The definition of "food additive" should be revised

In recent years, with the occurrence of some "food additives" events, "food additives" as a hot topic with more prominent issues, high degree of concern and difficult governance, are increasingly concerned by the whole society For this reason, the food regulatory authorities such as food and drug supervision, industry and commerce, quality supervision and so on have carried out various special rectification actions for food additives several times a year In the daily food safety supervision of catering services, the author found that many administrative counterparts and some law enforcement officers are not clear about what is food additives, and often confuse the condiments in daily life with food additives The main reason is that the definition of food additives in the food safety law is too wide The definition of food additives is clearly defined in Chapter 10 "Supplementary Provisions" of the food safety law, that is, Article 99 of the law stipulates the meaning of the following terms in this Law Food additives refer to synthetic or natural substances added into food for the purpose of improving food quality, color, fragrance and taste, as well as for the purpose of antisepsis, preservation and processing technology According to this regulation, the price of pepper, seasoning, vinegar, salt, pepper and other seasonings in daily life fully meet the definition of "food additive" Because in daily life, the purpose of using the above condiments by the public is to improve the quality, color, fragrance and taste of food, as well as the need of processing technology, and they are all natural substances added into food, among which salt can also be synthesized artificially It can be seen from the legal concept of food additives that the above condiments in daily life can be included in the category of "food additives" However, in the practice of law enforcement, the supervision department has never supervised and managed it according to the requirements of "five specialties" (purchasing by special personnel, keeping by special personnel, receiving by special personnel, registering by special personnel and keeping by special counter) To sum up, the definition of "food additive" in Article 99 of food safety law is not rigorous, which is easy to cause ambiguity and misunderstanding, and should be modified The author suggests that the definition of "food additive" in the regulation should be revised to "food additive, which refers to the synthetic or chemical substances added into food to improve the quality, color, fragrance and taste of food and to meet the needs of antisepsis, preservation and processing technology" The reasons are as follows: by referring to the full text of the food safety law, the author found that the provisions concerning "food additives" basically include "no chemicals other than food additives shall be added or used in food" For example, Article 28 of the law stipulates: "it is prohibited to produce and market the following foods: (1) foods produced with non food raw materials or foods with chemicals other than food additives, or foods produced with recycled foods as raw materials." Article 46 stipulates: "food producers shall use food additives in accordance with the provisions of food safety standards on the variety, scope of use and dosage of food additives; they shall not use chemicals other than food additives or other substances that may endanger human health in food production." Article 85 stipulates: "in case of any of the following circumstances in violation of the provisions of this law, the relevant competent departments shall, in accordance with their respective responsibilities, confiscate the illegal income, food illegally produced and operated, tools, equipment, raw materials and other articles used for the illegal production and operation （1） The production of food with non food raw materials or the addition of chemicals other than food additives to food, or the production of food with recycled food as raw materials " According to the requirements of the integrity of the legal system and the rigor of legislation, the terms before and after a law should be consistent Therefore, the definition and description of food additives in the "Supplementary Provisions" of the food safety law should be "chemical substances" rather than "natural substances" In this way, the condiments necessary for daily life are no longer in line with this definition, making the concept of "food additives" more scientific, and avoiding differences in law enforcement practice In addition, the listed food additives are also chemical substances according to the application scope and dosage standards of food additives published by the relevant national departments In view of this, the author hopes that when the relevant departments revise the food safety law, they can make up for this defect and make the provisions of the food safety law more serious and accurate.