Forthcoming 51st meeting of the Codex Alimentarius Committee on Food Additives (25-29 March 2019, Jinan, People's Republic of China)

Date: Mar 20, 2019

This article originally appeared in World Food Regulation Review, Vol. 28, Number 9, February 2019.

This article aims to present and explain the main topics on the agenda of the forthcoming 51st session of the Codex Alimentarius Committee on Food Additives, taking place in Jinan from 25 to 29 March 2019.

In next month’s WFRR issue (March), a similar article will summarize the main decisions resulting from CCFA51.


The forthcoming 51st meeting of the Codex Alimentarius Committee on Food Additives (CCFA51) is expected to finalize most of the backlog on food additives, other than sweeteners and colours. For the first time since 2011, CCFA51 will also address pending drafts for provisions for the remaining colours in three food subcategories belonging to Confectionery for possible adoption in the Codex General Standard on Food Additives (GSFA). CCFA51 will also discuss important matters relating to nitrites and nitrates, as well as concepts such as “plain”, “fresh”, “unprocessed”, “untreated” and possible reinforced principles for using food additives in food categories containing these qualifiers in the GSFA. CCFA51 will try to make progress as well to find alternative options for a revised wording – or a full replacement by new notes – of the famous Note 161 throughout the GSFA in the context of sweetener provisions. CCFA51 will also address an important issue relating to the use of parent names of food additives and the procedure by which such groupings could affect food additives permitted in the GSFA. CCFA51 will also review its regular yearly items such as alignment between GSFA and commodity standards, endorsement of provisions included in draft commodity standards developed by other Codex Committees, amendments to the international numbering systems and functional classes of food additives, set the future priorities of JECFA upcoming scientific evaluations, and endorsement as a Codex norm of a series of new or revised specifications of identity and purity for a couple of food additives.

The 51st session of the Codex alimentarius Committee on Food Additives will be held in Jinan (China) from 25 to 29 March 2019, preceded by an important presession working group in person (PWG) to advance recommendations to the CCFA51 plenary. This PWG builds on recommendations from an electronic working group (EWG), which has advanced discussions on a large number of draft provisions for miscellaneous food additives and colours, particular uses in plain milk products and mozzarella, and on new proposals to add certain provisions of the GSFA or revise others.

GSFA: completion on almost all remaining miscellaneous additives and resuming discussion on a few colour provisions, among other discussions on plain and flavoured milk, mozzarella, soft drinks, etc.

Draft provisions on miscellaneous food additives in the whole GSFA and on the inclusion in Table 3 of the GSFA of two additives for approval – i.e. at GMP level unless otherwise specified. This is the long-awaited final discussion on most of the remaining draft provisions for miscellaneous food additives other than sweeteners, colors, adipic acid and other exceptions, which are to be addressed separately by CCFA at this session and at a later stage.

Draft provisions will be discussed in almost all food categories. This is by far the biggest piece for the PWG and the CCFA51 plenary. It will include draft provisions mainly for emulsifiers, thickeners, stabilizers, antioxidants, bulking agents, carriers, color retention agent, acidity regulators, emulsifying salt, etc.

A consensus is expected to be found on most of the provisions, except where some Codex member countries are of the opinion that an insufficient technological justification has been provided during the EWG past 8 months discussions. There will also be some discussion about the provision of propylene glycol in carbonated and non-carbonated water-based flavored drinks, whereby it may reignite the debate on secondary food additives (in flavoring and other preparations) vs carrier food additive. We recommend interested readers to read Annex 4 of the CCFA51 agenda item 5a working document available at www.fao.org.

There is also a proposal to include two food additives in Table 3 of the GSFA, namely Gum Ghatti (INS 419) and Tamarind Seed Polysaccharide (INS 437). Once formally approved in Table 3 of thGSFA, it means that their use will be permitted at GMP level in all food categories not annexed to Table 3. The two additives may be considered admissible in those food categories annexed to Table 3 if and only if comments are submitted in the coming months for suggested uses and numerical use levels in food categories annexed to Table 3 for discussion and possible future adoption in Table 1 and 2 at CCFA52 and beyond. CCFA51 will address other uses already approved in some specified foods covered by some Codex Commodity Standards, where these two food additives may be considered as technologically justified by the means of tables annexes to Table 3 of the GFSA or in the context of the on-going alignment work.

