Additives – beware of Chinese regulations

On September 2017, the AQSIQ announced that a total of 233 batches of imported food from 34 countries or regions were tested as unqualified for import. Among those, 67 batches were rejected because of use of food additives beyond allowed scope.

For example:

• Nissin Udon noodles were rejected for excessive use of Vitamin B1, B2;
• Nestle chocolate powder, were rejected for excessive use of copper gluconate;
• Godiva truffle chocolates, were rejected for excessive use of potassium sorbate;
• WIBERG Seasonings, were rejected for excessive use of several vitamins;
• NEUHAUS black chocolate, were rejected for excessive use of cochineal;
• UNILAC grated Parmesan Cheese, were rejected for excessive use of sodium nitrate;
• Chewing gum with watermelon flavor, were rejected for excessive use of quinoline yellow;
• Candies, were rejected for excessive use of caffeine;
• Marshmallow, were rejected for excessive use of sorbitan monooleate ethoxylate, sodium methyl paraben, capsicum oleoresin;
• Lemon biscuit, were rejected for excessive use of curcumin;
• Toffee, were rejected for excessive use of anthocyanin, chlorophyll.

Every months AQSIQ releases similar reports; non-allowed use of additives is one of the most frequent causes of rejection to importation of food products.

China has requirements for the use of food additives, which basically works with positive lists of allowed additives – mainly contained in GB 2760-2014.

The lists specify also the food products for which each additive is allowed, as well as the maximum amount.

Beside GB 2760-2014, other additives are allowed as long as specifically approved by NHFPC – which upon approval issues the corresponding standard for the new additive, including the allowed use scope. Moreover, it is possible the specific vertical standard applicable to a certain product also contains provisions about additive use for that product.

Caffeine is an interesting example: it is considered as an additive – in which case it is regulated by relevant provisions of GB 2760; however it can also be naturally present in some food ingredients (such as coffee beans or tea leaves): for some of these its maximum amount is regulated (e.g. tea, coffee), for other it is not (e.g. carbonated drinks).