"Food additives are important basic raw materials in the modern food industry, and play an important role in improving food quality and quality, improving food processing conditions, and extending the shelf life of food. But do you understand that many food additives because of its own with flammable, skin corrosion / irritation, eye irritation and other hazardous properties, and is included in China's "Catalogue of Hazardous Chemicals" in the import and export links, to meet the requirements of food additives inspection and supervision requirements at the same time, but also need to meet the requirements of the inspection of hazardous chemicals.
First, what is a food additive?
GB 2760-2014 National Standard for Food Safety Standard for the Use of Food Additives" on the definition of food additives: "to improve the quality of food and colour, aroma and taste, as well as for preservation of corrosion, preservation of freshness and processing needs to be added to the food of synthetic or natural substances. Flavours for food, base agent substances in gum-based confectionery, and processing aids for the food industry are also included."
According to their functional categories, they can be divided into 22 categories such as acidity regulators, anti-caking agents, defoamers and antioxidants.
Tip: Now some people talk about food additives, mainly due to the repeated exposure of "melamine", "Sudan red", "industrial gelatin" and other food safety incidents are many Food safety incidents such as "melamine", "Sudan red", "industrial gelatin" and many other food safety incidents are related to "illegal additives" in food, these additives are often easy to confuse the concept with the normal use of food additives. In fact, food additives are important products of the modern food industry, and food additives that meet the varieties, scope and usage levels stipulated in the relevant national standards are in compliance with food safety requirements and can be consumed without fear.
Food additives listed in the Catalogue of Hazardous Chemicals (2015 Edition)
Take a look at several common food additives that are listed in both the GB 2760-2014 National Standard for Food Safety Standard for the Use of Food Additives and in our "Catalogue of Hazardous Chemicals (2015 Edition)".
Sodium Nitrite
Sodium nitrite can be used as a food additive, mainly functioning as a colour protectant and preservative, and is permitted to be used in cured meat products, soy sauce and marinated meat products.
In the Catalogue of Hazardous Chemicals (2015 Edition), Sodium Nitrite is listed as item 2492 with CAS number 7632-00-0, and its hazard categories include oxidising solids, acute toxicity, and hazardous to the aquatic environment.
In the UN Recommendations on the Transport of Dangerous Goods? Model Regulations (TDG), sodium nitrite is classified as oxidising substance of Class 5.1 and toxic substance of Class 6.1, with UN No. 1500 and recommended packing group III. Its dangerous goods transport pictogram is:
Potassium hydroxide
Food-grade potassium hydroxide can be used as an acidity regulator for adjusting the pH value during the production process, and is allowed to be used in appropriate quantities according to production needs during the processing of prepared milk powder and prepared cream powder, biscuits, infant formulae and other foodstuffs.
In the Catalogue of Hazardous Chemicals (2015 Edition), Potassium Hydroxide is classified as item 1667, CAS No. 1310-58-3, and its hazard categories include skin corrosion/irritation and severe eye damage/eye irritation.
In the UN Recommendations on the Transport of Dangerous Goods? Model Regulations (TDG), sodium hydroxide is classified as a corrosive substance of Class 8, UN No. 1813, with a recommended packing group of Class II.
Sulphur
Sulphur can be used as a bleaching agent and preservative in food processing, limited to fumigation of dried fruits, candied and cooled fruits, etc., and it is the sulphur dioxide it produces that really acts as a bleaching and preservative.
In the Catalogue of Hazardous Chemicals (2015 Edition), sulphur is listed as item 1290, CAS number 7704-34-9, and its hazard class is flammable solids.
In the UN Recommendations on the Transport of Dangerous Goods? Model Regulations (TDG), sulphur is classified as Class 4.1 flammable solids, UN No. 1350, with a recommended packing group of Class III.
Ethyl Acetate
Ethyl acetate is classified as a "permitted synthetic flavouring for food use" in the GB2760 standard, and can also be used as a processing aid in the food industry, as a solvent for the extraction of prepared wines, and in the processing of yeast extracts.
In the Catalogue of Hazardous Chemicals (2015 Edition), Ethyl Acetate is classified as item 2651, CAS No. 141-78-6, and its hazard categories include flammable liquid, severe eye damage/eye irritation, and specific target organ toxicity.
In the UN Recommendations on the Transport of Dangerous Goods? Model Regulations (TDG), Ethyl Acetate is classified as Class 3 flammable liquid, UN No. 1173, and the recommended packing group is Class II.
