Report of the U.S. Delegate, 46th Session, Codex Committee on Food Additives
The 46th Codex Committee on Food Additives (CCFA) met in Hong Kong, SAR, Beijing, Peoples Republic of China, March 17-21, 2014. The meeting was chaired by Dr. Junshi Chen and attended by 50 member countries, one member organization (EU), 33 observers from international nongovernmental organizations, and the UN Food and Agriculture Organization (FAO) and World Health Organization (WHO).
The U.S. Government participation in the meeting included: Dr. Susan Carberry (Head of Delegation), Dr. Paul Honigfort (Alternate Delegate), Dr. Daniel Folmer (technical expert), Ms. Barbara McNiff (U.S. Codex Office), and Ms. Mari Kirrane (Alcohol and Tobacco Tax and Trade).
The highlights of the decisions made by the Committee are outlined below.
Matters Referred by the Codex Alimentarius Commission (CAC) and Other Committees or Task Forces
The Committee noted that decisions from the Codex Committee on Fish and Fishery Products (CCFFP) would be considered under the agenda item on the endorsement of food additive provisions in Codex commodity standards.
The Committee noted the response from the Committee on Nutrition and Food for Special Dietary Uses (CCNFSDU) that Note 55 (“Singly or in combination, within the limits for sodium, calcium, and potassium specified in the commodity standard.”) of the General Standard for Food Additives (GSFA) should be applied to all relevant provisions in food categories 13.1.1 (Infant formulae) and 13.1.3 (Formulae for special medical purposes for infants), both with numerical maximum use levels and at GMP.
The Committee addressed several inconsistencies in the GSFA that were pointed out by the Codex Secretariat:
- The Committee agreed to revise the text of a number of notes in the GSFA to improve clarity and harmonize the language of notes that express the same concept. The revised notes were forwarded to the CAC for adoption.
- The Committee agreed to revise the text associated with food category 12.2.1 (Herbs and spices) in the Annex to Table 3 of the GSFA to align it with the text associated with food category 01.1.1 (Milk and buttermilk) in the Annex to Table 3 of the GSFA.
- The Committee agreed to include in Table 3 of the GSFA the provisions for cyclotetraglucose (INS 1504(i)) and cyclotetraglucose syrup (INS 1504(ii)) for circulation at Step 3 and consideration at the next session.
- The Committee agreed to forward the provision for potassium hydrogen sulfate (INS 515(ii)) in Table 3 of the GSFA to the CAC for adoption at Step 5/8.
- The Committee discussed the provision for benzoates in food category 14.1.4 (Water-based flavoured drinks, including “sport,” “energy,” or “electrolyte” drinks and particulated drinks), which has Note 301 (“Interim maximum level.”) associated with it. The Committee could not reach consensus on the removal of Note 301, and agreed to request Joint Expert Committee for Food Additives to perform an exposure assessment for the use of benzoates in this food category.
- The Committee agreed to forward to the CAC for adoption the revised provisions for sodium aluminum silicate (INS 554) and calcium aluminum silicate (INS 556) in certain commodity standards (CODEX STAN 207-1999, 251-2006, and 290-1995) that had been inadvertently omitted in the report of the 45th CCFA.
- The Committee agreed to request JECFA to revise the specifications monograph for potassium acetate to list INS (261(i)), and to clarify whether the group ADI for potassium acetates also includes potassium diacetate.
- The Committee agreed to request that the CAC revoke the provision for brilliant blue FCF (INS 133) in food category 09.2.5 (Smoked, dried, fermented and/or salted fish and fish products, including mollusks, crustaceans, and echinoderms).
A pre-session physical working group (pWG) considered the discussion paper on Note 161 (“Subject to national legislation of the importing country aimed, in particular, at consistency with Section 3.2 of the Preamble.”), which was tasked with exploring the use of alternatives note(s) or approaches that could address the concerns that resulted in the application of Note 161. There was a strong consensus among the pWG participants to remove Note 161 from the GSFA and that the use of sweeteners was justified in energy reduced foods and foods with no added sugar. However, there was no consensus on the use of sweeteners in foods that do not meet the definition of “energy reduced” or “no added sugar.” The pWG considered the four options that the electronic working group (eWG) had proposed and forwarded a recommendation to the Committee that the Committee consider forming a new eWG to request information on the effect of the application of Option 3, (“For use only in energy-reduced food or food with no added sugars as defined CAC/GL 23-1997.”) The eWg could utilize this information to determine if the application of this note on a general basis for sweeteners in specific food categories was appropriate or if alternative notes would need to be developed.
