Does the detection of unpermitted food additives indicate that the food is not compliant with GB 2760-2014?
GB 2760-2014 National Food Safety Standard-Standards for Usage of Food Additives specifies the permitted food additives, scope of application and maximum use limit in different categories of foods also specifies the residue limit for certain food additives (such as sulfite food additives). If a certain type of food additive is not permitted by GB 2760-2014 to be used in certain foods, it is still possible for the type of food additive to be detected in the foods, considering the ‘carry-over’ principle. Therefore, a detectable food additive that is not permitted to be used does not necessarily mean a failure to meet the standard requirements.
Extended analysis:
Carry-over principle
GB 2760-2014 3.4.1：A food additive may be present in foods as a result of carry-over from the ingredient (including food additives) under the following circumstances:
The presence of a food additive shall be permitted as a result of carry-over from the ingredient (including food additives) under the following circumstances:
A)In accordance with this standard, the food additive is permitted in one of the ingredients of the compound food.
B)The usage of the additive shall not exceed the maximum usage limit as an ingredient in a compound food.
C)The ingredients shall be used under normal production process conditions and the amount of the additive in the food shall not exceed the limit carried over by the ingredients;
D)If an additive is permitted in one food, where that food is subsequently used as an ingredient in another compound food, the presence of the additive in the compound food shall distinctively lower than the general additive limit requirement by directly adding into food.
A substance is not added to certain foods or food ingredients, which is however detected in the finished food products. The substance might come from the foods or food ingredients themselves, or environmental pollution, contamination of raw materials, migration of packaging materials, metabolites produced during the growth of animals and plants, microbial metabolites produced during food processing (such as fermentation). It is necessary to consider all the possibilities of detection of non-allowable food additives and to take control measures accordingly.
Source: NHC Beijing
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