Colours for three sub-food categories of Confectionery

Last year, CCFA50 decided to initiate an experiment to see whether the international food additive community could discuss and possibly agree on all pending provisions for colours in three specified food categories and their subcategories to start with (see WFRR April 2018 issue). This year PWG and CCFA51 will consider recommendations to adopt most of the proposed colour provisions in (i) decorations for confectionery products, (ii) hard and soft candies and (iii) chewing gum. On the willingness of country blocks to find consensus around the EWG recommended maximum use levels for adoption (resulting from three rounds of negotiations among 55 countries from all over the world), will depend whether CCFA is able (i) to adopt such provisions for colors in the GSFA for the first time since 2011 and (ii) agree to continue the consideration of other colour provisions in the step process for other food categories. It should be noted that in the course of the three rounds of negotiations, the food industry provided massive contributions for the (i) technological justification of use, (ii) technological needs and (iii) consent to reduce the initially proposed draft maximum levels currently in the step process.

Therefore, it would be unfortunate that some country delegations nevertheless deny the fact that such justifications have been duly provided, even though some of the proposed levels may be higher than or not present in their respective national/regional legislation. On that point, the forthcoming PWG discussion will be symptomatic of whether country blocks may approach these Codex negotiations as such or would invoke their national legislation to hinder the adoption of those provisions in the Codex GSFA. It has also a potential risk to reopen the same wounds which led CCFA to stop considering color provisions since 2011. Everyone hopes this won’t be the case and that wisdom and constructive spirit may prevail in 2019.

Plain and flavoured milks

The PWG and CCFA51 will also discuss the technological justification of the use of trisodium citrate at GMP level in “Plain milk”, especially in plain milk obtained from other species than bovine species. However, opinions are clearly split as reflected in the proceedings of last year CCFA. Cur- rent proposal is to allow the use only as emulsifier or stabilizer. However, such use is disputed heavily in the case of cow and other bovine milks. Therefore, some argue that the allowed use of trisodium citrate should be limited to milks from non-bovine species. Others in favor of this use in cow milk argue that limiting it to sterilized and UHT treated only cow milk could resolve the matter. Dairy industry seems to be on that side and the recommendations of the EWG reflect this view. It is expected that those who expressed support for use only in non-bovine milk at the last session (e.g. EU Russian Federation, Uganda during the EWG and Costa Rica during last year CCFA) may raise again their concerns about these recommendations.

The other controversial issue is whether emulsifier and stabilizer such as carob bean gum, carrageenan, guar gum, gellan gum, etc. are justified in all products covered by this (new) food cate- gory named “Other fluid milks (plain)”. This relates also to the qualifier “plain” to describe adequately what those fluid milks are. It seems that the intent to use those substances relate more to some subcategory of products, which, although milk-based, would be slightly different from plain fluid milks, e.g. flavored and enriched in vitamins and minerals fluid milks, as pointed out last year. The current EWG recommendations, which obviously result from an attempt to find a middle ground, aim at approving numerical use levels for each substance in the full category of products covered by “Other fluid milks (plain)”, but leave opened the GMP level option for the whole food category as well. It also suggests an exemption at GMP level for “milk-based beverages only”. Reference to fortified and flavored fluid milks have clearly not been pursued forward by the EWG, compared to last year CCFA meeting discussions.

Mozzarella with high moisture

Another quite contentious point is on the agenda: whether the uses of preservatives in and anticaking agents for surface treatment of mozzarella with high-moisture content conforming to the Codex Commodity Standard for Mozzarella (CXS 262-2006) are technologically justified. The EWG recommends however that (i) the use of anti-caking agents in the surface treatment of “high-moisture mozzarella” is technologically justified only when that mozzarella is in a shredded or diced format and (ii) the use of preservatives in the surface treatment of high-moisture mozzarella is technologically justified when that mozzarella is not packaged in liquid. As a consequence, it recommends amending the table of food additives permitted in high-moisture mozzarella set in the Codex commodity standard for mozzarella, with two additional notes: (i) to permit but limit the use of all preservatives “only for high-moisture not packaged in liquid” and (ii) to permit but limit the use of all anti-caking agents to “surface treatment of shredded and/or diced cheese, only”. (Note of the author: maybe “cheese” could be changed to high moisture mozzarella...). We shall still see how the Italian delegation will react, but it seems the proposed approach could constitute an acceptable compromise for standardized mozzarella, which are clearly different from those mozzarellas with PGIs in Europe.

