Forthcoming Global Meeting on Food Additives (Macau (China), 17-24 March 2017) is to set Important New International Standards Fostering Global Harmonization and Facilitating Movement of Processed Foods Globally
This article oringally appeared in World Food Regulation Review and is reprinted with permission.
Will the next session of the Codex Alimentarius Committee on Food Additives come up with further global harmonization on food additives? Most likely yes, but, as usual, with a significant level of uncertainty about the extent of which such progress may be made.
Coming up mid-March, hundreds of governmental food safety managers and representatives of consumer organizations and food and drink industry sectors from all over the world will gather in Macao (China) to discuss and make recommendations to the Codex Alimentarius Commission to adopt further international references for the use of food additives. Typically, the Codex Committee on Food Additives set the scene for further global harmonization of the future rules applicable to the addition of technological ingredients to food (i.e. food additives at large, including enzymes, flavorings, colours, sweeteners, other food additives).
GSFA pending provisions: the main piece of work
Routinely, each CCFA yearly meeting discusses hundreds of pending provisions of many food additives for their final inclusion into the Codex Alimentarius General Standard on Food Additives (i.e. GSFA). On this year’s agenda, the CCFA will try to finalize its discussion from last year on hundreds of food additive use level provisions (e.g. most of them emulsifiers, humectants, bulking agents) in the first half-range of all GSFA food categories (i.e. from dairy products to edible casings - including confectionery products, cereals and cereal-based products, edible ices, processed fruits and vegetables, bakery wares and meat products). Some sub-food categories are not concerned as they were excluded from the start of the current scope of this work (e.g. canned or bottled (pasteurized) fruit and vegetable; vegetable purees, paste and pulps). Last year CCFA decided to discuss some improvements to existing provisions for cocoa and chocolate products and hard and soft can-dies to take into account CCFA former decisions on combined uses of some emulsifiers and decisions to further align GSFA with the requirements set in the Codex Alimentarius Regional Standard on Halawa Tehenia.
For many food sectors and governments, it is essential that those discussions are completed, as developing countries with limited public finance resources often use the provisions adopted in the Codex Alimentarius GSFA to adopt the same - or similar - provisions in their own legislation to offer an adequate level of protection to their own consumers regarding imported products and products manufactured locally.
For business operators, the harmonization of national legislation implementing the Codex GSFA use levels is a further source of simplification in their recipes and is undoubtedly fostering global market growth based on internationally agreed safe grounds and harmonization of all applicable standards into a single one.
Once that work is completed, the upcoming CCFA is likely to decide to embark on a new work to complete similar reviews of all the pending food additive provisions (except sweeteners and colors which are for the time being kept postponed) in the GSFA for the second half of the food categories of the GSFA, i.e., from the food category 9.0 Fish and fish products, including molluscs, crustaceans, and echinoderms down to 16.0 Prepared foods. However, it is unknown and yet to be determined how the upcoming CCFA will address that remaining work along with its long list of priorities and its expected discussion on how such priorities might be set from this year on. It may also depend greatly on the discussion paper on CCFA work priorities (see further down below).
More on the GSFA to be discussed
The upcoming CCFA will also allocate time to discuss:
(i) how to make progress on several food additive provisions in grape wines and also to make a decision with regards to the automatic permission of any food additive assigned an Acceptable Daily Intake (ADI) not specified by JECFA as acceptable in grape wine, while assorting them with the conditions (a) not to change the natural and essential characteristics of the grape wines and (b) not any substantial change in the composition of the wine and (c) make a determination and whether such provisions to be included into the GSFA shall be GMP or those numerical maximum use levels set by the OIV;
(ii) handling nitrites and nitrates uses in cheese and processed cheese, in heat-treated or other pro-cessed meat products and in fish and fish products;
(iii) continuing the debate on benzoates level(s) in water-based flavoured drinks (so-called ‘soft drinks’, as well as the ‘sports’ and ‘energy’ drinks);
(iv) making some required adapted changes to notes of existing food additive provisions to some chocolate and cocoa products;
(v) taking into account the consequences of the recent changes to the descriptors for some milk and milk products categories and adapt the existing food additive provisions adopted in the GSFA accordingly; and,
(vi) using real use levels and technological justifications which have been reported on adipic acid usages since last meeting and asking JECFA to perform a dietary exposure assessment accordingly.
The upcoming CCFA will also consider, one by one, the requests received from Codex member countries and Codex observer organizations on new and/or revised use levels for inclusion - at a proposed draft stage only - into the GSFA, for further discussion at a later stage (e.g. paprika extracts).
