Discussion on the compliance of food flavors and fragrances as raw materials for compound food additives

Jiangsu Provincial Market Supervision and Administration Bureau Peng Honglei

In recent years, in the work of food additive production license in Jiangsu Province, some enterprises have used food spices or food flavors as raw materials for compound food additives to participate in the composition of the formula when declaring the production license of compound food additives, and have been refused by the provincial production license approval department on the grounds that they do not meet the "National Standard for Food Safety General Principles for Compound Food Additives" (GB26687-2011
).

Some enterprises have raised doubts about this, arguing that food spices belong to one of the functional categories of food additives in the "National Standard for Food Safety Food Use Standards" (GB2760-2014), and the composition of the formula for participating in compound food additives as raw materials meets the definition of compound food additives, that is, "in order to improve food quality and facilitate food processing, two or more single varieties of food additives, with or without added excipients, are mixed by physical methods
.

These two views seem reasonable, but they are extremely one-sided and incorrect
.

Why does the production license approval department refuse to accept the application for a production license for compound food additives that use food spices or food flavors as raw materials to participate in the composition of the formula? The main reasons are as follows
.

First, the definition of food flavors in the National Standard for Food Safety (GB30616-2020) is a concentrated blending mixture composed of food flavors and food flavor accessories to play a flavoring role (except for salty, sweet or sour products, and does not include flavor enhancers).

The second is the "National Standard for Food Safety General Principles for Compound Food Additives" (GB26687-2011) 4.

Third, for the "National Standard for Food Safety Food Additive Use Standard" (GB2760-2014) Appendix B, which is both a food flavor variety used for the preparation of food flavors and food spices with other food additive functions, if it plays other food additive functions in food, it can be used as raw materials for compound food additives, but it should comply with the provisions of
GB2760.

Fourth, the "National Standard for Food Safety General Principles for Compound Food Additives" (GB26687-2011) stipulates the definition of compound food additives: in order to improve food quality and facilitate food processing, two or more single varieties of food additives, with or without added excipients, are mixed by physical methods into food additives
.

Fifth, if food spices and food flavors are allowed to participate in the formulation of compound food additives, it will cause confusion
in the classification of the attributes of such products.

The "Reply of the Jiangsu Provincial Health and Family Planning Commission on whether food spices and food flavors can be used as components of compound food additives" points out: "National Food Safety Standard General Principles for Compound Food Additives" (GB26687-2011) clearly states that "this standard applies to all compound food additives except food flavors and gum-based candy base agents"
.

In summary, the Jiangsu Provincial Food Additive Production License Approval Department does not accept compound food additive formulas containing food spices and food flavors (except in the case of the third reason) in the production license of compound food additives that meet the requirements of
relevant national food safety standards.

China Food News (2022-09-26 06 edition)

(Editor-in-charge: Yang Xiaojing)