Water-based flavoured drinks and coffee/tea-based ready-to-drink beverages

The EWG recommendations aim at resolving two types of contentious concerns among countries. The first one relates to the sub-types of products where additives like stearoyl lactylates, polyglycerol esters of fatty acids, and moreover dioctyl sodium sulfosuccinate may be technologically justified for use, depending on the food cate- gory and the food additive considered: e.g. only in fruit-flavored beverages; use level expressed on a served-to-the-consumer basis; or ready-to-drink products and protein containing beverages; and/or for use in beverages which contain beverage whiteners only. The second issue relates to dietary exposure assessment based on the proposed maximum levels and the JECFA’s acceptable daily intake (ADI), and whether this is acceptable or not from a food safety risk management point of view. The PWG is expected to progress case-by-case on each provision separately and it may revive the unconcealable views already expressed during last year CCFA. Very difficult to predict whether consensus may be possible on all the recommendations for approval.


The CCFA51 plenary will be tasked to respond to a request raised at the last July Codex Commission session about “the justification for the inclusion of Rebaudioside A from multiple gene donors expressed in Yarrowia lipolytica (INS 960b(i)) in the GSFA.”

Two levels of discussion are expected to occur: on the procedure itself; and probably on the principles for such similar changes to GSFA as well. This is the case when similar food additives are subject to a parent food additive category (i.e. which is generally done under the agenda item on the INS), generally because JECFA assigned a group ADI to all the similar food additives covered by such a parent category. The third aspect is that there are different possible (national) interpretations on how the use of such similar food additives would be declared on the food label in the list of ingredients, for instance only by referring to the name of the parent category, and not to the specific name of one of the added similar food additive covered by that parent category. This labelling aspect is, for the time being, not in the scope of the question which has emerged from the last Codex alimentarius Commission. The Codex INS is not to be used for labelling purpose, as in theory the INS is just an inventory, but in practice it is used differently at the national level.

This topic, which may appear a bit technical at first sight, is fundamental. The last year CCFA decision to introduce a parent category in the INS numbers for all types of “Steviol Glycosides” and the creation of two new INS under that parent category has led automatically to permit Rebaudioside A from multiple gene donors expressed in Yarrowia lipolytica (i.e. a type of steviol glycoside obtained by a genetically modified microorganism) in the same food categories and at the same maximum use levels which were already permitted for the steviol glycosides obtained by extraction from the plant Stevia rebaudiana Bertoni (i.e. Steviol glycosides from Stevia).

At this point in time, it is still uncertain up to which point CCFA51 may be able to have an in- formed discussion on all those issues, beyond the question of clarification on the procedure coming from last CAC. However, the question will also be raised when CCFA51 is to consider the recommendation to create for instance a parent category for e.g. “Sucrose esters” to cover all the uses of three food additives within the same JECFA group ADI, i.e. (i) sucroglycerides (currently INS 474), (ii) sucrose esters of fatty acids (currently INS 473), and (iii) sucro-oligosaccharides (SOE) of type I and II (currently INS 473a). In this case, it has to be further discussed what would be the INS number and the name allocated to the parent category, and what would be the expected revised sub-numbers for these three food additives. The wider principle discussion of creating a parent category will also be at the heart of the discussion, such as what it would mean for existing provisions for one or more of the three food additives. Indeed, which choice is to be made when two or more of the three additives may be permitted in the GSFA at different maximum levels in the same food category (i.e. which level to pick for the group? The highest, the lowest, a middle ground?)? And obviously that recommendation would lead to extending the use all three food additives singly or in combination wherever at least one of them is permitted in a food category (alike what happened with the new Rebaudioside A approved last year) without any case by case discussion of the technological justification in each food category. Indeed, food additives may have the same toxicological profile which justifies a group ADI; but is that the same for the technological purposes and needs? In other words, does a group ADI always mean automatically that all food additives are equivalent from a food technology point of view? It may be true for Phosphates, Anthocyanins, or Benzoates. But for others? 