Some of the above topics are expected to take quite some time before consensus may emerge around them (e.g. benzoates in ‘soft drinks’; grape wine with max limits or not?; nitrates/nitrites are they food additives preserving the safety of foods or prevention agents against pathogenic microorganisms?). Some others may be able to get the sup-port of all countries attending the upcoming CCFA (e.g. alignment on cocoa and chocolate products). However, many acquainted stakeholders who generally say that anticipating outcome and results from a Codex Alimentarius Committee meeting is like predicting the six winning numbers at a national weekly lottery. Humbly, they would rather prefer to say: “Future will tell”.
CCFA also endorses and gives work priorities to the FAO/WHO risk assessment body JECFA
In addition, the upcoming CCFA will review specifications of identify and purity of more than a dozen food additives (and even more on flavorings) elaborated or revised and approved by the last meetings of the Joint FAO/WHO Expert Meeting on Food Additives (i.e. JECFA) and propose them officially to become Codex Alimentarius “standards”. JECFA secretariat will also report on the very comprehensive and significant work accomplished to move away from a single specification for all modified starches and develop an individual specification for each of them.
The CCFA will also revise the priority list of sub-stances which it decides each year shall be subject to a thorough scientific review by JECFA experts. It may include (i) full safety evaluation with establishment of specifications, or (ii) change to existing specifications (e.g. updated method of analysis), or (iii) safety evaluation for use in foods for special population groups (e.g. intended for infants or young children), or (iv) any other scientific assessment and inputs required from JECFA. For example, the EU is proposing several enzymes to be added for safety evaluation by JECFA, as well as a revision of the JECFA specification of glycerol ester of wood rosin, as a substance used in beverages. The European emulsifier industry suggests to extend the use of CITREM to other food categories. Finally, the global flavor industry suggests three new flavorings to be evaluated by JECFA and would like JECFA to put higher on its work priorities pending requests already assigned to JECFA by CCFA (27 substances), or to complete existing re-view by JECFA as additional information requested is or has been submitted (39 substances) and to reconsider the review of one substance based on new safety data generated and available. It may also include the reevaluation of several food additives that the CCFA may deem appropriate to get a JECFA opinion on the state-of-the-art scientific facts helping to confirm the acknowledged margins of safety of such substances, such as some synthetic colors, or substances that JECFA has not reviewed for a long time or for which new safety data have become available. The final list of JECFA priorities is generally discussed by an in-session working group established at the start of the CCFA meeting and the CCFA will then review the working group’s recommendations; generally on the third day of its plenary.
CCFA constantly adapts the International Numbering System (INS) of Food Additives to Innovation
The third main part of CCFA agenda is to update the Codex Alimentarius International Numbering System for food additives, see document CX/FA 17/49/3, which is the international standard which allocate a unique code number to each food additives and define the functional classes and the technological purposes for which the food additive is intended to be used in food and food processing. For example, new natural color extracts are proposed to be added to the INS as well as a new form of lecithin. Trehalose is also proposed to be added in the INS with specific technological functions which are unrelated to its novel food status in the 28 EU member countries. The other main changes are a proposal to take out all the listed numbered enzymes from the INS, which, if this is accepted by CCFA, would mean enzymes may not be viewed as food additives at the international level in the future but subject to a dedicated approach, likewise the one which now prevails in the 28 EU member countries since 2008.
CCFA to respond questions from other Codex Alimentarius Committees as well as ensuring coherence between Codex Alimentarius food standards and the GSFA
As an important fourth element, the CCFA will address questions which have arisen from other Codex Alimentarius specialized Committees, such as the Codex Committee on Nutrition and Special Dietary Uses (i.e. “baby foods”, food supplements, foods for other medical purposes).
The upcoming CCFA will also continue its work on ensuring better alignment between the provisions for food additives included in vertical commodity standards and the corresponding food categories defined in the GSFA. The main focus of this upcoming CCFA will be on standardized fish and processed fish products, in particular with the use of Good Manufacturing Practice (GMP) food additives from the Table 3 of the GSFA which would normally not be approved in those categories, or to the contrary to exclude some provisions from the use in standardized products.
