By Xiangwen He - 14 March 2016

The food safety incidents that have occurred in China in recent years have led to increasing international media scrutiny and have damaged the reputation of Chinese products, not only in domestic markets but also in foreign markets. The major causes for these incidents have been identified as being the results of the illegal use of food additives. In order to strictly regulate the use of food additives and food flavourings and re-build the confidence of consumers, China has now streamlined its food supervisory system. There are currently three main competent agencies responsible for supervision of additives: The National Health and Family Planning Committee of China (NHFPC), which takes responsibility for reviewing the safety of new food additives and formulating food safety standards for food additives; The China Food and Drug Administration (CFDA), which is responsible for the supervision of the production and circulation of food additives; and The General Administration of Quality Supervision, Inspection and Quarantine of China (AQSIQ), which takes charge of the inspection and quarantining of imported and exported food additives.

The NHFPC published the new National Standard for Uses of Food Additives (GB 2760-2014) along with 36 other national standards relating to food in December 2014. The new standard replaced GB 2760-2011 and came into force in May 2015. It specifies the principles for the application of food additives, the allowed food additive varieties, the scope of application, and the maximum level or residue levels. Compared to GB 2760-2011, the new standard makes major modifications including: the moving of nutritional enhancers and gum-based substances in chewing gum and their ingredients to separate standards; the modification of the “Carry-over” principle; the modification of the provisions for use of food additives; the removal of provisions of food additives that are not technically necessary in some food categories; the modification of the provisions for the use of flavouring substances in foods; the modification of the provisions for use of food processing aids; and the modification of the Food Category System.

All food additives used in China should comply with the basic principle that they are technically necessary and proven to be safe. New food additives are required to be registered with NHFPC before marketing and application in foods. Useful appendices in the new standard GB 2760-2015 are listed below:

Appendix A Provisions for the Use of Food Additives.

A.1 lists the permitted food additives in Chinese alphabetical order with the English name, Chinese Numbering System for Additives (CNS), the International Numbering System for Additives (INS/E number), the functions, and a table specifying the food classification number, food categories, maximum use level, and the maximum residue level. There are 22 additive functional varieties with over 2400 permitted food additives listed. Any additive not included in A.1 can not be used in food.

A.2 lists the additives permitted for use in any kinds of food in accordance with GMP.

A.1 and A.2 do not regulate Flavouring Substances or food additives used as food processing aids. Such information is found in separate appendices to this standard.

Appendix B Provisions for the Use of Food Flavouring Substances.

B.1 lists food categories that can not be added to food flavouring substances.

B.2 lists over 390 natural flavouring substances permitted in foods with Chinese codes and Flavor & Extract Manufacturers Association (FEMA) numbers.

B.3 lists over 1470 synthetic flavouring substances that are allowed to be used in foods with Chinese codes and FEMA numbers.

Appendix C Provisions for the Use of Food Processing Aids.

C.1 lists the processing aids that can be used in all kinds of food processing where the residue quantity needs no restriction, with the names of the processing aids in Chinese alphabetic order (excluding enzyme preparations).

C.2 lists the processing aids that need functions and usage scopes to be defined, with the names of the processing aids in Chinese alphabetic order (excluding enzyme preparations).

C.3 lists the enzymes that can be used in food processing with the names of the enzyme preparation in Chinese alphabetic order. The source and donor of the enzyme must comply with the provisions in the list.

Appendix D Additives functions.

Sets out the function categories for specific food additives, although it should be noted that it is not a comprehensive listing.

Appendix E Food category system.

Food classified in the food category system is only for specifying the use of food additives in this standard, and only applies in this standard. When an additive is specified for use in a general category, it is specified for use in all sub-categories, unless otherwise stated. There are sixteen food categories in total with different sub-categories.

Appendix F is an index for permitted food additives that are listed in Appendix A.

Understanding China's food laws can seem daunting to exporting businesses. The expanding Regulatory Affairs team at Campden BRI include native Chinese speakers on hand to help. Please contact them via sharon.he@campdenbri.co.uk or come and meet the team at stand F108 at Food and Drink Expo at the NEC, Birmingham on 18th-20th April 2016.

Xiangwen He, Food Law Advisor
+44(0)1737 824204
sharon.he@campdenbri.co.uk