Possible new principles for the use of food additives in food categories with qualifiers such as “plain”, “fresh”, “unprocessed”, “untreated”

Russia has prepared a discussion paper to com- pile within the overall set of texts adopted by the Codex alimentarius Commission (Commodity Standards, GSFA food categorization system, Guidelines, Code of Practices) where the qualifiers “plain”, “fresh”, “unprocessed”, “untreated” are being used. The discussion paper aims also at assessing what it may mean in terms of the range and extent to which food additives shall be permitted in such foods.

From the Russian point of view, the idea is to establish further principles or criteria to restrict further the use of food additives proportionally to the level of processing. It also corresponds to what is currently not permitted to do according to the Eurasian Economic Union (EAEU) regional standard regulating food additives in its member countries (i.e. in the Russian Federation, Kazakhstan, Belarus, Armenia and Kyrgyzstan). It also corresponds to some advocacy movement, fed by some WHO-related think tanks, that ultra-processed foods are bad because ultra-processed foods contain food additives and reversely unprocessed foods are healthier because they don’t contain food additives. However, to date, no causal link has been scientifically demonstrated that e.g. organic foods are significantly healthier than conventionally produced foods. Only a few epidemiological studies have found some statistical correlations, however none of them have been able to explain the scientific reasons for such mathematical findings.

Nitrites and Nitrates

The discussion paper is not available at the time this article is drafted. This discussion paper is elaborated by an EWG chaired by the EU and co-chaired by the Netherlands and results from last year CCFA50 discussion and lack of consensus to take any risk management decision. The paper is to address some of the missing knowledge about nitrates and nitrites.

This discussion paper is expected to contain an inventory of data available on nitrates and nitrites, taking into account what was already compiled in last year CCFA working document on nitrites and nitrates as well as the written comments of the joint FAO/WHO JECFA Secretariat. That inventory shall contain:

(i) collected general information on risk-management approaches on nitrates and nitrites used as food additives by regulatory agencies of Codex members;

(ii) collected information on what is the most appropriate way of expressing the MLs in relation to control purposes, international trade, different production processes;

(iii) collected information on which types of products or production processes are nitrates and nitrites used, for what purpose and at what levels? What MLs expressed as ingoing and residual amounts are needed for preservation and color retention? Are there alternatives to nitrites and nitrates available for each of the GSFA subcategories for which provisions on nitrates and nitrites exist (whether adopted or in the Codex Step procedure) - and if available, provide accompanying data and studies demonstrating the effectiveness of the levels in performing the desired technological function;

(iv) collected information on natural occurrence data on nitrates and nitrites; and

(v) collected available information on remaining questions to further consider feasibility and the need for risk assessment. Namely:

(a) Does exposure to nitrosamines (exogenous and endogenous) pose a health risk? What are recent exposures from all sources and from food additives to nitrosamines generated during: i) the production process in foods; ii) heat-treatment in the domestic setting; and iii) gastrointestinal transit?

(b) What are appropriate levels (ingoing and residual) necessary to inhibit Cl. botulinum in view of risk (nitrosamines, ADI being exceeded) and benefit (microbiological safety) considerations taking into account other factors affecting microbial growth? and,

(c) To what extent does the use of additives such as ascorbic acid in conjunction with nitrates and nitrites reduce nitrosamine formation and mitigate the potential health risk from the use of nitrates and nitrites? Is available information enough to allow the safe use of nitrates and nitrates at higher levels when used in conjunction with these additional additives?

It may be quite a lot to digest and CCFA51 may only focus on the two first aspects described under (i) and (ii) above. See next month’s WFRR article on CCFA51 outcome...

