Opinion solicitation:
Letter from the Ministry of Health on soliciting opinions on the "Standards for the Use of Food Additives" and the "Draft for Soliciting Opinions" (Supervision Letter from the Health Office {2013} 203)
1、 Basic information on standard drafting (including brief drafting process, main drafting units, drafters, etc.)
The National Food Safety Standard for the Use of Food Additives (GB2760-2011) was established in the 2011 national food safety standard preparation and revision project plan (the second batch), led by the National Food Safety Risk Assessment Center (hereinafter referred to as the Assessment Center), China Foods Limited Industry Association, China Bakery Sugar Products Industry Association, the National Grain Administration Standards and Quality Center, China Foods Limited Food Additives and Ingredients Association The China Dairy Industry Association and the China Beverage Industry Association participated in and jointly undertook the revision work.
In 2012, the Evaluation Center established a revision working group, which discussed the principles and tasks of this revision work. During the revision process, it carefully analyzed and referred to the usage regulations of international and other international food additives, organized a review of the actual use of food additives in China, the necessity of using food additives in each type of food, and the rationality of the food classification system A nationwide survey was conducted on the query methods for the use standards of food additives, and a food safety risk assessment was conducted using the food intake data obtained from the nutrition survey of Chinese residents and the actual use data of food additives in China. During this period, the working group organized more than 10 standard revision meetings, completing the management scope of food additives, the principles of use of food additives, and the usage regulations for some food additives in Appendix A
Revise the content of Appendix D and some food classification systems.
Main drafters: Wang Zhutian, Zhang Jianbo, Wang Huali, Zhang Jiyue, Luo Pengjie, Ding Shaohui, Li Yunan, Yue Zengjun, Xue Yi, Li Yue, Zhang Jiukui, Zhao Yanping, Kang Yongpu, Yang Yonglan, Xie Huamin, Zhu Zhiguang, etc.
2、 Important content and main modifications of the standard
（1） Revision of GB2760 Provisions on the Use of Nutritional Fortifiers
The Ministry of Health has released the Standard for the Use of Food Nutrition Fortifiers (GB14880-2012), and the provisions on nutrition fortifiers in the standard are deleted in this revision of GB2760.
（2） Revision status of the introduced principles
Regarding the revision of the principle of inclusion in GB2760, the main reference is made to Article 4.2 of CODEX GENERAL STANDARDS FOR FOOD ADDITIVES CODEX STAN 192-1995, which stipulates that if a food raw material or ingredient is specifically used for the production of a certain food, it can be used or added with food additives in accordance with the provisions of the food produced in this standard, This includes provisions that cannot exceed the maximum usage limit applicable to the food (An Additive May Be Used In Or Added To A Raw Material Or Other Ingredient If The Raw Material Or Ingredient Is Used Exclusively In The Preparation Of A Food That Is In Conformity With The Provisions Of This Standard, Including That Any Maximum Level Applying To The Food Is Not Exceeded), as well as EU and ANZ regulations on the principle of inclusion, Based on the current situation of China's food industry, the principle of introducing food additives has been revised.
After multiple discussions, it is recommended to add the following content under the principle content introduced in section 3.4 of the main body of GB2760 standard: 3.4.2 When a certain food ingredient is used as a raw material for a specific end product, additives approved for the above specific end product are allowed to be added to these food ingredients, and the content of the additive in the end product should meet the requirements of this standard. The label of the specific food ingredient should clearly indicate its use in the production of the aforementioned specific food.
（3） Regarding the revision of Appendix A
3.1 Revision of Aluminum Containing Food Additives in GB2760
In June 2011, at the 74th meeting of JECFA, the provisional weekly tolerable intake (PTWI) of aluminum was revised to 2mg per kilogram of body weight per week, and the previously implemented PTWI of 1mg per kilogram of body weight per week was revoked. In 2011, the evaluation center conducted a risk assessment of aluminum in food based on the latest evaluation results from JECFA. The assessment results showed that the average dietary aluminum intake of the entire population in China was lower than the PTWI proposed by JECFA (2 Mg/kg body weight/week); However, the dietary aluminum intake of both the low age group and the high food consumption group has exceeded that of PTWI. Flour and flour products are the main sources of dietary aluminum in China. It is worth noting that residents in the northern region, due to their high consumption of pasta, 60% of residents consume more aluminum than PTWI. In contrast, China's dietary aluminum intake is higher than that of other countries. It shows that China needs to take measures to reduce the dietary aluminum intake of its residents, in order to reduce the health risks that excessive aluminum intake may bring.
