codex alimentarius commission

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1 codex alimentarius commission FOOD AND AGRICULTURE WORLD HEALTH ORGANIZATION ORGANIZATION OF THE UNITED NATIONS JOINT OFFICE: Via delle Terme di Caracalla Rome Tel.: Telex: FAO I Codex@fao.org Facsimile: Agenda Item 7c CX/FAC 01/7 February 2001 JOINT FAO/WHO FOOD STANDARDS PROGRAMME CODEX COMMITTEE ON FOOD ADDITIVES AND CONTAMINANTS Thirty-third Session The Hague, The Netherlands, March 2001 COMMENTS SUBMITTED ON THE FOOD CATEGORY SYSTEM OF THE GSFA The following comments have been received from CEFS and WSRO. CEFS General Comments As European sugar manufacturers, we are concerned about the category 11.0 of the Food Category System : Sweeteners, including honey. There are inconsistencies between the provisions for food additives defined in the GSFA and these described in the Codex Standard for Sugars. The inconsistencies are mainly due to the classification of sweeteners in the Food Category System of the GSFA. At its last meeting, CCFAC agreed on one hand that the relationship between food additive provisions in the GSFA and the Codex commodity standards should be clarified (ALINORM 01/12, para. 35), and on another hand that the Food Category System will be circulated for comments (ALINORM 01/12, para. 37). CEFS would like to propose new subcategories for the category Our proposal makes it possible to hold account of the provisions for food additives of the Standard for Sugars and to eliminate the differences between the Standard for Sugars and the GSFA. Food additive provisions in the Codex Standard for Sugars The Standard for Sugars specifies that SO 2 is the only permitted additive in the sugars described in the Standard, i.e. white sugar, plantation or mill white sugar, powdered sugar, soft white sugar, soft brown sugar, dextrose anhydrous and monohydrate, powdered dextrose, glucose syrup, dried glucose syrup, fructose and raw cane sugar. However, the use of several anticaking agents is allowed in powdered sugar and powdered dextrose at a maximum level of 1.5 % singly or in combination provided that starch is not present. Comments on the current Food Category System In the current category 11.0 of the Food Category System, sugar products are classed into two subcategories : 11.1 and Sugars described in the Standard for Sugars are not always clearly defined in the subcategories 11.1 and For example, refined products like white sugar are in the same category as coproducts like treacles and molasses and more complex products like toppings. Consequently, products which need the addition of some additives are in the same category as products in which the use of these additives is not technologically justified. Proposal of amendments to the Food Category System Having taken all these facts into account, CEFS would like to propose amendments to the category 11.0 (detailed in annex I) :

2 2 - Creation of a new subcategory 11.1 which would include products defined in the Codex Standard for Sugars, classified in function of their need in additives (owing to the maximum levels permitted in the Standard for Sugars) The other new subcategories ( ) would comprise all other products originally present in the category 11.0, also listed owing to their need in additives as specified in the European legislation or in GSFA : would include brown sugar other than soft brown sugar and raw cane sugar (which are defined in the Standard for Sugars) sugar solutions, syrups, molasses excluding glucose syrup other sugars and syrups (xylose, maple syrup, toppings, ) honey (former subcategory 11.3) table-top sweeteners (former subcategory 11.4) Consequences of the proposed amendments to the Food Category System on table 1 and 2 of the GSFA The proposed amendments to the category 11.0 would result in small revisions in table 1 and 2 of the GSFA (see in annex II). The additive provisions for the new subcategory 11.1 would correspond with the provisions foreseen in the Codex Standard for Sugars. The only needed additives in the new subcategory 11.2 and 11.3 are sulphites. The proposed maximum levels are those laid down in the European Directive 95/2/EC. Food additive provisions for the new subcategory 11.4 would be provisions foreseen for the current subcategories 11.1 and 11.2 (detailed in annex III). In this way, CEFS proposal allows to eliminate discrepancies between provisions for food additives in the Codex Standard for Sugars and in the GSFA. Annex to Table 3 of the GSFA Regarding the annex of table 3 listing the food categories or individual food items where the use of food additives with GMP limitations on use are not allowed or restricted, we propose to include the new subcategories 11.1, 11.2, 11.3 and Additives of table 3 could then only be used, in accordance with GMP, in the category 11.4 (other sugars and syrups). All the additives for which the use is allowed in accordance with GMP could then be deleted from table 1 and table 2 of the GSFA (see annex III).