Similar to the pWG, there was also general support in the Committee to advance work on finding a replacement for Note 161 and to establish a new eWG, although there was no consensus on whether the eWG should base its work on the replacement note in Option 3 or both in Option 1 (“To replace sugar wholly or partly, or in products where no sugar is added during manufacture.”) and Option 3. After an extensive debate, the Chair, CCFA, noted that, although Option 3 was specified in the recommendation of the pWG, it did not imply that only Option 3 would be applied to address the concerns regarding Note 161. The Chair, CCFA, noted that the eWG was to explore and assess the consequences and impact of Option 3, and that, if the application of Option 3 had severe impact, the Committee would continue to explore other alternative notes. He also noted that there was nothing that precluded eWG members from suggesting other options if they believed Option 3 was not feasible. All Members and Observers were encouraged to actively participate in and provide information to the eWG. The eWG was re-established, led by the UK, and assisted by the United States, to request the information on the replacement note “For use only in energy-reduced food or food with no added sugars as defined in CAC/GL 23-1997” to provisions for sweeteners in FA/45 CRD 2, Appendix VIII. The eWG will use this information to determine if the application of this note on a general basis is appropriate, or if alternate notes can be developed to address concerns for the provisions of sweeteners in specific food categories when the replacement note is not appropriate.
Matters of Interest from the 77th Meeting of Joint Expert Committee of Food Additives (JECFA)
The Committee was informed of the recommendations of the 77th JECFA regarding the food additives that were evaluated. Most recommendations required no action by the Committee. However, the Committee noted that:
- Glucoamulase from Trichoderma reesei expressed in Trichoderma reesei should be included in the database on processing aids.
- Note 28 of the GSFA, which contains the ADI conversion for nisin, should be deleted from the GSFA, as it is no longer necessary in view of the new ADI established by JECFA.
Endorsement and/or Revision of Maximum Levels for Food Additives and Processing Aids in Codex Standards
The Committee endorsed the food additive provisions forwarded by the CCFFP in the Draft Standard for Fresh and Quick Frozen Raw Scallop Products; and in the Standards for Quick Frozen Shrimps or Prawns (CODEX STAN 92-1981); for Quick Frozen Lobsters (CODEX STAN 95-1981); for Quick Frozen Blocks of Fish, Fish Fillets, Minced Fish Flesh and Mixtures of Fillets and Minced Fish Flesh (CODEX STAN 156-1989); for Quick Frozen Fish Sticks (Fish Fingers), Fish Portions and Fish Fillets – Breaded or in Batter (CODEX STAN 166-1989); and the General Standard for Quick Frozen Fish Fillets (CODEX STAN 190-1995).
Alignment of the Food Additive Provisions of Commodity Standards and Relevant Provisions of the GSFA
The Committee considered the document prepared by the electronic Working Group (eWG), led by Australia. It noted the revisions made to the decision tree for alignment of commodity standards with the GSFA, and principles, and appended the revised decision tree to the Meeting Report for reference for its future work on alignment. The Committee agreed to forward to the CAC the following for adoption:
- Revised sections of the Standards for Luncheon Meat (CODEX STAN 89-1981); for Corned Beef (CODEX STAN 88-1981); for Cooked Cured Ham (CODEX STAN 96-1981); for Cooked Pork Shoulder (CODEX STAN 97-1981); and for Cooked Cured Chopped Meat (CODEX STAN 99-1981).
- Revised food additive provisions of the GSFA relevant to these commodity standards.
The Committee also agreed to re-establish an eWG, led by Australia, to:
- Consider the application of the decision tree to the Standard for Bouillons and Consommés, and to the standards for chocolate and cocoa products.
- Consider the provisions in the GSFA that, according to the Committee on Processed Fruits and Vegetables (CCPFV) are not technologically justified in the food categories covered by the standards for Certain Canned Citrus (CODEX STAN 254-2007); for Preserved Tomatoes (CODEX STAN 13-1981); and for Processed Tomato Concentrates (CODEX STAN 57-1981).
- Develop a draft list of prioritized commodity standards for application of the decision tree approach to guide future work on the alignment.
The Chairperson noted that the work on alignment was a complex task and that the completion of the work on the five meat standards was an important accomplishment for the Committee that will facilitate work on the alignment of other commodity standards with the GSFA, and will contribute to making the GSFA the single authoritative reference point for food additives in Codex.
Revision of the Guidelines for the Simple Evaluation of Food Additive Intake (CAC/GL 3-1989) (N08-2013)
Brazil, as lead country of the eWG, provided a summary of the work of the eWG, and noted that a revised proposal had been prepared that included revisions suggested in written comments (FA 46/CRD 10). The Committee noted that the Guidelines were developed as a tool for the simple evaluation of dietary exposure at the national level, and was not in conflict with the Working Principles for Risk Analysis for Application in the Framework of the Codex Alimentarius. The Committee discussed the Guidelines as contained in FA 46/CRD 10, and agreed that the document should be forwarded to the CAC for adoption at Step 5/8.