According to the risk assessment results of aluminum containing food additives in Chinese food, on April 1, 2012, the Ministry of Health publicly solicited opinions from the society on the 13 types of aluminum containing food additives in the "National Food Safety Standard for the Use of Food Additives" (GB2760-2011) (Health Office Supervision Letter [2012] No. 293) and incorporated the revision of the above regulations on the use of aluminum containing food additives into the GB2760-2011 standard revision work undertaken by the evaluation center. Based on the risk assessment results of aluminum containing food additives in Chinese food, the evaluation center conducted a systematic analysis of the solicitation of opinions on 13 types of aluminum containing food additives, and organized relevant industry associations to conduct research on the actual use of aluminum containing food additives. Referring to the use of aluminum containing food additives internationally, the revision of the regulations on the use of 13 types of aluminum containing food additives was completed. The research results suggest revising the regulations for the use of 9 aluminum containing food additives and revoking the regulations for the use of 3 aluminum containing food additives. The specific situation is as follows:
1. Revision of regulations on the use of Potassium alum and Ammonium alum
(1) Revision of regulations on the use of Potassium alum and Ammonium alum in wheat flour and its products
The results of the Exposure assessment on aluminum diet of Chinese residents in 2011 showed that flour, Mantou and deep-fried dough sticks had the highest aluminum content and the highest contribution rate to aluminum exposure. Combined with the international regulations on the use of aluminum containing food additives and the results of the Ministry of Health's consultation on aluminum containing food additives, The revision working group suggested that the wheat flour and its products in the scope of use of Potassium alum and Ammonium alum, two aluminum containing food additives in GB2760-2011, should be revised to fermented flour products, fried flour products, batters (such as the batter used for fish and poultry), coated flour, and fried flour. The above revision suggestions will be solicited by the revision working group in the food industry. After investigation, China Foods Limited Industry Association reported that the above two food additives are not needed in the industrial production of Mantou and other fermented flour products, but yeast, fermentation powder, compound Leavening agent and other additives are used instead of the above two additives. Therefore, after further discussion, the Working Group proposed to delete the provisions on the use of Potassium alum and Ammonium alum as Leavening agent in fermented flour products.
Therefore, in this revision, it is suggested to change the use scope of Potassium alum and Ammonium alum 06.03 wheat flour and its products to 06.03.02.05 fried flour products and 06.03.02.04 batter (such as batter for fish and poultry), wrapping powder and frying powder, with the use amount and residue unchanged.
(2) Revision of regulations on the use of Potassium alum and Ammonium alum in aquatic products
On April 1, 2012, during the public consultation process of the Ministry of Health, some units reported that two aluminum containing food additives, Potassium alum and Ammonium alum, were mainly used for jellyfish in aquatic products, and suggested revising the calculation method of their residues. Based on the solicitation of opinions, the revision working group suggests modifying 09.0 aquatic products and their products to 09.03.02 pickled aquatic products (only for jellyfish), and further studying the residual amount of aluminum in jellyfish products and its calculation method. The revision working group entrusted Zhejiang Province and Guangdong Fisheries Circulation and Processing Association to study the action mechanism of Potassium alum and Ammonium alum in the normal production process of jellyfish, the background content of aluminum in jellyfish, the amount and calculation method of Potassium alum and Ammonium alum, the aluminum content in the final product, and the necessity of the process. After research by two associations, a revised proposal was proposed regarding the use of aluminum containing additives in jellyfish: the residual aluminum in jellyfish is 1000mg/Kg (calculated by Al and wet weight). The above suggestions have been evaluated by the National Food Safety Risk Assessment Center and it is believed that if the aluminum residue standard for jellyfish is increased to 1000mg/Kg, it will pose a higher health risk to the population who frequently consume jellyfish in China. Considering the protection of people who frequently consume jellyfish, it is recommended to maintain the standard for aluminum residue in jellyfish. According to the evaluation results, the revision working group suggested that the scope of use of Potassium alum and Ammonium alum 09.0 "aquatic products and their products" should be revised to 09.03.02 "salted aquatic products (only jellyfish), with a residual amount of 100mg/Kg (dry samples, calculated in Al).
2. Revision of regulations on the use of synthetic colorant aluminum lake
Aluminum oxide is used as the carrier of synthetic colorants in aluminum lakes, but aluminum content in aluminum lakes is very low, which has a low contribution rate to the intake of aluminum in the diet. By controlling the use of colorants, the intake of aluminum can be effectively controlled. Therefore, referring to international standards and the actual use of international synthetic colorants, the revised working group recommends maintaining the regulations for the use of synthetic colorants in aluminum lakes, There are no separate regulations for the use of aluminum in aluminum lakes.
