Food Additives in China: Regulations and Practical Cases

Specifically, these guidelines cover the principles for the application of food additives in mainland China, as regulated by GB 2760-2014 National Food Safety Standard for Uses of Food Additives and its appendixes:

• Chapter 2 focuses on the definitions and explanations of food additives as well as the types of additives included in the definition. In general, all food additives used in China shall comply with the basic principles that (i) they are technically necessary and proven to be safe, and (ii) they are registered and approved by the Chinese authorities. Practical tips on how to read through the numerous lists of permitted or restricted additives, flavouring substances and food processing aids are provided, aided by concrete examples.
  
• If a certain substance is not included in any of the lists of GB 2760 – or subsequent approval announcements of the National Health Commission (NHC) – then it must first be registered with the NHC to be allowed to be used in foods in China. However, confusion may arise between new food additives and new food raw materials: Chapter 3 will illustrate the definitions and use of both so to guide manufacturers through the application procedure.
  
• Chapter 4 summarises the labelling requirements for food additives to be sold in China, distinguishing between food additives imported into China as final products, and final food products containing food additives.

It is important to note that these guidelines are based on the current version of GB 2760-2014 in force. However, the standard is currently under revision. Chapter 5 introduces the expected changes based on the preliminary drafts of the revised standard issued in 2021 and 2022, in particular with regard to the application of nutrition fortification substances, as well as the structural changes applied to the tables included in the standard’s appendixes.

Finally, the last chapter provides a list of frequently asked questions that the EU SME Centre has received in the past year from EU SMEs. These mostly involve the applicability of GACC’s 2021 Decree 248 to producers of food additives or natural ingredients exported to China. This chapter also introduces useful tools that can be used by EU SMEs to easily identify permitted food additives and relevant food safety standards.

Note: the screenshots displaying tables and examples are mostly taken from unofficial English translations of Chinese standards published by the Foreign Agricultural Service of the US Department of Agriculture (USDA). The full translations can be accessed from the relevant links in the footnotes.

Contents

Executive summary
1. Legal framework
2. Definitions, principles and provisions for use 
2.1. Food additives usage provisions (GB 2760 Appendix A)
2.2. Flavouring substances (GB 2760 Appendix B)
2.3. Food processing aids (GB 2760 Appendix C)
3. New food additives and new raw materials
4. Labelling requirements
5. New changes ahead: revision of GB 2760
6. Q&A and tips