China's Amended GB 2760 Food Additive Standard Enters into Force

The Chinese National Food Safety Standard for Uses of Food Additives (GB 2760-2014) became effective on May 24, 2015. The final amended Standard, which replaces the 2011 version, was published by China's National Health and Family Planning Committee (NHFPC) on December 24, 2014.[^1]

GB 2760-2014 will significantly impact both domestic and overseas food producers and distributors of food and food additives in China. The use of all food additives used in food products distributed in China must comply with this Standard. Key revisions in the 2014 version of GB 2760 are discussed below.

1. Adoption of New Food Additives Approvals

GB 2760-2014 now includes approvals for food additives that were published by the former Ministry of Health (MOH) and NHFPC since the last publication of the Standard.[^2]

2. Modification of the "Carry-over" Principle (Section 3.4)

The amended GB 2760 adopts the 'Reverse carry-over' Principle[^3] to align with the current Codex standard. This principal specifies that when a food additive is not permitted in a food ingredient, but is allowed in a finished food product containing that ingredient, its addition to the ingredient is legal, provided its presence in the final product still complies with the Standard. For example, tricalcium phosphate, a common stabilizer, is not allowed in fruit jam, but it is permitted in chocolate products with a maximum use level of 5g/kg under the amended Standard. Accordingly, the fruit jam, when reserved for use in chocolates as a filling, may contain tricalcium phosphate as a sub-ingredient. However, the product labeling needs to indicate that use of the fruit jam is limited to chocolates.

3. Modification of the Food Category System Formerly Set Forth in Appendix F (Now Table E.1)

The amended Standard modifies and moves the Food Category System from Appendix F to Appendix E. The new Food Category System was created, in part, to remove overlapping food classification under the previous standard. The System lists categories of foods, such as Milk and dairy product; Fats and oils, and fat emulsions; Sweeteners, including honey; Meat and meat products; and Foodstuffs intended for particular nutritional uses.

Each of the food categories includes subcategories. For example, the meat and meat products category includes subcategories such as: fresh meat, boiled meat, sausage, and cooked dried meat products. The listings for food additives elsewhere in the Standard have been revised accordingly to reflect the updated categorizations.

4. Adjustment to the Food Additive Use Specifications in Appendix A

The listing of certain food additives have been removed from Table A.1 (The Permitted Food Additives, the Scope of Use, Maximum Use Level, and the Maximum Residual Level). For example, due to concern over the evaluated intake of aluminum by the Chinese population compared to most habitants of other countries, the revised GB 2760 has removed the previous clearance of sodium aluminosilicate, starch aluminum octenylsuccinate, and sodium aluminium phosphate-acidic.

Use specifications for some food additives have been changed in Table A.1. For example, caramel color was explicitly permitted by GB 2760-2011 in chicken essence beverages. However, due to lack of technical necessity, the new Standard has removed the approval of caramel color in chicken essence.
Use scope and maximum use levels of some food additives have been changed in Table A.1., such as L (+) -tartaric acid, dl-tartaric acid, neotame, β-carotene, β-cyclodextrin, diacetyl tartaric acid ester of mono (di) glycerides, and aspartame. Previously, they were permitted in almost all kinds of food complying with GMP in Table A.2.
Table A.3, titled 'Food Categories Excluded in the Table A.2', has been revised. In this regard, "Coarse grain flour" has been added to Table A.3, while "Formulated foods for special medical purposes" has been removed.
Specifications of food additives that are not technically necessary in some food categories have been removed from Table A.1 and Table A.2. For example, tea yellow pigment and tea green pigment are two food colorants that used to be allowed in a wide range of food products, including candies, fruit and vegetable juice, flavored drinks, etc. However, according to the research by the Government, those pigments are no longer produced, therefore, they have been removed from the amended GB 2760.

5. Modifies Use Specification for Flavoring Substances and Flavorings in Appendix B

Anise star, origanum vulgare, licorice root (Glycyrrhiza glabra), cassia (Cinnamomum cassia Blume), cloves (Eugenia spp.), allspice (Pimenta officinalis Lind L.), and dill seed (Anethum sowa D.C.), as food flavorings, are no longer permitted in foods. In addition, food flavoring substances and flavoring essence now are prohibited in tea or coffee.^[4]

On May 27, 2015, the NHFPC, in its response to the Food Industry Association of China,[^5]clarified labeling issues arising from name modifications of food additives under the amended GB 2760. Specifically, according to the Response, foods produced prior to June 30, 2016 may continue to be sold with a product label displaying the old food additive name(s) until the product expires, provided that the safety of the food is not affected; after June 30, 2016, all food additives must be displayed in the name referred to in GB 2760-2014.

The Government is currently working on a Q&A document that will provide more details regarding the implementation of this Standard. Based on an unofficial source, this document will be released in June this year.

In conclusion, GB 2760-2014 contains revisions to the listing and use scope of numerous food additives. Producers and distributors of food products marketed in China need to closely examine their product formulations to ensure compliance with the amended Standard.

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[1] http://www.nhfpc.gov.cn/sps/s3593/201412/d9a9f04bc35f42ecac0600e0360f8c89.shtml; An unofficial English translation by the U.S. Department of Agriculture can be found here: http://gain.fas.usda.gov/Recent%20GAIN%20Publications/Standard%20for%20Food%20Additive%20Use%20-%20GB2760-2015_Beijing_China%20-%20Peoples%20Republic%20of_4-28-2015.pdf

[2] These include MOH Public Notices [2010] No.16, [2010] No.23, [2012] No.1, [2012] No.6, [2012] No.15, [2013] No.2, the National Health and Family Planning Commission Public Notice [2013] No.2, [2013] No.5, [2013] No.9, [2014] No.3, [2014] No.5, [2014] No.9, [2014] No.11, [2014] No.17

[3] Section 3.4.2. "[a]n additive may be used in or added to an ingredient if the ingredient is used exclusively in the preparation of a food that is in conformity with this standard, and the quantity of the food additive in the finished food product shall conform to this Standard. Label of the ingredient of the specific food shall clearly mark that the food ingredient is used for production of the specific food."

[4] See Table B.1

[5] http://www.moh.gov.cn/sps/s3593/201505/4c7fce389d554490920c37c30b93b8cc.shtml