In 2022, China's major overseas trading partners, including the EU, the United States, Australia and New Zealand, Canada, Japan, South Korea, the ASEAN region (including Singapore, Malaysia, Thailand, etc.), and the Eurasian Economic Union, carried out a comprehensive work of formulating and revising laws and regulations in the fields of general food regulations, food standards, additive use, labeling requirements, and import and export supervision. Most of the products involved in the work are high-risk foods, including animal-derived products, compound foods, aquatic products, infant formula milk powder and specific products, such as dietary supplements, organic products, genetically modified products and halal products, etc. The adjustment and update of the contents of the relevant overseas acts and standards will inevitably have different degrees of impact on the export work in 2023. The following is a summary and analysis of the revised contents of the acts and standards with high attention of enterprises, hoping to provide help for the work of relevant parties.

1.  General food regulations

In 2022, the countries and regions that have made adjustments in the field of revision of the general legal system for food safety mainly include the United States, Canada and Cambodia, a member of ASEAN.

(1) The United States: issued the 2022 edition of the Codex Alimentarius, adjusted the requirements for the transition period of the allergen ingredient list and labeling content, and allowed pets to eat outside the restaurant;

(2) Canada: amended the Basic Food law, enterprises obtained the autonomy to formulate the size of food packaging, and clarified the specific requirements of "product category" on the label;

(3) Cambodia: The “Food Safety Law” was officially issued, requiring that the food produced and imported locally must comply with the general principles and requirements formulated by the law, and the product quality should comply with the Cambodian national standards or CAC standards (refer to CAC standards if there is no product standard in Cambodia), so as to achieve the coordination and unification of the food safety supervision in Cambodia.

(4) Indonesia: The new regulations on heavy metal pollution in processed foods were issued, and the original regulations were repealed. The maximum residue standards of various pollutants such as arsenic, lead, mercury, and cadmium in processed foods are clear. At the same time, the residual limit requirements of tin in infant formula milk powder and other products also need to be concerned.

2.  Product standards

In 2022, the EU member countries including Ireland and Malta, Japan, South Korea, India, Malaysia, Thailand, and the Eurasian Economic Union adjusted and revised the standard requirements of specific product categories, such as genetically modified products, organic products, food supplements, infant formula products and vegetarian products, to make them more in line with market demand. Among them, special attention should be paid to:

(1) Ireland: issued the new food and organic product regulations, and revised the relevant EU regulations that the country complies with based on the implementation requirements of the country's food safety, such as the requirements for the launch of new food on the market and the requirements for organic production and sales;

(2) The UK: revised the regulations on infant formula products and other products, and expanded the list of nutritional fortifiers allowed in the production of processed grain food and infant food;

(3) Japan and South Korea: Japan issued product standards for a variety of products, such as soybean meat and miso, while South Korea revised the list of raw materials and some indicators of health functional foods, such as the specifications of total fatty acids;

(4) Eurasian Economic Union: clarified the product standard requirements of chocolate and its products, revised the definition and labeling requirements of milk and dairy products, and stipulated the transition period for the implementation of technical regulations on packaging drinking water and poultry meat and its products;

(5) Singapore: 59 product standards, such as corn flour, cassava flour, fruit bread, etc., were abolished, but food manufacturers must be responsible for the product name and description used on the label, and shall not make false publicity;

(6) Thailand: clarified the product standard of genetically modified food, and stipulated the product definition, product standard requirements, evaluation methods and detection methods. It is required that the production, import and sale of genetically modified products must use the substances in the list of the licensed catalogue that have been evaluated for safety.

When exporting corresponding products to the above-mentioned countries or regions, export enterprises should grasp the requirements of new product regulations in advance and do a good job in product benchmarking.

3.  Label marking

In 2022, in the context of the continued popularity of COVID-19 and the growing attention paid by the people to nutrition and health, the United States, Canada, the European Union, Japan, South Korea, ASEAN and other countries and regions have also done a lot of substantive work in food labeling, and the updated content in allergen labeling, nutrition labeling, especially health claims, deserves attention:

(1) The United States: sesame was included in the list of food allergens, and the mandatory labeling content of this ingredient in the label required a clear implementation date. It is proposed to revise the conditions and labeling requirements of voluntary "health" claims.

