On August 31, 2020, the National Health Commission of the People’s republic of China issued the "National Food Safety Standard--Fermented Milk (Draft for Soliciting Comments)" (hereinafter referred as "Draft for Comments"). Foodmate compares and sorts out the main changes between the draft version and the current version. The revised contents are mainly included in the following aspects:


1. Scope of application

The "Draft for Comments" revised the "whole fat, skimmed and partially skimmed" fermented milk in the scope of application of previous version into "fermented milk and flavored fermented milk", which is in consistency with the classification in the term definition in part 2.

2. Terms and definitions

Currently, there are many kinds of raw milk on the market, not only cow and goat milk, but also other animal milk, such as camel milk, horse milk, buffalo milk, etc. The development of the industry tends to be various. The scope of raw material for fermented milk is revised, the restriction on cattle/sheep as raw milk is deleted, raw milk and/or reconstituted milk are the main raw materials, and it is also in line with "National Food Safety Standard Raw Milk" revised.

At the same time, the definition of reconstituted milk is added. Reconstituted milk is a liquid obtained by mixing dry or concentrated dairy products with water in proportion. The "Draft for Comments" clarified the raw material requirements for fermented milk. Raw milk and reconstituted milk can be used as raw materials alone or together.

Amend the "milk powder" into "reconstituted milk".

3. Sensory requirements

In the testing method for sensory part, "solidified products can be placed in the original packaging" is added, making the inspection process closer to actual operation.

4. Physical and chemical indicators

The "Draft for Comment" revised the acidity from "≥70°T" to "≥60°T". This adjustment is based on this requirement set, fermentation can proceed well and continue to produce lactic acid, and the lactic acid produced can be not only give the unique taste of the product, but also inhibit the growth of harmful microorganisms, and milk protein can also be maintained good coagulation properties.

At the same time, according to the status of standard update, the acidity testing method is revised accordingly to implement in accordance with the latest revised method of fat testing.


5. Microbes limitation

According to the actual testing method, the product needs to be diluted 10 times during the test of the coliform count, the coliform limitation are revised accordingly, the m value of the coliform is changed from 1 CFU/ mL into 10 CFU/mL and the M value changed from 5 CFU/mL into 50 CFU/mL.

The limits of Staphylococcus aureus and Salmonella refer to GB 29921 "National Food Safety Standard Limits of Pathogenic Bacteria in Prepackaged Foods" directly. This draft no longer included relevant indicators for pathogens.

6. Others

For the labeling part, "milk powder" is changed into "reconstituted milk"; the remark for “××%” part is changed into “xx% refers to the mass fraction of milk solids from the reconstituted milk added in total milk solids from the fermented milk”.

In the labeling requirements for reconstituted milk, the "main display panel" is adjusted into "the same display panel", which is consistent with GB 7718 "National Food Safety Standard--General Label Rules for Prepackaged Food ".

7. Conclusion

The deadline for the draft comments of 2020 version is October 20, 2020. Foodmate reminds food companies to submit comments timely and pay close attention to the trends of the standard. At the same time, welcome to log in Foodmate Forum to participate the discussions, Foodmate will summarize the opinions and submit them to the National Food Safety Risk Assessment Center accordingly.

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Business Division of Food Safety and Regulatory Compliance of Global Foodmate provides food standards & regulations research, labelling compliance consulting/Chinese label design, industry public opinion monitoring and analysis, registration services (of Infant formula, FSMP, Health food, Novel Food Ingredients, Novel Food Additives, New Varieties of Food-Related Products and Overseas manufacturers of imported food) and other comprehensive food safety solutions for domestic and overseas enterprises and institutions in food industry. 

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