(1) Revoke the regulations on the use of 12 aluminum containing food additives in puffed food
The risk assessment results of dietary aluminum exposure for Chinese residents show that children aged 7-14 consume relatively high amounts of aluminum through puffed foods, and as they age, their aluminum intake tends to increase. puffed foods are one of the main sources of aluminum intake for this group of people. In order to protect the health of children, the revision working group recommends the revocation of all regulations on the use of aluminum containing food additives (including synthetic colorants aluminum lake) in puffed foods, with the regulations on the use of synthetic colorants in puffed foods remaining unchanged. The varieties of synthetic colorants involved include: Erythrosine and its aluminum lake, indigo and its aluminum lake, brilliant blue and its aluminum lake, Tartrazine and its aluminum lake, Sunset yellow FCF and its aluminum lake, carmine and its aluminum lake, Allura Red AC and its aluminum lake. In the remarks of the regulations on the use of the above varieties for puffed food, only Erythrosine, only indigo, only brilliant blue, only Tartrazine Only Sunset yellow FCF, Carmine and Allura Red AC can be used.
(2) Withdraw the varieties of aluminum containing food additives such as acid Aluminium phosphate sodium phosphate, silicon Sodium aluminate and octenyl aluminum succinate starch, and delete their use regulations
In order to reduce the intake of aluminum and the variety of aluminum containing food additives, with reference to the latest international regulations on aluminum containing food additives and in combination with the actual use of China's food industry, Sodium aluminate and octenyl aluminum succinate starch can be replaced by other food additives with the same function in the corresponding food categories. Acid Aluminium phosphate sodium phosphate is one of the 38 food additives to be withdrawn by the Ministry of Health, Its use regulations are basically the same as those of Potassium alum and Ammonium alum. Based on the above situation, the Working Group proposes to revoke the above aluminum containing food additives and their use regulations.
3.2 Revision of 38 Food Additives Proposed to be Revoked by the Ministry of Health
According to the provisions of the Food Safety Law and the Management Measures for New Varieties of Food Additives, in January 2012, the Ministry of Health publicly solicited opinions on the safety and process necessity of 55 food additives in the National Food Safety Standard for the Use of Food Additives (GB2760-2011). It was found that 17 of these food additives are still in production and use. The Ministry of Health has once again publicly solicited opinions on the necessity of processing 38 other food additives such as 2,4-dichlorophenoxyacetic acid, and incorporated the revision of the regulations on the use of these food additives into the revision of the GB2760-2011 standard.
During the process of soliciting opinions, the revision working group received a total of 305 opinions from 132 units and individuals. The standard revision working group conducted a systematic analysis of the collected opinions and organized relevant industry associations to conduct research on the actual use of the above food additives. Based on the principle of process necessity, the Ministry of Health re evaluated the 38 food additives proposed to be revoked. Referring to the international use of the above varieties, the revision work of the above varieties was completed. The revised results suggest the revocation of 14 types of food additives and their usage regulations, while retaining 24 types of food additives and their usage regulations. The specific revision results are shown in Attachment 1.
3.3 Revision of the Regulations on the Use of Food Additives in Appendix A of GB2760
The evaluation center has created a table on the necessity of food additive processes in GB2760-2011, which was filled out by members of the revision working group. Surveys were conducted in various industry associations based on food classification, and the process necessity of each use regulation for each food additive was sorted out.
Referring to the regulations on the use of food additives in other foreign countries and international organizations, combined with the process necessity information submitted by various industry associations, the regulations on the use of some food additives have been revised based on risk assessment, and the process necessity principles for the use of food additives in some food categories have been sorted out.
After sorting out, it is recommended to delete some food additives in certain food categories without process necessity, specifically involving 50 provisions for 37 types of additives (see Annex 2 for specific content).
Referring to the relevant regulations of GSFA and taking into account the actual use of food additives in China's food industry, the usage regulations of some food additives have been revised, specifically involving 13 types of additives (see Annex 3 for specific content).
1. Appendix C Revision of the Regulations on the Use of Processing Aids
During the revision of this standard, China Foods Limited Additives and Ingredients Association reported that three substances, namely, polyoxypropylene glyceryl ether, polyoxypropylene oxyethylene glyceryl ether and sucrose polypropylene ether, used to play a defoaming role in the production of soybean products and fermented products as processing aids. In recent years, the application enterprises have better alternative products, and the relevant food production enterprises have stopped using the above three processing aids, At present, there are no enterprises producing the above substances, so the above three processing aids no longer have process necessity in the food processing process. It is recommended to delete the above three types of processing aids and their usage regulations from GB2760.
2. Appendix D Revision of the Regulations on the Use of Adhesive Base
At present, China is developing the "National Food Safety Standard for Rubber Base General Standard", therefore the provisions on the use of rubber base in Appendix D of GB2760 have been deleted.