(2) Canada: It is clearly required that the main display panels of high-sodium, high-sugar and high-saturated fat foods must be marked with the "magnifying glass" sign, and relevant enterprises should complete the label revision before December 31, 2025;

(3) EU: It is proposed to formulate an unified mandatory pre-packaged nutrition label, nutritional composition analysis and food nutrition claim requirements, mainly involving scientific analysis of excessive intake of saturated fatty acids, sodium and added free sugar, and insufficient intake of dietary fiber and potassium;

(4) Japan: revised the labeling requirements of genetically modified products and  products without food additives, and roughly divided the labeling types of unused additives into 10 categories, including simple "no additives" labeling;

(5) South Korea: revised the consumption period of the product, added the product category to be marked according to"MM/DD/YY" on the label and the daily standard value of some nutrients in the nutrition composition table, such as linolenic acid.

(6) Singapore: Retail prepackaged ready-to-drink beverages were graded (A-D) according to their sugar and fat content, with the lowest content of relevant ingredients in grade A and the highest content in grade D. Beverages rated C and D were required to be labeled with the Nutri-Grade mark, while healthier A and B drinks can be labeled with the Nutri-Grade mark voluntarily.

4.  import and export supervision

In 2022, the United States, the European Union, Australia, New Zealand, South Korea and other mainstream countries and regions carried out a series of legislative work on the verification requirements of foreign suppliers, border control of imported food, national residue monitoring plan list, imported food compliance intervention plan, import declaration document submission and other aspects, mainly including:

(1) The United States: updated the guidelines on the provision of unique enterprise identification code (UFI) in the foreign supplier verification plan (FSVP), and the provision that the ID code "UNK" (unknown) can be temporarily used to replace the DUNS number when applying for imported food was abolished. Products will be refused entry if the food does not complete the FDA-approved UFI code when making the import declaration.

(2) EU: issued a number of amendments related to the management requirements of food import and export, such as the revision of the annotated list of the national residue monitoring plan for animal-derived foods, and stipulated the labeling requirements of the third-country monitoring plan for agricultural and veterinary residues and pollutant residues. In terms of border sampling of imported food, the proportion of temporary sampling of mycotoxins, pesticide residues, etc. has increased. For China，Xanthan gum is involved, and the risk factor is pesticide residues, with a sampling probability of 20%. As the third-country product access list has been updated, China can export fin fish and crustaceans, chicken legs and snails, hoof products (excluding hoof powder), bone and bone products (excluding bone powder), and horn and horn products (excluding horn powder) to the EU.

(3) Australia: The relevant contents of the compliance intervention plan for imported products were adjusted, and the food categories included in the intervention list were expanded. For example, shrimp products, spices including its products, chili powder, and processed garlic (produced in China or South Korea) were included in the compliance intervention plan list. The compliance intervention plan will conduct random inspection of imported products based on the risk level, with the minimum inspection frequency of 10% and the maximum inspection frequency of 100%. The inspection scope will include the production line.

(4) South Korea: It is required that aquatic products or livestock products exported to South Korea must be accompanied by a health certificate issued by the competent authority of the exporting country. Increased the frequency of document inspection of imported products. The imported food declaration form should be accompanied by product photos (except for some product categories such as live, refrigerated and unpackaged aquatic products, agricultural and forestry products, and meat). At the same time, South Korea has strengthened the inspection requirements for aquatic products imported at home and abroad that need to undergo precision inspection.

Summary

According to the summary of the revision of the acts and standards of international foods in 2022 in the countries and regions mentioned above, it can be seen that for the major trading countries and regions there has been no major overhaul of the food safety framework, but many revisions have been made to the specific implementation of product standards, labeling requirements and import and export supervision. The refinement of standards, the increasingly strict content related to "health" in product labels and the frequent revision of requirements in import supervision, such as access restrictions, border sampling and document review, have become the trend of legal revision of international food standards. Therefore, it is of great guiding significance to strengthen the monitoring of the release and update of the international standard law and the data collation and summary, to do a good job in the benchmarking and comparison of the quality and safety requirements of domestic and foreign products, to study and refine the label identification and to control the import and export regulatory requirements in real time, so as to obtain the access qualification of products from overseas countries and regions, and to avoid the entry risk.