07/04/2022

FOOD LAW - China: Talking about the National Food Security Standard

 

National Food Security Standard (hereinafter referred to as the “National Standard”) is crucial to anyone who works in the food industry. However, many people are not clear about the classification of National Standard, which is important to foreign exporters.



Let’s start with the Food Safety Law, which is the fundamental law of food safety. According to the Food Safety Law, Chapter 3 Food Safety Standards, Article 25: 

Food safety standards shall be standards for mandatory execution. No mandatory food standards other than food safety standards may be developed. 

Article 26. Food safety standards shall contain: 

✔ limits of pathogenic microorganisms, pesticide residues, residues from veterinary medicines, biological toxins, heavy metals, and other pollutants, and other substances hazardous to human health in food, food additives, and food-related products; 

✔ varieties, range of application, and dosages of food additives; 

✔ nutritional composition requirements for staple and supplementary food exclusively for infants and other particular groups of people 

✔ requirements for labels, marks, and instructions related to health, nutrition, and other food safety requirements; 

✔ hygienic requirements for the process of food production or trade; 

✔ quality requirements related to food safety; 

✔ food inspection methods and procedures related to food safety; and 

✔ others which need to be developed into food safety standards. 

Obviously, the upper rank law has provided a clear position and scope for the national standard of food safety, so next step we will explain in detail the specific classification of national standards. 


The first category is common criteria 

Common criteria refer to standards that are widely used and have broad guiding significance as the basis of other standards within a certain range. 

In another word, all food products, no matter what category they belong to, shall comply with the common criteria. 

For example, if there is no corresponding food product standard for a food product imported from abroad, you can find the corresponding common criteria according to the food category of the product and comply with the safety requirements for the food category in the standard. 

In this way, the national standard problem in food import can be solved. There are 13 common criteria  as the list below:


Among the 13 general standards, the following standards are most commonly used:

✓ General standard for the labelling of prepackaged foods GB 7718-2011 
✓ Standard for nutrition labelling of prepackaged foods GB 28050-2011 
✓ Standard for use of food additives GB 2760-2014 
✓ Limits of contaminants in foods GB 2762-2017 
✓ Limit of pathogen in prepackaged foods GB 29921-2021 

Due to space reasons, the content of the standard will not be explained in detail here. Readers can search about the detailed standard and find the explanation by the professional practitioners of food regulation in accordance with specific situation. 

It is hereby noted that clarified that the use of “most” and other superlatives in this article is to impress the readers and not the absolute words. 


The second category is standard of food products 

A total of 70 national standards are formulated for major food categories (important to people's livelihood), such as various dairy products, rice and flour products, meat products, candy products, seasoning products, etc. 

The third category is special dietary food standards, which is used for specific consumer groups such as infant formula and other special food. Relevant national standards shall be abided by. There are 10 standards in total:



The fourth category is quality specifications and relevant standards of food additives 

This category has the most national standards, 646 in total. All the food additives shall abide by this kind of standard, which will not be listed here due to space reasons. 

The fifth category is quality specification and standard of food nutrition fortifier

There are 53 standards in total. All the food nutrition fortifier shall abide by this kind of standard, which will not be listed here due to space reasons. 

The sixth category is food related product standards 

There are 15 standards in total. Food related products refer to food packaging materials, containers, detergents, disinfectants, etc. and there are 3 important standards: 

detergent GB 14930.1-2015 
disinfectants GB 14930.2-2012 
General safety requirements on food contact materials and articles GB 4806.1-2016 

The seventh category is production and operation specifications and standards 

There are 34 standards in total, which shall be abided by during the production and operation of the food. There are two important standards:

General hygienic standard for food production GB 14881-2013 
Code of hygienic practice in food business process GB 31621-2014 

The remaining standards are various test methods, including 234 physical and chemical test methods, 32 microbiological test methods, 29 toxicological test methods and procedures, 120 pesticide residue test methods and 74 veterinary drug residue test methods.

Conclusion 

The above analysis is based on the announcement of the Food Safety Standards Monitoring and Evaluation Department of National Health Commission in February 2022, which is the latest official announcement. It is hoped that the popularization of science will help nonprofessionals of food regulation to have a preliminary understanding of national standards of food safety. 



Leon Zheng 
                                            HFG Law&Intellectual Property