January 22, 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 additives composite leavening agent (G/SPS/N/CHN/1035) 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 additives composite leavening agent” (G/SPS/N/CHN/1035), which was notified to the World Trade Organization (WTO) on November 25, 2015. IFAC is a global association representing companies that produce high quality substances used worldwide as food additives. In Section 2.1.3, the draft Standard proposes that if no aluminum-containing food additives are added in the manufacture of a food product, then the aluminum content of the agent should not be used in excess of 100 parts per million (ppm) in accordance with the provision in GB 5009.182. IFAC does not believe that this proposal is clearly defined and request additional clarification on the intention of the proposed requirement. Additionally, IFAC requests clarification as to the consequence if the aluminum content of an agent exceeds 100 ppm when aluminum-containing additives are not added. Would the aluminum content need to be declared or would there be another consequence? IFAC is concerned that this proposed requirement could be interpreted differently among different regulatory officials and therefore strongly urge that clarification be provided before finalization of the standard. In summary, IFAC requests that the National Health and Family Planning Commission provide further clarification regarding the requirements for aluminum-containing additives in this draft standard. 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 .