Note 161 in the context of sweeteners

The discussion paper was not available at the time this article was written. This discussion paper was elaborated by an EWG co-chaired by the EU and the USA but was unfortunately delayed because of the US government shutdown at the end of 2018. Thus, the third circular with suggestions to find a compromise wording and alternatives notes to the note referring to national legislation and to the section on the principles for use of food additives in the preamble of the GSFA (i.e. “Note 161”) has not yet been shared either. It is unclear how the co-chairs are going to resolve the issue before CCFA51. According to reliable sources, the most likely scenario is that they are going to skip the third circular of the EWG and will produce a ‘two co-Chair’s proposal’ rather than an official recommendation resulting from a consensus within the EWG. This discussion paper will then be discussed by the CCFA51 plenary. It is not part of the man- date of the pre-session PWG in Jinan. The two co-chairs final proposal will be based on the draft solution presented in the EWG second circular draft, taking into consideration the very contradictive comments they have received in response to that second circular, and what they think may have a chance to be acceptable by all directly involved stakeholders and countries. More detail in nextmonth’sWFRRarticleonCCFA51outcome...

Other CCFA routine issues (Endorsement, Alignment, INS, JECFA, Endorsement)


CCFA51 will review draft provisions for food additives in the following draft standards developed by the Codex Committee on Spices and Culinary Herbs (CCSCH): dried or dehydrated garlic; dried oregano; dried roots, rhizomes and bulbs – dried or dehydrated ginger; dried leaves - dried basil; dried floral parts - dried cloves; saffron. The endorsement is expected to be straight forward.

However, under the “matters referred” CCFA51 agenda item, it is interesting to note the question from the last CCSCH with regard to (i) the use of anticaking agents in culinary herbs sold in powdered form to maintain “the free-flow characteristic of the products” with a particular focus on GMP levels for magnesium stearate and silicon dioxide and (ii) a clarification by CCFA on “how processing aids could be addressed under the Section 4 “Food additives” in accordance with relevant pro- visions in the Codex Procedural Manual?” The two matters are linked. Silicon dioxide for example can be viewed in some national jurisdictions as a processing aid e.g. used in milk powder silos as a free-flow agent, whereas in other national jurisdictions (or even at the same time in the same jurisdiction) it could be viewed as a food additive exerting the anticaking property in the final food (weigh protein powders for sportive people). This is a complicated topic and CCFA discussion may light up an interesting debate for possible future work of the CCFA on processing aids versus food additives, including the tricky issue of “residues”.


A dedicated pre-CCFA51 session’s Saturday afternoon PWG will discuss the report from an EWG chaired by Australia on proposals to align certain food additive provisions in commodity standards with their related food categories in the GSFA. Pro- visions relate to (i) 13 cheeses standards (e.g. Camembert, Gouda, Emmental, Provolone, etc.); (ii) honey; (iii) sugars; (iv) natural mineral waters; (v) Bottled/packaged drinking waters (other than natural mineral waters); (vi) wheat flour; (vii) couscous; (viii) instant noodles; (ix) wheat protein products including wheat gluten; (x) Vegetable protein products (VPP); (xi) Soy protein products and their related food categories in the GSFA, e.g. Ripened cheese, includes rind.

The approach will be to permit food additives in commodity standards in the future by functional groups and reference to Table 1 to 3 of the GSFA, instead of individual provisions, as per present provisions in the commodity standards. In other words, the current individual food additive provisions for example Cheddar will be deleted and re- placed with a table permitting e.g. colors, acidity regulator, preservatives, anti-caking agent, either in the cheese mass and/or in the rind/surface treatment. No doubt that the general issue of 1 to 1 correspondence with the GSFA food category descriptors will also be part of that discussion. CCFA51 plenary will take decisions based on the recommendations from that pre-session PWG report.

Review of JECFA past work, current recommendations for CCFA consideration and CCFA decisions on next priori- ties of work for JECFA for the next 2 years

JECFA86 outputs

CCFA51 will discuss the outcome of last meeting of JECFA (86th meeting, June 2018). Limited decisions are expected to be taken by CCFA51 from that report. JECFA86 conclusions relate to the following substances:

Anionic methacrylate copolymer (AMC): JECFA86 was unable to complete the evaluation of AMC. More data is required to clarify the in vivocarcinogenic potential of the residual monomer methyl acrylate.

Basic methacrylate copolymer (BMC): JECFA86 assigned an ADI “not specified” and established new specifications. JECFA recommends BMC (INS 1205) for inclusion in Table 3 of GSFA and circulate for comments at Step 3, and parallel request for use levels in food categories not covered by Table 3 for further discussion in Table 1 and 2.

