How to check whether the food ingredients are compliant with Chinese regulations ?

Original Article by Ms. Cathy Yu, CIRS

For imported foods, compliance with regulations in China is very important. Some ingredients can be used in common foods in original countries, but some are not allowed to be added into food in China. Therefore, CIRS has prepared a guidance document to help food trading companies to check whether the ingredients can be used in specific products or not.

Step 1: Check all ingredients distinguish food raw materials and food additives.

Step 2: Check whether all food raw materials are compliant with Chinese food regulations and official documents in one of the 7 checkpoints:

  • Check whether the food material is on the list of approved new food raw materials and confirm if it can be used in the specific food or not according to the list.
  • Search whether the food material has its own Chinese National Standard.
  • Check if the food material appears on the list of substances considered as food or drugs.
  • Check all Notices related to approved food materials by NHFPC.
  • If the food material is a probiotic, check whether it is on the list of approved bacterial culture in food.
  • If the food material has over 30 years of safe use history in specific province, you can apply for the evidence to the local HFPC .
  • Review the National Standard of the product to make sure that the food material can be used in the product or is forbidden in it.

Please note, If the food raw materials not meet the above criteria, they shall undergo New Food Material Registration to NHFPC.


Step 3: Check whether all food additives are compliant with National Standards and Notices.

There are 3 checkpoints to help you to chek the compliance of a food additive:

  • Check the scope and dosage of the food additive according to GB 2760-2011 Standards for Uses of Food Additives.
  • Check the scope, dosage and source of the nutritional enhancer according to GB 14880-2012 Standard for Uses of Nutritional Fortification Substances in Foods.
  • Check whether the food additive (including nutritional enhancer) is on the list of approved new food additive according to the Notices by NHFPC.

If the use of food additive fail to meet all above 3 criteria, the formula shall be modified or the food additive shall be registered to NHFPC as New Variety of Food Additive.

CIRS recommends that before exporting foods into China, food companies shall review the formula based on the above 10 criteria to confirm all the food ingredients are compliant with regulations in China. If you are interested in launching a food product in China or would like to discuss these topics please do not hesitate to contact us.

Download:

GB 2760-2011 Standards for Uses of Food Additives (CN version free download)

GB 14880-2012 Standard for Uses of Nutritional Fortification Substances in Foods (CN version free download)


Contact Us

Ms. Cathy Yu, Senior Consultant, Food Safety Regulation, CIRS China
11F Dongguan Building, 288 Qiuyi Road, Binjiang District, Hangzhou, China, 310020
Tel : +86 571 8720 6538 | Fax : +86 571 8720 6533
Email: cathy.yu@cirs-group.com

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