3 3 ANNEX I CEFS proposal of new subcategories for the category Sweeteners, including honey 11.1 Products of the Codex Standard for Sugars White sugar, dextrose anhydrous, dextrose monohydrate, fructose Powdered sugar, powdered dextrose Soft white sugar, soft brown sugar, glucose syrup, dried glucose syrup, raw cane sugar Dried glucose syrup used to manufacture sugar confectionery Glucose syrup used to manufacture sugar confectionery Lactose Plantation or mill white sugar Brown sugar excluding products of food category Sugar solutions and syrups, also (partially) inverted, including treacle and molasses, excluding products of food category Other sugars and syrups (e.g. xylose, maple syrup, sugar toppings) Honey Table-top sweeteners, including those containing high-intensity sweeteners ANNEX II Additives permitted in subcategories of category 11.0 Food category : white sugar, dextrose anhydrous, dextrose monohydrate, fructose Maximum level comments Sulphites 15 mg/kg * note 44 Food category : powdered sugar, powdered dextrose Sulphites 15 mg/kg * note 44 Phosphates 3300 mg/kg notes 33, 56 Magnesium carbonate mg/kg note 56 Silicon dioxide (amorphous) mg/kg note 56 Calcium silicate mg/kg note 56 Magnesium silicate (synthetic) mg/kg note 56 Sodium aluminosilicate mg/kg note 56 Calcium aluminosilicate (synthetic) mg/kg note 56

4 4 Food category : soft white sugar, soft brown sugar, glucose syrup, dried glucose syrup, raw cane sugar Sulphites 20 mg/kg note 44 Food category : dried glucose used to manufacture sugar confectionery Sulphites 150 mg/kg note 44 Food category : glucose syrup used to manufacture sugar confectionery Sulphites 400 mg/kg note 44 Food category : plantation or mill white sugar Sulphites 70 mg/kg note 44 Food category 11.2 : brown sugar excluding products of food category Sulphites 40 mg/kg note 44 Food category 11.3 : sugar solutions and syrups, also (partially) inverted, including treacle and molasses, excluding products of food category Sulphites 70 mg/kg note 44 Food category 11.4 : other sugars and syrups (e.g. xylose, maple syrup, sugar toppings) Additives comprise those listed in the current categories 11.1 and 11.2 (see in annex III) * a reduction from 15 mg/kg to 10 mg/kg for white sugar products is already asked at Codex level. Such a reduction has already been adopted in the EU Directive on Miscellaneous Additives (98/72/EC). Moreover, in concentration above 10 ppm SO 2 is classified among allergens. Notes : 33 : as phosphorus 44 : as residual SO2 56 : provided starch is not present Additives currently permitted in GSFA categories 11.1 and 11.2 ANNEX III Additive INS number Max Level Acesulfame potassium mg/kg Alitame 956 GMP Allura red AC mg/kg Amaranth mg/kg Annatto extracts 160b GMP Ascorbyl esters 304, mg/kg (10) Aspartame mg/kg Benzoates mg/kg (13) BHA mg/kg BHT mg/kg Brilliant blue FCF mg/kg Canthaxanthin 161g GMP Caramel colour class III 150c GMP Caramel colour class IV 150d GMP Carotenoids 160ai, 160e, 160f 35 mg/kg Chlorophylls, copper complexes 141i, 141ii 64 mg/kg (62) Cyclamates 952 GMP (17) Diacetyltartaric and fatty acid esters of glycerol 472e GMP

