Official FAQ: Common Questions on China National Standards for Food Safety - Limits of Contaminants and Mycotoxins in Food

Recently, China's CFSA issued FAQs regarding National Standards for Food Safety. From our years of regulatory compliance experience, we’ve translated a selection of some frequently asked questions related to the limits of contaminants and mycotoxins in food to help you better understand the current requirements in China.

Q1: Are algal products subject to provision 3.5 of the National Standards for Food Safety – Limits of Contaminants in Food (GB 2762-2022)?

A1: GB 2762-2022 provides specific limits for algal products with sufficient contaminant data. However, the conversion principle in provision 3.5 of GB 2762 does not apply to algal products.

Q2: According to GB 2762-2022, do dried aquatic products include dried algae products?

A2: Appendix A of GB 2762-2022 specifies the description of food categories (names). According to the standard, dried algal products belong to the category of algal products, which are not dried aquatic products.

Q3: According to GB 2762-2022, should the lead limits in grape juice be enforced according to the requirements for “grape juice” or “fruit and vegetable juices and beverages containing berries and small grains of fruit (except grape juice)”?

A3: GB 2762-2022 stipulates the requirements for lead limits in beverages. The lead limit in single-species grape juice must comply with the lead limit requirements for grape juice, and the lead limit in mixed grape juice must comply with the latter.

Q4: GB 2762-2022 stipulates the lead limits for pollen and honey, but does not specify the lead limits in pollen products and honey products, how do you determine the lead limit in these two types of products?

A4: GB 2762-2022 only stipulates the limit requirements for lead in pollen and honey. Manufacturers of pollen products or honey products should adopt qualified raw materials and reasonable control measures for compliant production so that the level of contaminants in the relevant products can be as low as possible.

Q5: How do you understand the “edible parts” stipulated in GB 2762-2022 and GB 2761-2017?

A5: The definition of “edible parts” in GB 2762-2022 and GB 2761-2017 is that the raw materials of food are mechanically removed from the non-edible portion. It is emphasized here that the removal of non-edible parts is by mechanical means, excluding non-mechanical means, such as crude vegetable oil (gross oil) processed to obtain refined vegetable oil, evaporation of water, and steeping of tea leaves, which do not fall into the category of obtaining edible parts as referred to in the definition.

Q6: What is the revision of the application principle of “discounting of contaminant limits in dried products”?

A6: When the standard was revised, specific limits were set for dried products with sufficient data on contamination, such as dried vegetables and dried fruits; and limits were set in the form of dry weight for food products mainly circulating in the market in the form of dried products, such as dried fungus products and dried silver ear products. However, dried meat products, dried aquatic products, and dried edible fungi do not have sufficient data to support the formulation of the corresponding limit values and still need to be implemented in accordance with the provisions of 3.5 in GB 2762-2017.

GB 2762-2022 adjusts the principle of converting the contaminant limits in dried meat products, dried aquatic products, dried edible mushrooms, and other dried products to the following: “Where the limit indicator is required for both the fresh food and the corresponding product, the contaminant limit for the dried product shall be converted from the contaminant limit for the corresponding fresh food by combining it with its dehydration or concentration rate.” If the level of contaminants in the dried product is lower than that in the fresh raw material, it can be judged that the limit value is met the requirement.

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Further Information

Food FAQ: Compilation of Common Questions Regarding China National Standards for Food Safety- General Questions

Official FAQ: Common Questions on China National Standards for Food Safety-Pathogenic Bacteria Limits