codex alimentarius commission

FOOD AND AGRICULTURE WORLD HEALTH

ORGANIZATION ORGANIZATION
OF THE UNITED NATIONS
JOINT OFFICE: Via delle Terme di Caracalla 00100 Rome Tel.: 39.06.57051 Telex: 625825-625853 FAO I E-mail Codex@fao.org Facsimile:39.06.5705.4593

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, 12-16 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 11.0. 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 SO2 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 11.2. Sugars described in the Standard for Sugars are not always clearly defined in the
subcategories 11.1 and 11.2. For example, refined products like white sugar are in the same category as co-
products 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) :
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- 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 (11.2-11.6) 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 :
- 11.2 would include brown sugar other than soft brown sugar and raw cane sugar (which are defined in
the Standard for Sugars)
- 11.3 sugar solutions, syrups, molasses excluding glucose syrup
- 11.4 other sugars and syrups (xylose, maple syrup, toppings,)
- 11.5 honey (former subcategory 11.3)
- 11.6 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 11.5. 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).
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ANNEX I

CEFS proposal of new subcategories for the category 11.0

11.0 Sweeteners, including honey

11.1 Products of the Codex Standard for Sugars

11.1.1 White sugar, dextrose anhydrous, dextrose monohydrate, fructose

11.1.2 Powdered sugar, powdered dextrose

11.1.3 Soft white sugar, soft brown sugar, glucose syrup, dried glucose syrup, raw cane sugar

Dried glucose syrup used to manufacture sugar confectionery

11.1.3.1
Glucose syrup used to manufacture sugar confectionery
11.1.3.2
Lactose
11.1.4
Plantation or mill white sugar
11.1.5
Brown sugar excluding products of food category 11.1.3
11.2
Sugar solutions and syrups, also (partially) inverted, including treacle and molasses,
11.3 excluding products of food category 11.1.3

Other sugars and syrups (e.g. xylose, maple syrup, sugar toppings)
11.4
Honey
11.5
Table-top sweeteners, including those containing high-intensity sweeteners
11.6

ANNEX II

Additives permitted in subcategories of category 11.0

Food category 11.1.1 : white sugar, dextrose anhydrous, dextrose monohydrate, fructose

Maximum level comments

Sulphites 15 mg/kg * note 44
Food category 11.1.2 : powdered sugar, powdered dextrose

Sulphites 15 mg/kg * note 44

Phosphates 3300 mg/kg notes 33, 56
Magnesium carbonate 15000 mg/kg note 56
Silicon dioxide (amorphous) 15000 mg/kg note 56
Calcium silicate 15000 mg/kg note 56
Magnesium silicate (synthetic) 15000 mg/kg note 56
Sodium aluminosilicate 15000 mg/kg note 56
Calcium aluminosilicate (synthetic) 15000 mg/kg note 56
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Food category 11.1.3 : soft white sugar, soft brown sugar, glucose syrup, dried glucose syrup, raw cane
sugar

Sulphites 20 mg/kg note 44

Food category 11.1.3.1 : dried glucose used to manufacture sugar confectionery

Sulphites 150 mg/kg note 44

Food category 11.1.3.2 : glucose syrup used to manufacture sugar confectionery

Sulphites 400 mg/kg note 44

Food category 11.1.5 : plantation or mill white sugar

Sulphites 70 mg/kg note 44

Food category 11.2 : brown sugar excluding products of food category 11.1.3

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 11.1.3

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 SO2 is classified among allergens.

Notes :