03 Requirements for Inspection and Supervision of Import and Export of Hazardous Chemicals
According to the "Announcement on Issues Related to the Inspection and Supervision of Import and Export of Hazardous Chemicals and Their Packaging" (General Administration of Customs Announcement No. 129 of 2020), the Customs implements the inspection of import and export of hazardous chemicals and their packaging listed in the Catalogue of Hazardous Chemicals.
Therefore, enterprises in the import and export of sodium nitrite, potassium hydroxide and other food additives listed in the "Catalogue of Hazardous Chemicals" should truthfully declare the properties of hazardous chemicals in the goods, and provide relevant materials as required.
Take sodium nitrite as an example, import declaration should fill in the hazardous category of sodium nitrite, packaging category, UN number, packaging marking, etc., and should also provide: "Declaration of Conformity of Imported Hazardous Chemicals Enterprises", Chinese hazardous publicity labels, Chinese SDS samples, etc.; export declarations should be provided with the "Declaration of Conformity of Exporting Hazardous Chemicals Producing Enterprises", hazardous characteristics of the classification and identification of the report, hazardous Publication of labels, safety data sheets samples, as well as the use of packaging attached to the "outbound cargo packaging performance inspection results," and other information. Customs implementation of the inspection mainly includes:
(a) Whether the main ingredients/component information, physical and chemical properties, and hazard class of the product comply with the relevant regulations.
(B) whether the product packaging is a hazardous publicity label (imported products should be a Chinese hazardous publicity label), whether accompanied by a safety data sheet (imported products should be accompanied by a Chinese safety data sheet); hazardous publicity labels, the content of the safety data sheet in line with the relevant provisions.
(C) the import of packaging used in packaging type, packaging marking, packaging categories, packaging specifications, unit weight, packaging and other conditions in line with the relevant provisions; export packaging should be in accordance with the sea, air, road and rail transport export of dangerous goods packaging inspection and management requirements for the implementation of packaging performance testing and use of identification.
If the enterprise declared the above import and export goods, not properly declared as dangerous chemicals, not in accordance with the requirements of the import and export of dangerous chemicals to provide the relevant materials and electronic ledger, the Customs and Excise Department will be based on the "Customs Law", "Import and Export Commodity Inspection Law" and its implementing regulations and other relevant laws and regulations to implement the penalties.
04 import and export food additives inspection and quarantine requirements
Import and export of hazardous chemicals used as food additives, should also comply with the relevant provisions of food safety.
Food Safety Law of the People's Republic of China and its implementing regulations: imported food additives should be in line with China's national food safety standards, export food additive manufacturers should ensure that their exports of food additives in line with the standards of the importing country (region) or contractual requirements, but also in line with China's conclusions or participation in international treaties, agreements and related requirements.
Import and Export Food Additives Inspection and Quarantine Supervision and Administration Specifications" (the former AQSIQ Announcement No. 52 of 2011), which provides for the Customs included in the "Entry-Exit Inspection and Quarantine Institutions to implement the inspection and quarantine of entry-exit commodities catalogue" in the import and export of food additives inspection and quarantine supervision and management requirements.
Food additives import and export enterprises should be in accordance with the provisions of the declaration to the Customs, and provide the following materials: trade contracts or use statements indicating the use of the product, description of the ingredients (for imports), certificate of conformity (for exports), business licence or business / production license, labels and specification samples, as well as other special circumstances of the materials, etc., related to the requirements of the quarantine should also be provided in accordance with the requirements of the relevant materials of the quarantine. Customs in accordance with relevant inspection protocols, standards and deployment of directive requirements for the import and export of food additives name, number and weight, labels, instructions, packaging and other content to implement on-site inspection and quarantine, take test samples sent to the laboratory on the quality of specifications, safety and hygiene projects and the authenticity of the label content of the authenticity of the test to verify the accuracy.
Customs reminders!
In addition to the above list of several food additives, some food additives due to their flammable, corrosive, toxic and other hazardous properties, may be dangerous chemicals. Customs reminds enterprises to pay special attention to food additives that are classified as hazardous chemicals listed in the Catalogue of Hazardous Chemicals, not only to meet the regulatory requirements for import and export of food additives, but also to meet the regulatory requirements for the import and export of hazardous chemicals, and must truthfully declare the information of the goods to the Customs. In addition, if the HS code of the imported or exported goods involves food additives, but the goods are actually used only for industrial purposes and not for food additives, the enterprises should also declare truthfully and accurately, and at the same time submit the trade contract and the certificate of using the goods only for industrial purposes.