5 Dioctyl sodium sulfosuccinate mg/kg Erythrosine mg/kg Hydroxybenzoates, p- 214, 216, mg/kg (27) Indigotine mg/kg Phosphates , mg/kg (33, 56) , 542 Polydimethylsiloxane 900a 50 mg/kg Ponceau 4R mg/kg Propylene glycol alginate mg/kg Propylene glycol esters of fatty acids mg/kg Riboflavines 101i, ii GMP Saccharin mg/kg Sorbates mg/kg (42) Sucralose mg/kg Sucrose esters of fatty acids mg/kg Sulphites , 227, 228, mg/kg (44) Sunset yellow FCF mg/kg Tartrazine mg/kg 5 The following additives are also listed in the Annex of Table 3. The provisions could be deleted in Table 1 and 2 if the new subcategory 11.4 is not listed in the Annex of Table 3. Acetic and fatty acid esters of glycerol 472a GMP Acetylated distarch adipate mg/kg Acetylated distarch phosphate mg/kg Acid treated starch mg/kg Alginic acid mg/kg Alkaline treated starch mg/kg Alpha-amylase (Aspergillus oryzae var.) 1100 GMP Ammonium alginate mg/kg Bleached starch mg/kg Calcium acetate mg/kg Calcium alginate mg/kg Calcium aluminium silicate (synthetic) mg/kg (56) Calcium silicate mg/kg (56) Caramel colour class I 150a GMP Carob bean gum mg/kg Carrageenan mg/kg Citric and fatty acid esters of glycerol 472c GMP Distarch phosphate mg/kg Enzyme treated starch mg/kg Gellan gum mg/kg Glycerol 422 GMP Guar gum mg/kg Gum arabic 414 GMP Hydroxypropyl cellulose 463 GMP Hydroxypropyl distarch phosphate mg/kg Hydroxypropyl methyl cellulose 464 GMP Hydroxypropyl starch mg/kg Isomalt 953 GMP Lactic and fatty acid esters of glycerol 472b GMP Lecithin 322 GMP Magnesium carbonate 504i mg/kg (56) Magnesium chloride 511 GMP Magnesium hydrogen carbonate 504ii GMP Magnesium hydroxide 528 GMP Magnesium silicate (synthetic) 553i mg/kg (56) Methyl cellulose 461 GMP Methyl ethyl cellulose 465 GMP Microcrystalline cellulose 460i GMP Mono- and diglycerides mg/kg Monostarch phosphate mg/kg Nitrous oxide 942 GMP

6 Oxidized starch mg/kg Pectins (amidated and non-amidated) 440 GMP Phosphated distarch phosphate mg/kg Polydextrose 1200 GMP Potassium alginate mg/kg Potassium dihydrogen citrate 332i GMP Powdered cellulose 460ii GMP Salts of myristic, palmitic, stearic acids (NH 4, Ca, 470 GMP (71) K, Na) Salts of oleic acid (Ca, K, Na) 470 GMP Silicon dioxide (amorphous) mg/kg (56) Sodium alginate mg/kg Sodium aluminosilicate mg/kg (56) Sodium carboxymethyl cellulose mg/kg Sodium dihydrogen citrate 331i GMP Sorbitol (including sorbitol syrup) 420 GMP Tara gum 417 GMP Tartaric, acetic & fatty acid esters of glycerol 472f GMP Tragacanth gum 413 GMP Tripotassium citrate 332ii GMP Trisodium citrate 331iii GMP Xanthan gum mg/kg Xylitol 967 GMP Notes: 10 as ascorbyl stearate 42 as sorbic acid 13 as benzoic acid 44 as residual SO 2 17 as cyclamic acid 56 provided starch is not present 27 as p-hydroxybenzoic 62 as copper acid 33 as phosphorus 71 Ca, K, and Na salts only 6 WSRO The World Sugar Research Organisation (WSRO) is concerned about the lack of precision in the definition of categories and subcategories especially the discrepancies between the provisions for food additives described in the Codex Standard for Sugars (CSS) and those defined in the General Standard for Food Additives, category 11.0: Sweeteners, including honey. The Standard for Sugars (CSS) which is currently final at Step 8 regulates food additives like SO 2 as well as anticaking agents as the only permitted additives in the sugars defined in the Standard. In category 11.0 of the Food Category System of the GSFA, sugar products are classified into two subcategories 11.1 and Unlike the sugars standard, the GSFA places refined products like white sugar are in the same category as co-products like treacles, molasses and more complex products like toppings. That means, products in which the use of special additives is not technologically justified, are in the same category as products which need the addition of these additives. While refined sugar, plantation white sugar or mill white sugar may contain sulphurdioxide, this may not be true for some of the other products. The inconsistencies are mainly due to the classification of sweeteners in the Food Category System of the GSFA. WSRO therefore urges the Codex Secretary to revise the Category 11.0 for example by adding or creating new subcategories especially for white sugar so that the additive provisions of the GSFA correspond with the provisions foreseen in the Codex Standards for Sugars.