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January 13, 2016 National Health and Family Planning Commission No. 1 Xizhimen Outer South Road Xicheng District Beijing 100044

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January 13, 2016 National Health and Family Planning Commission No. 1 Xizhimen Outer South Road Xicheng District Beijing 100044 January 13, 2016 National Health and Family Planning Commission No. 1 Xizhimen Outer South Road Xicheng District Beijing 100044 People’s Republic of China Re: National Food Safety Standard: Food additive sodium carboxymethyl cellulose (G/SPS/N/CHN/1027) Dear Sir or Madam, The International Food Additives Council (IFAC) is commenting on the People’s Republic of China National Health and Family Planning Commission’s “National Food Safety Standard: Food additive sodium carboxymethyl cellulose” (G/SPS/N/CHN/1027), which was notified to the World Trade Organization (WTO) on November 20, 2015. IFAC is a global association representing companies that produce high quality substances used worldwide as food additives. The draft National Food Safety Standard proposes to revise the loss on drying requirement from less than 10% to less than 8%. It is noted that this change can be met by domestic companies. However, the China Food Safety Law states that the establishment or revision of a National Food Safety Standard should be based on the result of a food safety risk assessment and not on manufacturer ability to meet a certain requirement. A revision to the loss on drying requirement from 10% to 8%, a difference of 2%, would mean that 20 kg more water per 1 MT of carboxymethyl cellulose (CMC) would need to be evaporated as the loss on drying for CMC in the finished product is from water residue. Such an additional drying would require roughly 20 more kWh of electricity per 1 MT of CMC to achieve the required evaporation. This additional required loss is not environmentally sound due to the additional electricity requirement and adds an unnecessary cost to the production without sufficient quality justification. There is no added technical value achieved with the revised loss on drying requirement. No additional benefit will be seen in the finished product in terms of product quality or application in foods. Additionally, the current loss on drying requirement of less than 10% aligns with international specifications, including the Joint FAO/WHO Committee on Food Additives (JECFA) monograph, the Food Chemicals Codex (FCC) monograph, and international regulations, such as the European Union (EU) Directive. Maintenance of the current requirement would help ensure consistency and harmonization of global regulations while maintaining highest product quality. Additionally, IFAC does not support the use of mandatory microbiological specifications in this standard as other organization monographs for CMC (e.g., Codex Alimentarius, Food Chemicals Codex) do not include such requirements. In the manufacturing process, it is extremely unlikely that dry cellulose derivatives, including CMC, would contain microorganisms as they have low moisture levels and low water activity. As microbiological risk is primarily associated with water activity level, microbial activity would not be promoted during production of sodium carboxymethyl cellulose and therefore such specifications should not be included. In summary, IFAC requests that the National Health and Family Planning Commission maintain the current loss on drying requirement of CMC of less than 10% and remove the microbiology requirement. We appreciate the opportunity to comment on this matter. Please contact me if you have any questions or would like any further information. Sincerely, Robert Rankin Executive Director .
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