Neutral methacrylate copolymer (NMC): JECFA86 assigned an ADI “not specified” but only temporary because of tentative specifications due to absence of data submitted for a suitable method of assay.

Sorbitol syrup: JECFA86 confirmed the assignment of an ADI “not specified” for sorbitol syrup.

Erythrosine: Full reevaluation and no reason to revise the previous ADI of 0–0.1 mg/kg body weight, which is confirmed as new ADI.

Indigotine: Full reevaluation and no reason to revise the previous ADI of 0–5 mg/kg body weight, which is confirmed as new ADI.

Lutein and lutein esters from Tagetes erecta and zeaxanthin (synthetic): JECFA86 assigned a group ADI “not specified” for (i) lutein fromTagetes erecta, (ii) lutein esters from Tagetes erecta and (iii) zeaxanthin (synthetic), but couldn’t conclude about meso-zeaxanthin, as no specification is currently available for meso-zeaxanthin. JECFA86 also revised the specifications for lutein from Tagetes erecta and kept unchanged specifications for lutein esters from Tagetes erecta and zeaxanthin (synthetic).

As such, JECFA86 recommends CCFA51 to include lutein from Tagetes erecta (INS 161b(i)) and zeaxanthin (synthetic) (INS 161h(i)) in Table 3 of GSFA and circulate for comments at Step 3, together with request for uses and use levels of the group food additives for the food categories listed in the Annex to Table 3 for future discussion and possible inclusion in Table 1 and 2. This JECFA recommendation is important as there are current draft provisions for zeaxanthin, synthetic proposed for adoption in the GSFA for candies, chewing gum and confectionary decorations.

Spirulina extract: JECFA86 assigned an ADI “not specified” but kept it temporary because the specifications remain tentative until further analytical data is provided, probably in December 2019.

Flavouring agents: JECFA86 completed the evaluation with no safety concern for almost all of them (about 70), but one. JECFA86 noted that genotoxicity data for p-mentha-1,8-dien-7-alraised concerns for potential genotoxicity. JECFA86 indicated it also couldn’t re-evaluate(+)-carvone according to the revised Procedure because of the lack of information on the oral expo- sure from all sources and the need to review the ADI. A review of the ADI is recommended based on the evaluation of all biochemical and toxicological data. Also, data is needed for an exposure assessment for oral exposure to (+)-carvone from all sources to complete the evaluation for (+)-carvone. It couldn’t re-evaluate (-)-carvone according to the revised Procedure either given the lack of information on the oral exposure from all sources and the lack of toxicological data.

Priority List of JECFA scientific advice to CCFA on food additives, flavourings and enzymes

CCFA51, most likely with the help of a possible in-session WG, will review the various requests received for revising the established list of JECFA priorities. CCFA51 will decide about their relevance and urgency. The requests may be grouped as follows:

– Safety evaluation and establishment of specification (new substances) Fulvic acid (i.e. 7,8-dihydroxy-3-methyl-10- oxo-1H,10H-pyrano[4,3-b]chromene-9-carboxylic acid), supported by South Africa for a South African company sponsor.

Riboflavin from Ashbya gossypii (sponsored by EU Specialty Food Ingredients). 46 flavorings, which include 45 new flavorings, 1 material for re-evaluation due to substantial new data since its original evaluation (sponsored by IOFI).

– Change to existing specifications

Change the solubility criterion from “sparingly soluble in ethanol” to “practically insoluble or insoluble in ethanol” in the specification ofPolyvinyl alcohol to (supported by EU for a Japanese company sponsor, via a law firm based in Belgium).

Change of the Method of assay from the “ICP-AES technique” to a titration method laid down in the monographs of the USP-Food Chemical Codex and other pharmacopoeia monographs (sponsored by CEFIC) in the specification of Magnesium stearate.

Replacement of the “congealing range” identification parameter by ‘Identification test — by acid value, iodine value, gas chromatography’ for three out of the five sorbitan esters approved in the GSFA (sponsored by EFEMA on behalf of a Danish company). 14 flavorings for which updated specifications data have become available (sponsored by IOFI).

– Reminder on pending priorities already on the list and confirmation of dossier/data availability

AMFEP expressed impatience through a reminder about all pending enzymes already included in the JECFA priorities table.