Finally, the CCFA will continue to fulfil its mandate to endorse proposed draft food additive provisions coming from other Codex Committees dealing with elaborating vertical standards on Commodities and other Standardized Foods. The upcoming CCFA will address this time requests for provisions of food additives in standardized canned pineapple, in standardized quick frozen vegetables (e.g. broccoli, Brussels sprouts, cauliflower, fried potatoes, peas, spinach, green and wax beans), standardized pickled fruits and vegetables, and Asian regionally standardized non-fermented soybean products and laver products, and Central, Latin American and the Caribbean region-ally standardized yacon.
CCFA to discuss new ways of setting up its own work priorities
Last but not least, the CCFA will also discuss the best ways to organize its future work and priorities based on a discussion paper (CX/FA 17/49/14) prepared jointly by China and the USA, countries respectively chairing the CCFA and the workings group(s) relating to the GSFA. This discussion will be a very important step forward for the CCFA if there is consensus on the future proposals. But the topic is also very sensitive as a lot of stakeholders would like to see the criteria helping the advancement of the provisions in line with their global interests. Therefore, the topic may lead to long negotiations between countries on those future criteria or procedure by which the CCFA will adopt its future working priorities. Many stakeholders involved in CCFA meetings hope that the new approach will bring a bit more transparency to the decision-making process and - maybe even more importantly - a much more foreseeable timeline than at present for a given provision, from its first application to CCFA, until its final adoption and publication into the GSFA.
Q&A about the Codex Alimentarius and the CCFA
What is the Codex Alimentarius?
The Codex Alimentarius is a compendium of internationally recognized ‘norms’, generically called ‘standards’, in the area of food safety and fair practices in food trade, which include for example regulating maximum permitted use for food additives or pesticide residues but also define rules on food labelling, including nutrition labelling. The Codex Alimentarius contains also many self-standing food standards (so-called “commodity standards” or “vertical food standards”) defining minimum quality and safety requirements, including labelling and methods of analysis guidance, on standardized foods. The Codex Alimentarius also includes guidelines which give a frame to countries to set their own national legislation based on general safety objectives determined by the Codex Alimentarius Commission and recommended code of practices which provide technical must-to-do procedures to ensure good hygiene for a number of varied processing for example or specific recommendations to manage and control the absence (or tolerable presence below threshold of no safety concerns) of microbiological pathogens which may be present in foods. Codex Alimentarius standards are adopted by only one body, the Codex Alimentarius Commission. The Codex Alimentarius Commission is actually a semi-self-standing UN body which currently counts 187 member countries and one member organization (i.e., the European Union as such) and 240 Observer organizations; including 56 intergovernmental organizations (such the African Union, IPPC, OIE, OIV or IIF), 16 United Nations bodies (such as the International Trade Centre UNCTAD) and 168 non-governmental organizations (such as Consumers international). The Codex Alimentarius Commission has always been since its first meeting in 1963 under the dual umbrella of the FAO and the WHO, two established permanent organizations of the United Nations (UN). It is always good to remember that the Codex Alimentarius is born from and is still ruled within the Joint FAO/WHO Food Standards Programme, with a regularly confirmed dual primary mandate to “protecting the health of the consumers and ensuring fair practices in the food trade”.
Why Codex Alimentarius standards/norms are so important globally and at national and regional level?
The Codex Alimentarius norms (synonym to “standards” used in its common sense), although voluntary by nature, have been used and are being used as references by the various arbitration bodies of the World Trade Organisation (WTO) when they aim at resolving trade disputes between countries in the area of food safety protection (so-called sanitary and phytosanitary measures, which includes food additives provisions but also part of labelling, such as allergen labelling) and fair practices in food trade (i.e. so-called technical barrier to trade measures, which include primarily composition factors, labelling (e.g. denomination of sales, nutrition facts panels, etc.), weight and measures, methods of analysis).
What is the Codex Alimentarius Committee on Food Additives?
The Codex Alimentarius Committee on Food Additives (CCFA) is only one of the seventeen other active Codex Alimentarius technical bodies (i.e. Committees and ad hoc Task Force(s)), which help the Codex Alimentarius Commission to develop the standards, guidelines, recommended codes of practice and other recommendations, which are in the end approved by the yearly Codex Alimentarius Commission. The seven regional Codex coordinating committees also may propose the adoption of standards to the Codex Alimentarius Commission, but the scope of those standards would then only be regional, also their relevance remains of global reach. The CCFA meets yearly and is focusing on all food additives, including flavorings, enzymes and to a limited extent so far pro-cessing aids as well. The CCFA does not deal however with so-called “indirect food additives” (i.e. substances permitted to migrate to food from food contact materials used in packing media/packaging).