A lesson from China for the regulation of food additive

By Juanjuan SUN

            With a notice coming from the Ministry of Health as well as other relevant ministries in China, whitening additives in flour, including benzoyl peroxide and calcium peroxide, have been officially banned since May 1^st, 2011. To whiten the flour, these additives were introduced in China in 1986 with the maximum 0.06mg/kg. In view of the ban proposal raised jointly by Chinese Grain Association and Chinese Cereals and Oils Association in October 2001, the argument on whether whitening additives shall be prohibited or not had been lasted for ten years since there are only certain scientific evidences that demonstrate that these two chemical substances are harmful to the respiratory system. In spite of the scientific controversy around this issue, the final official decision was made to prohibit it.

This example illustrates two concerns: one is about how to regulate food additives over a long period of time; the other is about how to regulate food additives at the scale of a country.

Regarding the first concern, it should be noted that the soundness of food additives may change with scientific and technological advancement.

Chemical substances can only be used for food products if their soundness is justified by scientific evidences. However, it should be noted that science has its own uncertainty; scientific knowledge constantly changes and evolves. As a result, the best available science on food issues may be different from one year to the next. Therefore, the safety of food additives should be reviewed and updated timely, in line with the newly emerged scientific evidences.

Regarding the second concern, it should be noted that food safety regulations can differ from one country to another. As in the case of whitening additives, only the European Union has taken the same methods as China. However, the U.S.A., Canada, and even Central American and Caribbean countries still allow the use of whitening additives on the basis of limited quantity control.

            For this reason, questions will continually be raised on why China chooses to forbid rather than authorize the use of these additives. As an answer, two explanations can be brought.

Firstly, it reflects the application of the principle of precautionary action against scientific controversy.  Currently, there are no official requirements to apply the precautionary principle in China. However, the prohibition of these whitening additives could be regarded as a protective action taken with precaution. The decision was taken to put public health as the priority when a scientific controversy exists concerning the soundness of a specific chemical.

As far as chemical substances are concerned, it is important to keep in mind that even if the scientific justification of their safety is of importance, it is yet more essential to admit the uncertainty of science, especially in the event of scientific controversy. The significance of the precautionary principle is to allow protective actions against the scientific controversy rather than waiting until the suspected health risk materializes, in order to put the protection of public health first.

Secondly, the strict regulation in China is related to the regulatory environment. Nowadays, most food safety issues in China are caused by the abuse or misuse of chemical substances during the food production and processing. As a result, panic and distrust have spread among the consumers regarding all the chemical substances which are added into food, including food additives. In this context, the strict regulation on additives has played an important role to help restore the confidence of consumers in the food chain. As it was the case in the EU after the BSE crisis (Bovine Spongiform Encephalopathy, also known as the “mad cow disease”), the public perception about the risks influenced the country’s regulatory approach on food safety.