (Milk)”.

*Notes: X refers to certain species.

2. GB 25190-XXXX National Food Safety Standard Sterilized Milk

Terminology and definition

Compared to the current effective version GB 25190-2010, the scope of raw materials is expanded from raw cow and goat milk to cover the milk from other species. The requirement “added or not added with reconstituted milk” is deleted from the definition of “ultra high temperature milk” and “retort sterilized milk” in this draft.

Moreover, the draft newly explains the processing method "ultra high temperature sterilization" and "retort sterilization".

Test method for sensory inspection

Physicochemical requirements

In line with the expanded scope of raw materials, the draft adds the physicochemical indicator for milk from species other than cow and goat. At the same time, some physicochemical indicators (amended as below) and test methods for pasteurized cow milk and goat/sheep milk are revised.

Products	Revisions
Sterilized cow milk	Fat content: ≥ 3.1 g/100g → ≥ 3.2 g/100g
Sterilized cow milk	Acidity requirement: 12-18 ºΤ → 10-18 ºΤ
Sterilized goat/sheep milk	Acidity requirement: 6-13 ºΤ → 6-14 ºΤ

Labeling

In addition to the labeling of “Pure X Dairy (Milk)”, this draft newly requires products to be labeled with the description “Sterilized X Dairy (Milk)”. The labeling requirements related to reconstituted milk are deleted.

3. GB XXXX-XXXX National Food Safety Standard High Temperature Pasteurized Milk

Along with the fast development of China’s low temperature milk market, many dairy enterprises have launched “high temperature pasteurized milk” to gain market share in the past years. Compared to pasteurized milk, such products shall also be kept under refrigeration but with a longer expiration date. The concept is similar to what is called Extended Shelf Life (ESL) milk in other countries. As disclosed in the draft, such products shall be treated at one of the following temperatures or above for a minimum of required duration: 115℃ for 20 seconds; or 120℃ for 15 seconds; or 130℃ for 2 seconds; or other equivalent thermal processing methods.

Due to the absence of corresponding national product standard for high temperature pasteurized milk, currently, market players produce such products mainly by following enterprise’s own standard filed with the authority. As a result, the requirements vary. Moreover, most consumers are not familiar with this field and hard to tell the difference between pasteurized milk and high temperature pasteurized milk. Once this draft is approved, it will help differ the two products and better support the industry development.

Just like the national product standard for other dairy products, this draft stipulates the following requirements for high temperature pasteurized milk: application scope, product definition, requirement for the processing technique, technical requirements, and labeling requirements. In terms of labeling, products of this kind can only be labeled as "High Temperature Pasteurized X Dairy (Milk)", whereas pasteurized milk can be labeled with the description "Fresh X Dairy (Milk)". This labeling distinction can help consumers differentiate between the two products.

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