Information on Commercial Use of Selected Food Additives (Replies to CL 2013/8-FA, Part B, Point 4)
The Committee noted that in reply to the Circular Letter requesting information on the commercial use of 16 food additives listed in the GSFA and for which there are no corresponding JECFA specifications, information had been provided for 9 substances. The Committee agreed to include these substances in the JECFA Priority List with the understanding that commitment for submission of full dossiers for JECFA evaluation would be provided by the next session. The Committee also agreed to remove from the GSFA the 7 substances for which information on their commercial use was not provided.
The Committee discussed:
- recommendations for provisions in Tables 1 and 2 for food additives listed in Table 3 with “emulsifier, stabilizer, thickener” function (CX/FA 14/46/8);
- recommendations for provisions (i) in Tables 1 and 2 of Table 3 food additives with “acidity regulator” function for use other than as acidity regulators; and (ii) for other Table 3 food additives with functions other than “emulsifier, stabilizer, thickener,” “colour,” or “sweetener” function (CX/FA 14/46/9);
- recommendations for food additive provisions of food category 14.2.3 (Grape wines) and its sub-categories (CX/FA 14/46/10);
- proposals for revision of the descriptors and food additive provisions of food category 01.1.1 (Milk and buttermilk (plain)) and its sub-categories, and food category 01.1.2 (Dairy-based drinks, flavoured and/or fermented (e.g., chocolate milk, cocoa, eggnog, drinking yoghurt, whey-based drinks) (CX/FA 14/46/11);
- recommendations for the entry of new provisions, including those for food category 16.0 (Prepared foods) and for revision of existing food additive provisions (replies to CL 2012/5-FA, Part B, Points 9 and 10) (CX/FA 14/46/12);
- proposals for provisions for nisin (INS 234) in food category 08.0 (Meat and meat products, including poultry and game) and its sub-categories (replies to CL 2012-5/FA, Part B, Point 8) (CX/FA 14/46/13);
- discussion paper on the use of Note 161 in provisions for selected sweeteners (CX/FA 14/46/14); and
- proposals for new and/or revised food additive provisions (replies to CL 2013/8-FA, Part B, Point 5) (CX/FA 14/46/15)
The Committee forwarded 550 food additive provisions for adoption at Step 8 or 5/8 by the CAC, and discontinued work on 159 draft and proposed draft provisions. For the first time, there are more adopted (Step 8) provisions in the GSFA than draft and proposed draft provisions.
The physical Working Group (pWG) on the GSFA, chaired by the United States, made recommendations on items (a), (b), (c) and (e), listed above.
The pWG further developed the Working Principles for the consideration of Table 3 additives with “emulsifier, stabilizer, thickener” function (FA 46/CRD 2, Appendix I) and the Determination of Technological Justification for the Use of Emulsifiers, Stabilizers, and Thickeners in Food Categories Contained in the Annex to Table 3 (FA 46/CRD 2, Appendix II) in order to assure a uniform procedure and assist in the discussion at the present session. The Committee endorsed the recommendations of the pWG regarding the adoption at Step 8 or 5/8 of certain draft and proposed draft provisions for Table 3 food additives with “emulsifier, stabilizer, thickener” function, and regarding the discontinuation of work on other draft and proposed draft provisions for Table 3 food additives with “emulsifier, stabilizer, thickener” function.
The Committee endorsed the recommendations of the pWG regarding the adoption at Step 8 or 5/8 of certain draft and proposed draft provisions for Table 3 food additives with “acidity regulator” function for use other than as acidity regulators, and for other Table 3 food additives with functions other than “emulsifier, stabilizer, thickener,” “colour,” or “sweetener” function, and regarding discontinuation of work on other draft and proposed draft provisions for these Table 3 additives.
The Committee endorsed the recommendations of the pWG regarding the GSFA provisions in food category 14.2.3 (Grape wines) and its sub-categories. The Committee agreed to re-establish an eWG, led by France, to collect information on the actual use levels of the food additives listed in FA 46/CRD 2, Appendix VI, and including sodium carboxymethyl cellulose (INS 466) and prepare recommendations on a case-by-case basis.
The Committee considered the discussion paper on the inconsistencies in the descriptors for food categories 01.1.1 (Milk and buttermilk (plain)) and its sub-categories, and food category 01.1.2 (Dairy-based drinks, flavoured and/or fermented (e.g., chocolate milk, cocoa, eggnog, drinking yoghurt, whey-based drinks) that was prepared by the eWG led by New Zealand. The Committee agreed that the food additive category descriptors needed to be revised to address the identified inconsistencies. Therefore, the Committee agreed to re-establish an eWG, led by New Zealand, to: (i) further revise the structure of food category 01.1 (Milk and dairy-based drinks) and its sub-categories to resolve the issues identified regarding the placement of certain dairy products; and (ii) prepare a project document for new work that would also include an analysis of the implication of the proposed revision on the current provisions in the GSFA.
