Compliance interpretation and case analysis of nutrition enhancer

Food with nutrition enhancers is common in our daily life. For example, candy with vitamin enhancers, infant formula with vitamin and mineral enhancers.

Food producers should have a comprehensive understanding of standards, regulations, and announcements of nutrition enhancers in China. CIRS Group provides a deep interpretation of the definition, regulation compliance, and case studies of food nutrition enhancers in China.

1. Definition of Nutrition Enhancer

Natural or synthetic nutrients that are added to food products to improve the nutrition value of the product.

2. Relevant Regulations

• GB 14880-2012 The Usage of Food Nutrition Enhancers
• Supplementary standards or announcements issued by NHC
  

3. Case Studies

3.1 Prepackaged common foods

Note: In the second step, supplementary announcements from NHC should also be checked.

Example: Zinc enhancement in solid beverage:

1. According to Table D.1 of GB14880, solid beverage belongs to No. 14.0 (beverage) ---14.06 (solid beverage).
2. The added dosage of zinc in the solid beverage is limited between 60 mg/kg-180 mg/kg in the Table A.1 of GB14880.
3. Ensuring if the source of zinc complies with the Table B.1 of GB14880 and the No.5 announcement from NHC.:

Nutrition enhancer	Compound source
Zinc	Zinc sulfate, zinc gluconate, glycine zinc, zinc oxide, zinc citrate, zinc chloride, zinc acetate, zinc carbonate, zinc citrate (trihydrate).

3.2 Special dietary food

Note: In the second step, supplementary announcements from NHC should also be checked..

Example 1. Zinc enhancement in cereal supplements for infants

1. According to Table D.1 of GB14880, infant cereal supplements belongs to No. 13.0 (special dietary food) ---13.02 (infant supplement food) ---13.02.01 (infant cereal supplements).
2. According to GB 10769-2010, the content level of zinc in cereal supplements for infants should be limited between 0.17 mg/100kJ-0.46 mg/100kJ.

   Item	Index
   	Cereal supplements for infants and young children	High-protein cereal supplements for infants and young children	Cereals for infants and young children	Biscuits for infants and young children or other cereal supplementary foods for infants and young children
   Zinc/mg/100kJ	0.17-0.46			-

3. Ensuring if the source of zinc complies with the Table B.1 of GB14880 and the No.5 announcement from NHC.

Nutrition enhancer	Compound source
Zinc	Zinc sulfate, zinc gluconate, zinc oxide, zinc lactate, zinc citrate, zinc chloride, zinc acetate, zinc citrate (trihydrate).

Example 2. Casein calcium peptide enhancement in cereal supplements for infants

1. According to Table D.1 of GB14880, infant cereal supplements belongs to No. 13.0 (special dietary food) ---13.02 (infant supplement food) ---13.02.01 (infant cereal supplements).
2. According to Table C.1 of GB14880, the added dosage of casein calcium peptide in infant supplement food should be no more than 3.0g/kg. Therefore, the usage of casein calcium peptide in infant cereal supplements should also be no more than 3.0g/kg even if there is no certain requirement of the dosage of casein calcium peptide for infant cereal supplements.

4. Attentions

4.1 When the substance is identified in more than one category.

Example: Vitamin C (L-ascorbic acid) can be both a nutrition enhancer and a food additive.
How to classify the Vitamin C? ------Ensure the purpose of usage

1. If the substance is used as a nutrition enhancer, GB 14880-2012 should be used as a reference.
2. If it is used as food additives, you should check the requirement in GB 2760-2014.

4.2 About nutrient enhancer usage and final product content

1) For prepackage common food

Whether the dosage of a nutrition enhancer complies with GB standard depends on the added amount rather than the amount in the final product.

The requirement using the amount of nutrition enhancers in GB 14880-2012 refers to the actual amount added during production. Because of the large differences of nutrients in different food raw materials and the different nutrients have different attenuation and loss during production and storage. Therefore, the final amount of nutrients may be higher or lower than what is required in GB14880.

2) For special dietary food

Whether the amount of nutrition enhancer is compliant depends on the nutrient content in final products according to product GB standard (e.g. the product GB standard of cereal supplements for infants is GB 10769-2010.).

Note: The nutrients that list in Table C.2 in GB 14880 should follow the added dosage requirements just like the prepackaged common food.

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