The last article entitled "the US plans to strengthen the control of toxic heavy metal levels in baby food" described the background of the US Food and Drug Administration (FDA) plan to develop more extensive regulatory standards for heavy metal levels. We are basically aware of the relevant work that FDA will carry out in the near future. This time, FoodMate conducted further analysis and research on the actual control requirements of China and the US on the level of toxic heavy metals in baby food. According to the data, we predicted the possible changes of related products in the future trade between China and the US, as well as the areas that trade stakeholders need to pay attention to.

Regulations on heavy metal control in the US

Except for individual products (such as beverages), the US has not formulated the limit standards of toxic heavy metals in general food in specific regulations. FDA mainly defines the action level or maximum recommended limits of pollutants in some foods by issuing industry guidelines. At present, the US control documents on the limit level of heavy metal pollutants in food (see Table 1 for details) mainly involve lead and arsenic in food that infants and children often eat.


In addition, based on the monitoring of apple juice products, risk assessment results and dietary exposure of children, FDA issued "Draft guidance for Industry: action level for arsenic in apple juice" in 2013and proposed the action level of inorganic arsenic in apple juice (10 μg/kg (ppb)).

Regulations on heavy metal control in China

At present, there is a general national food safety standard for the limit of heavy metal pollutants in food in China, which is “National food safety standard, Maximum levels of contaminants in food” (GB 2762-2017). The standard specifies the product range and control indicators for infants and young children, including the limit of lead and arsenic in a variety of special food, the limit of mercury in canned supplementary foods for infants and young children, and the limit of tin in formula food and supplementary foods for infants and young children.

On August 31, 2020, the National Health Commission issued “National food safety standard, Limits of pollutants in food (Exposure Draft)”, which expanded some food categories and adjusted the relevant limits. Including the revision of the limit of lead in infant food and supplementary food; the limit requirements of arsenic, lead, mercury and tin in other infant food are basically unchanged.

Whether it is the current version of the standard or the Exposure Draft, at present, China focuses on the control of lead, arsenic, mercury and tin in baby food.

Levels of toxic heavy metals in infant food in China and the US

Combined with the control requirements of China and the US on heavy metal pollutants in baby food, the requirements of the two countries on the content level of heavy metal pollutants in baby food are sorted out for reference. See table 2 and table 3 for details.



Combined with the data in Table 2 and table 3, taking infant rice cereals and candy in the US as an example, the content level of lead in infant rice cereals has not been set in the US, but arsenic has been set (on the contrary in China). This difference may be due to different dietary patterns in different countries. The limit level of lead in candy in the US is 0.1 ppm, while that in China is 0.5 mg/kg (ppm). In comparison, the requirements of the US are more stringent. In addition, China has systematically formulated the limit levels of lead, arsenic (including inorganic arsenic), mercury and tin in all kinds of baby foods, while the US has no specific requirements.

Summary

In view of the differences in the control level of heavy metal pollutants in baby food between China and the US, FoodMate has three suggestions for reference.

1. FDA's current pollution control on infant rice cereals (arsenic) and candy products (lead) will not change in the short term and should continue to be strictly implemented. If there are export enterprises of infant food and confectionery food that trade with the US, it is necessary for them to continue to meet the current compliance management requirements of the US. However, in the future, whether FDA will include more product categories or more heavy metal categories and specific requirements has not been decided yet, but there is a great possibility. Please pay close attention to the follow-up sharing of FoodMate.

2. Recently, the US FDA has written to its domestic food enterprises to further strengthen the prevention and control of heavy metals. It is suggested that infant food and candy processing and export enterprises with export business to the US should strengthen the troubleshooting and prevention and control of toxic heavy metals such as lead, arsenic, mercury and cadmium in their production process. FoodMate also learned that relevant regulatory agencies and export enterprises in China also received reminders from the US. In any case, advance self-control is a good strategy, whether it is to strengthen internal management measures or to deal with the future policy adjustment of FDA. The implementation of the requirements under the framework of the U.S. Food and Drug Administration Modernization Act should be carried out from beginning to end.

3. China's food pollutant limit standards, especially for formula foods and complementary foods for infants and young children control requirements will be further refined and tightened. Enterprises need to pay more attention to the introduction of the follow-up formal standards, improve the self-control system, and strengthen the management of heavy metal pollutants in product source and process control.

(Special thanks to Mr. Feng of Langfang Customs for his contribution to this article)

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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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