Vision: a well-organized food regulatory system
China’s standardization work started early in 1962 and has undergone several phases of large-scale reform[2]. During the evolution of China’s food legislative and regulatory framework, China has released, developed, refined and reformed its national food safety and quality standards. Major milestone events like the implementation of the various iterations of China’s Food Safety Law drastically alter the lower level foundational principles underpinning China’s national food safety standards and necessitates development and implementation of new standards to replace outdated standards. However, generally speaking development of foundational legislation and regulation tends to precede subordinate national safety standards which are on a lower rung of China’s legal hierarchy and thus China’s national food standard framework is still a work in progress.
Problem 1: Some food quality standards contain food safety requirements;
Safety requirements usually refer to maximum limits of contaminants, microorganism, fungal toxins, pesticide residue, and so forth. Quality requirements usually refer to physiochemical properties and recommended nutrient concentration that are indicators of product quality. In food product standards published/revised in recent year’s e.g. GB 2716-2018 Standard for Plant Oil [3] within which there is no detailed safety requirement except for expressions like “refer to GB 2762[4] for maximum levels of contaminants”. This individual treatment and clear division of safety and quality standards is a goal of China’s government.
However, some standards released earlier, infant formula standard GB 10765-2010[5]for example, contain both quality requirements and safety requirements. GB 10765 is now under revision, one of the major changes in China’s new infant formula product standards is that safety requirements will be treated individually in corresponding hygiene standards.
Problem 2: Some food quality standards are mandatory.
According to Standardization Law[6] revised in 2017 and article 25 of Food Safety Law[7], China encourages manufacturers to comply with recommended standards, and only food safety standards are mandatory.
In 2017, China Standardization Administration abolished 396 mandatory GB standards and transformed 1077 mandatory GB standards to recommended GB/T standards[8], including product standards for white granulated sugar, rice, corn oil. The launching of this plan means product standards will no longer contain hygiene requirements and many mandatory standards will change to recommended standards (GB/T).
Work deployment: sorting out quality standards and safety standards
Applicable scope
The plan targets food national standards and legislative plans that are drafted by the Standardization Administration, including standards for food, food related products and edible agricultural products.
Work scheme
Based on an evaluation by authorities, standards will be given a result with the instruction: “abolish”, “revise”, “integrate”, “coordinate”, or “continue to be effective”. Evaluation will assess the following 5 criteria:
Contain safety requirements/indicators or not
The food safety requirements indicators are consistent with food safety standards or not
Necessity or rationality
Standard category
Integrality and coordination
For food quality national standards, the result and instruction will be: “terminate”, “integrate” or “continue to be implemented”.
Schedule
May | launch |
May ~June | review and clearance |
July | reexamination |
August | consultation period |
September | notification |