Recently, the use of food additives has once again caught the eye of massive consumers. As we know, the use of food additives worldwide is subject to strict regulations of different degrees so as to ensure the safety of their use and the need for process addition. Due to disparate impact of economic, social, dietary habits and other factors, the food additive management system varies in different countries and regions with their own characteristics. Food exporting enterprises should understand the specific regulations of their target countries in order to ensure the compliance of their product exports. In order to enable relevant enterprises to gain an in-depth understanding of the differences in the regulation of food additives in various countries/regions, Global Foodmate is sharing our analysis of the regulatory requirements of food additives in various countries/regions, this session we will introduce how the Eurasian Economic Union manage food additives.
 
I. Introduction of the EAEU
 
The Eurasian Economic Union, formerly known as the Customs Union of Russia, Belarus and Kazakhstan, was formally upgraded to the Eurasian Economic Union(EAEU) on January 1, 2015, according to the provisions of the Treaty on the Eurasian Economic Union, headquartered in Moscow, its member states include Russia, Belarus, Kazakhstan, Kyrgyzstan and Armenia. The permanent management body is the Eurasian Economic Commission. In the field of food safety regulation, the treaty requires member states to follow general food safety regulations, including food standards, regulatory requirements for the use of food additives, labeling requirements, and product-specific technical regulation provisions. In view of this, the use of additives in products exported to EAEU member states must comply with the relevant Eurasian Economic Union regulations.
 
II. Overview of food additive regulation
 
The Council of the Eurasian Economic Commission is responsible for issuing technical regulations and regulatory standards on food safety in the Union in order to ensure the establishment of mandatory and uniform enforcement requirements for food additives, flavors and fragrances, and processing aids and their use in food products within the Union's unified customs territory. The Union's technical regulations stipulate that food additives, flavors and processing aids may be allowed to circulate in the Union's unified customs territory only if they meet the requirements of the technical regulations and other Union technical regulations of equal force. Food additives that do not meet the requirements of the technical regulations are not allowed to be marked with the EAC and are not allowed to be put into circulation. Food additives, flavors and fragrances and processing aids circulating in the unified customs territory should provide information to prove their safety, to ensure their traceability (product accompanying documents) and information on the storage conditions and expiration dates of the relevant products.
 
For food additives with no history of use or newly developed varieties, the use need to apply to the Department of Technical Regulations and Standards under the Eurasian Economic Commission for the risk assessment and other necessary experiments to prove that its use is harmless to humans before it can be used in food production.
 
III. The management regulations of food additives use
 
The regulation of food additives, flavors and fragrances and processing aids in the Eurasian Economic Union is mainly based on technical regulation TR CU 029/2012 "Food Additives, Flavors and Fragrances and Processing Aids", the main content includes the categories and types of food additives, food safety requirements, food additive identification specifications, the maximum level of use of various types of food additives requirements, food additives conformity assessment requirements, the Flavor and fragrance use requirements. The technical regulations on the classification of food additives are mainly divided by the function of additives, and in different appendix tables on the function of additives involving preservatives, coloring agents, flavor enhancers (excluding nutritional fortification) in different categories of products, such as the maximum use level requirements are regulated, and certain categories of products in the category of prohibited additives are described. It should be noted that the Eurasian Economic Union has not developed a detailed food classification standard for the use of additives, so when judging an additive whether it can be used in a product needs to be combined with the Union products' Unified Code for External Economy (TN VED) to conduct a unified analysis of research.
 
For the requirements of flavors and fragrances and processing aids use, TR CU 029/2012 has developed list of processing aids and list of flavors allowed to be used in different appendix tables. The flavors and fragrances in the list are allowed to use in food production as needed.
 
For the requirements of food additives numbering, the Eurasian Economic Union adopted the EU food additive numbering system (E-number). The method is to add "E" before the number of food additives, such as E967 xylitol. Food additives with E-number indicate that they have been approved for use by the Eurasian  Economic Union.
 
For nutritional fortification, the Union has not yet developed a unified standard of use. The use need to follow the corresponding regulatory requirements of certain member states: such as the Russian Federation SanPiN 2.3.2.2804-10 "Food Nutrition, safety and Health Requirements" Appendix 19 provides detailed requirements for the use of nutritional fortification in specific categories of products specifications.
 
IV. The food additive labeling requirements
 
Eurasian Economic Union Technical Regulation TR CU 022/2012 "Food Labeling" is the main basis for food labeling, which clearly stipulates that food labeling must truly reflect the characteristics of the product and must not contain information that misleads consumers. This technical regulation requires the labeling of food additives should identify its functional name, the name of the additive (available INS number or E code as options). If an additive has multiple functions, the specific functions performed in the product should be identified. If the product label has been marked "carbonic acid" or similar words, the ingredients used in the carbon dioxide can be exempted from marking. For the use of flavors and fragrances in the product, the word "flavor and fragrance" (ароматизатор (ы)) should be identified in the label, and the flavor ingredients associated with the name of the food may be exempted from labeling.
 
For the claims such as "0 added" and "not added" on the label of the product, the claiming party shall make the "0 added" claim for a certain component in the product on the premise that the product allows the addition or use of certain additives such as preservatives or colorants under the condition of following facts; If the use of an additive is prohibited in the product itself, no "add zero" claim shall be made for that additive. 
　　

V. Examples of food additive use
 
Take sodium glutamate (E621) as an example, to determine whether it can be used in condiments and what is the maximum use amount. The conclusion of the analysis is as follows.
 
(1) According to TR CU 029/2012 Appendix Table 2, sodium glutamate (E621) can be used in food production as a flavor enhancer, so it is determined that sodium glutamate is approved.
 
(2) Since there is no food category classification standard in the Eurasian Economic Union, it is necessary to determine whether sodium glutamate can be used in condiments based on their use attributes.. According to TR CU 029/2012, Appendix 16, "Standards for the Use of Flavor Enhancers", sodium glutamate can be used in condiments and seasonings (Приправы и пряности) alone or in combination with other glutamate salts such as potassium glutamate (E622) at the maximum use level of GMP. The maximum use level of sodium glutamate is 10g/kg for all food categories other than condiments and seasonings, and companies must be clear about the corresponding products and use standards when using the additives to avoid over-range or over-limit use, resulting in product non-compliance.