ETA (Enzymes Technical Association) reminded in their written submission that data is available for pending evaluation of D-Allulose 3-epimerase from Arthrobacter globiformis ex- pressed in Escherichia coli.

Codex approval as international norms of JECFA new and revised specifications of identity and purity

CCFA51 will review the outcome of the last JECFA86 to discuss whether new or revised specifications can be adopted as Codex standards. One specification was completed for Basic methacrylate copolymer (BMC). JECFA86 completed the revision of specifications of (a) Cassia Gum, (b) Erythrosine, (c) Glycerol ester of wood rosin (INS 445(iii)), (d) Indigotine; (e) Lutein from Tagetes erecta and a bunch of flavourings.

JECFA86 also advanced some tentative specifications, e.g. for individual modified starches.

For Spirulina extract, JECFA will have to complete the tentative specifications, when data are submitted by the sponsor on (a) full compositional characterization of commercial products in both liquid and powder forms; (b) full compositional characterization of the mulation/standardization; (c) validated analytical methods for identification of the substance with a suitable specificity (including validation data and representative batch data); and, (d) validated analytical methods for the determination of the purity of the substance with a suitable specificity (including validation data and representative batch data). This submission and further JECFA review work is expected to be completed by end 2019 and finalized full JECFA specifications submitted for Codex approval at the 2020 CCFA52 session.

International number system and functional classes/technological purposes

CCFA51 plenary will review the recommendations from a dedicated EWG and the related comments. Only a few, but significant changes are put forward.

EWG recommends the deletion from the INS of the following food additives (a) Red 2G (INS 128); (b) Sodium sorbate (INS 201); (c) Potassium ascorbate (INS 303); and (d) Distarch glycerol (INS 1411).

EWG recommends allocating the existing INS number to ˜-carotene-rich extract from Dunaliella salina by simply renaming Carotenes, beta-, algae as ˜-carotene-rich extract from Dunaliella salinawith existing INS 160a(iv).

Only one other change has been suggested to add a new functional class “Carrier” and two related technological purposes as “Carrier” and “encapsulating agent” to Methacrylate copolymer, basic (INS 1205), in addition to existing functional class and technological purpose as glazing agent (al- though JECFA has reviewed the safety of use of that additive only for its initial intended use of glazing agent of food supplements only).

In relation to the discussion on matters referred from the last Codex Commission, CCFA51 may also have to have a discussion of the impact of the parent category approach in the context of the discussion on the INS.

Although the proposed changes are not expected to be technically complicated to resolve, it may lead delegations to more fundamental questioning on the role of the INS as a simple inventory and al- location of a number, or as a Codex norm recognised by WTO/SPS/TBT Agreement as a “standard”. It may also lead to questions whether it is suitable to keep a substance in the list of approved Codex specifications if the substance is deleted completely from the INS. The current suggestion of consequential changes to the Codex text listing the Codex approved JECFA specifications to simply delete the INS reference number for Red 2G seems a bit contradictory to the fact that Codex would not view Red 2G as a suitable food additive any longer due to safety concerns after having deleted all the approved and pending provisions for Red 2G in the GSFA. In other terms, it is not because it will still be possible to have access to the specification for Red 2G in the JECFA database online, that the reference of Red 2G in the Codex document listing all the Codex approved JECFA specifications should be retained. One may argue it should also be completely deleted from that document as well. In other words, one may argue that there cannot be included in the Codex-approved JECFA specification list if the substance has been deleted from the INS list and/or from the GSFA.

Other matter referred

Based on a request coming from the before last meeting of the Codex Alimentarius Executive Committee (CCEXEC), CCFA51 is asked to provide its technical input about the new work under- taken by the Codex Committee on Food Hygiene (CCFH) to develop Guidelines for the management of (micro)biological foodborne crises/outbreaks and in particular reflect on whether similar guidance would be viewed by CCFA as needed in the context of microbiological contamination (and therefore criteria) of food additives, flavourings, enzymes or processing aids, as per the CCFA man- date and most likely JECFA specifications of identity and purity or other risk management options (dedicated CCFA guidelines).


Regulatory and Scientific Affairs Counselor