33 : as phosphorus
44 : as residual SO2
56 : provided starch is not present

ANNEX III

Additives currently permitted in GSFA categories 11.1 and 11.2

Additive INS number Max Level

Acesulfame potassium 950 1.000 mg/kg
Alitame 956 GMP
Allura red AC 129 300 mg/kg
Amaranth 123 300 mg/kg
Annatto extracts 160b GMP
Ascorbyl esters 304, 305 500 mg/kg (10)
Aspartame 951 3.000 mg/kg
Benzoates 210 - 213 1.000 mg/kg (13)
BHA 320 20 mg/kg
BHT 321 20 mg/kg
Brilliant blue FCF 133 100 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
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Dioctyl sodium sulfosuccinate 480 25 mg/kg
Erythrosine 127 300 mg/kg
Hydroxybenzoates, p- 214, 216, 218 100 mg/kg (27)
Indigotine 132 300 mg/kg
Phosphates 338 - 341, 3.300 mg/kg (33, 56)
450 - 452, 542
Polydimethylsiloxane 900a 50 mg/kg
Ponceau 4R 124 200 mg/kg
Propylene glycol alginate 405 5.000 mg/kg
Propylene glycol esters of fatty acids 477 5.000 mg/kg
Riboflavines 101i, ii GMP
Saccharin 954 300 mg/kg
Sorbates 200 - 203 1.000 mg/kg (42)
Sucralose 955 1.500 mg/kg
Sucrose esters of fatty acids 473 5.000 mg/kg
Sulphites 220 - 225, 227, 228, 539 500 mg/kg (44)
Sunset yellow FCF 110 300 mg/kg
Tartrazine 102 300 mg/kg

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 1422 10.000 mg/kg
Acetylated distarch phosphate 1414 10.000 mg/kg
Acid treated starch 1401 10.000 mg/kg
Alginic acid 400 10.000 mg/kg
Alkaline treated starch 1402 10.000 mg/kg
Alpha-amylase (Aspergillus oryzae var.) 1100 GMP
Ammonium alginate 403 10.000 mg/kg
Bleached starch 1403 10.000 mg/kg
Calcium acetate 263 1.500 mg/kg
Calcium alginate 404 10.000 mg/kg
Calcium aluminium silicate (synthetic) 556 15.000 mg/kg (56)
Calcium silicate 552 15.000 mg/kg (56)
Caramel colour class I 150a GMP
Carob bean gum 410 5.000 mg/kg
Carrageenan 407 5.000 mg/kg
Citric and fatty acid esters of glycerol 472c GMP
Distarch phosphate 1412 10.000 mg/kg
Enzyme treated starch 1405 10.000 mg/kg
Gellan gum 418 500 mg/kg
Glycerol 422 GMP
Guar gum 412 10.000 mg/kg
Gum arabic 414 GMP
Hydroxypropyl cellulose 463 GMP
Hydroxypropyl distarch phosphate 1442 10.000 mg/kg
Hydroxypropyl methyl cellulose 464 GMP
Hydroxypropyl starch 1440 10.000 mg/kg
Isomalt 953 GMP
Lactic and fatty acid esters of glycerol 472b GMP
Lecithin 322 GMP
Magnesium carbonate 504i 15.000 mg/kg (56)
Magnesium chloride 511 GMP
Magnesium hydrogen carbonate 504ii GMP
Magnesium hydroxide 528 GMP
Magnesium silicate (synthetic) 553i 15.000 mg/kg (56)
Methyl cellulose 461 GMP
Methyl ethyl cellulose 465 GMP
Microcrystalline cellulose 460i GMP
Mono- and diglycerides 471 6.000 mg/kg
Monostarch phosphate 1410 10.000 mg/kg
Nitrous oxide 942 GMP
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Oxidized starch 1404 10.000 mg/kg
Pectins (amidated and non-amidated) 440 GMP
Phosphated distarch phosphate 1413 10.000 mg/kg
Polydextrose 1200 GMP
Potassium alginate 402 10.000 mg/kg
Potassium dihydrogen citrate 332i GMP
Powdered cellulose 460ii GMP
Salts of myristic, palmitic, stearic acids (NH4, Ca, 470 GMP (71)
K, Na)
Salts of oleic acid (Ca, K, Na) 470 GMP
Silicon dioxide (amorphous) 551 15.000 mg/kg (56)
Sodium alginate 401 10.000 mg/kg
Sodium aluminosilicate 554 15.000 mg/kg (56)
Sodium carboxymethyl cellulose 466 5.000 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 415 5.000 mg/kg
Xylitol 967 GMP

Notes:
10 as ascorbyl stearate 42 as sorbic acid
13 as benzoic acid 44 as residual SO2
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

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 SO2 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 11.2.
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.