The Committee discussed the procedures for the entry of new and revised provisions in the GSFA, noting that it had not strictly adhered to the Procedure for Consideration of the Entry and Review of Food Additives. It was proposed that, in the future, the CL requesting new and revised provisions for the GSFA would include a form for submission of proposals that would clearly identify the criteria for initiation of work, as outlined in the Procedure. The Committee took decisions on the new and revised provisions in CX/FA 14/46/12, as outlined in REP 14/FA. The Committee also agreed not to consider proposals for new and/or revised food additive provisions submitted in CX/FA 14/46/15, and to request Members and Observers to resubmit their proposals in reply to the next CL, which would include the form.
The Committee agreed, with respect to the provisions in the GSFA for nisin: (i) not to include the provision in food category 08.0 (Meat and meat products, including poultry and game), as this had been discontinued at the 44th session; and (ii) to include in the GSFA at Step 3 the provisions for nisin in food categories 08.2.2 (Heat treated processed meat, poultry and game products in whole pieces or cuts), 08.3.2 (Heat treated processed comminuted meat, poultry and game products), and 08.4 (Edible casings (e.g., sausage casings) to be circulated for comment at a later date.
The Committee agreed to establish a GSFA eWG, led by the United States, to prepare proposals for: (i) provisions in Tables 1 and 2 of the GSFA for Table 3 food additives with “emulsifier, stabilizer, thickener” function, for their use for technological function other than as emulsifiers, stabilizers, or thickeners; and (ii) consideration of the provisions in Tables 1 and 2 in food categories 01.2 through 08.4, with the exclusion of food categories 04.1.2.4, 04.2.2.4, 04.2.2.5, 04.2.2.6, 05.1.1, 05.1.3, and 05.1.4, for those food additives without “colour” or “sweetener” function.
The Committee also agreed to establish a physical working group (pWG) on the GSFA that would meet immediately prior to the 47th session, chaired by the United States, to consider and prepare recommendations for the plenary on: (i) outstanding provisions related to CX/FA 14/46/9; (ii) the reports of the eWGs on the GSFA, on food category 14.2.3 (Grape wines), on the revision of food category 01.1 (Milk and dairy-based drinks), and on Note 161; and (iii) new proposals for the entry or revision of food additive provisions into the GSFA (replies to the Circular Letter).
Discussion Paper on the Use of Additives in Additives (Secondary Additives)
The Committee considered the discussion paper, prepared by the EU, on secondary additives. The Committee recognized that the issue of addressing and consistently managing secondary additives was important. However, there were differing views on how to proceed. Some delegations noted that CCFA’s resources should be devoted to reducing the backlog of provisions for inclusion in the GSFA; that there were no safety concerns related to the use of secondary additives; and that the existing mechanisms within JECFA and CCFA were adequate to address these issues. The Committee agreed to establish an electronic working group, led by the EU, to further develop the discussion paper, and in particular to: (i) develop a definition for secondary food additives; (ii) analyze the issue of secondary food additives, including potential inconsistencies in their current handling by CCFA; and (iii) make recommendations, if appropriate, to the 47th CCFA on possible ways to address the issue of secondary food additives.
Discussion Paper on Options for the Use of Outcomes of the Prioritization Exercise and Other Feasible Steps to Identify Compounds for Re-evaluation by JECFA
The Committee considered the discussion paper, prepared by the electronic working group led by Canada. Some delegations expressed concern that a re-evaluation process would require too much of JECFA’s resources, while others noted that old evaluations were based on data that do not comply with current scientific quality standards. The JECFA Secretariat proposed allocating a limited portion of JECFA meetings on food additives to the re-evaluation of substances, as prioritized by CCFA. The Committee supported this proposal, and decided to use the prioritized list of colors as a working example. The Committee agreed that the Codex Secretariat would issue a Circular Letter requesting information on the data availability to re-evaluate the first 6 colors, and, based on the responses, the physical working group on JECFA Priorities at the 47th CCFA would provide JECFA with a final list of substances for re-evaluation.
Other Agenda Items
The Committee also considered amendments to the International Numbering System (INS) for food additives; specifications from the 77th JECFA; and the priority list of additives for JECFA review.
The Observer from the International Organization of the Flavor Industry (IOFI) presented, in FA 46/CRD 13, the inconsistencies of terms related to flavorings among various standards on labelling and the Guidelines for the Use of Flavourings (CAC/GL 66-2008). The Committee supported further work to address this issue, and agreed to request that the United States prepare a discussion paper analyzing and making recommendations to address this issue.
The next Session of the CCFA is tentatively scheduled for March 23 – 27, 2015 in the Peoples Republic of China.