What is the food classification system and how to pinpoint food categories?

As a food practitioners or food inspection agency staff, have more or less encountered such confusion, the same type of food, we have a variety of applicable standards, national standards, industry standards or local standards, each standard has a definition of this type of food and categorization, the same type of food in the classification of different standards in different categories of food attribution.

The qualified determination of food additives is closely related to the classification of the food in its standard, and it can be said that the food classification system directly affects the results of the qualified assessment of food additives. Therefore, it is of great significance to analyze the differences between this food classification system, the food product standard, the food market access classification and the food classification system in GB 2760 and its influence on the results of food additives.

Introduction to China’s Food Classification System

At present, China’s food classification system has different food classification systems based on the needs of different specialized fields, and in the process of using it, special attention should be paid to the same food in different food classification system categories may be different. Partner network organized the various food classification system in China, the following content for your reference.

1. China’s food classification system and scope of application introduction

China’s food classification system mainly has a food production license food classification system, food safety standards food classification system, food safety supervision and sampling implementation rules in the food classification system, etc., the following is a detailed introduction:

1, “Food Production Permit Classification Catalog” will be divided into 32 categories of food, and specify the subclasses and their varieties belonging to the details. Food Production License” in the “food production license varieties detailed table” is filled out in accordance with the “Food Production License Classification Directory”. The catalog is applicable to food production license.

2. GB 2760-2014 National Standard for Food Safety Standard for Use of Food Additives adopts a grading system to categorize food into 16 categories. The food classification system is used to define the scope of use of food additives and is only applicable to the use of the standard. Where, for example, if a food additive is applied to a food category, it is permitted to be applied to all food levels above and below the level contained in that food category (unless otherwise specified), and conversely a food additive permitted for use in a lower level food cannot be considered to be applicable to its higher level food, so that when looking for a food additive permitted for use in a food category it cannot be considered to be applicable to its upper level food. permitted food additives, it is especially necessary to pay attention to the superior and subordinate relationships of food categories.

3. Appendix A.1 of GB 2761-2017 National Standard for Food Safety Limits of Mycotoxins in Foods describes the food categories (names), which involves 10 major categories of food, each of which is divided into a number of subcategories, which are in turn divided into sub-subcategories, sub-subcategories, etc. The description of food categories (names) is used to define food additives that are allowed to be used in a food category. The food category (name) descriptions are used to define the scope of application of the mycotoxin limits and apply only to the standard. When a certain mycotoxin limit is applied to a food category (name), it is applicable to all categories of food within that food category (name), except for special provisions.

4. GB 2762-2017 National Standard for Food Safety Limits of Contaminants in Foods, Appendix A Description of Food Categories (Names), involves 22 major categories of food, each of which is divided into a number of subcategories under each major category, which are in turn categorized into sub-subcategories, sub-categories and so on. The Notes on Food Categories (Names) (Appendix A) are used to define the scope of application of the contaminant limits and are only applicable to this Standard. When a certain pollutant limit is applied to a certain food category (name), all categories of food within that food category (name) are applicable, except for special provisions.

5, GB 2763-2021 “National Standard for Food Safety Maximum Residue Limits of Pesticides in Food” Appendix A (normative appendix) food categories and determination of parts of the food according to different sources of raw materials into 11 categories. Food categories and determination of parts (Appendix A) is used to define the scope of application of the maximum residue limits of pesticides, only applicable to the use of the standard. If the maximum residue limits of pesticides are applied to a food category, all foods under the food category are applicable, except for special provisions.

6, GB 14880-2012 “National Standard for Food Safety Standard for the Use of Food Nutritional Enrichment” of Appendix D food category (name) description, food is divided into 16 categories. D food category (name) description for defining the scope of use of nutritional enhancers, only applies to this standard, such as allowing a nutrient fortification agent is applied to a certain food category (name), then allowed to be applied to all categories of food under the category, or otherwise specified. If a nutrient fortifier is allowed to be applied to a certain food category (name), it is allowed to be applied to all food categories under that category, unless otherwise specified.

7. The food classification system in the Implementing Rules for Supervision and Sampling Inspection of National Food Safety shall be judged according to the food classification system of the basic standards (GB 2760, GB 2761, GB 2762, GB 2763, GB 29921, GB 31650, etc.) when the judgment is based on the basic standards. If there are other provisions in the rules for various types of food, they will be implemented according to their provisions.

8、Customs HS Code Query, provide import and export commodities HS code query, HS code “harmonization” covers the “Customs Cooperation Council Tariff Code Commodity Classification Directory” (CCCN) and the United Nations “Standard International Trade Classification” (SITC) two major classification and coding system, is a systematic, multi-purpose international trade commodity classification system. It is a systematic and multi-purpose international trade commodity classification system.

2. Progress of Revision of China’s Food Classification Standards

Because there is currently no set of unified guiding food classification system applicable to the national standard system for food safety, our country is also actively promoting the establishment of a unified food classification system. In 2014, the former National Health and Family Planning Commission set up a project to start the standard development of Food Safety Nomenclature and Food Classification, in 2017, the Food Evaluation Center, in conjunction with the China Association of the Food Industry, drafted a classification system that includes 25 major categories of food, and in 2018, the Review Committee of the National Standard for Food Safety solicited opinions internally for the Food Classification System Used for the National Standard for Food Safety.

However, the Food Classification System for Use in National Food Safety Standards only serves as a reference for food safety risk management work, and will not replace the current existing categorization of the food industry, nor will it replace the categorization used in various general food safety standards and food safety regulatory work, so food industry practitioners still need to be proficient in the various food classification systems introduced earlier.

Examples of Food Classification Confusion

1. Conflict cases of some food categories in GB 2760 and SC food classification system

(I) Steamed Buns

According to the Classification Catalogue of Food Production License, steamed buns should be categorized as hot processed pastries in pastries. According to the classification method of production license, it is easy to think that steamed bread also belongs to confectionery in the food classification system of GB 2760-2014 National Standard for Food Additives Use in Food Safety, and sweetener can be used with a limit of 1.6 g/kg. However, this is not the case, according to the description of food classification in GB 2760, confectionery (07.02) refers to confectionery made of grain, oil, sugar and/or sweeteners, eggs, etc. as the main ingredients, with appropriate amount of auxiliary materials added, and made through the process of modulation, molding, and ripening. Fermented noodle products (06.03.02.03) refers to the fermentation process made of noodle products, such as buns, steamed bread, rolls, etc., so steamed bread, does not belong to the pastry category of food, should belong to the fermented noodle products, it can be seen that the steamed bread is more in line with the definition of the fermented noodle products, and in the GB 2760 Food Classification Description of a clear example of steamed bread belongs to the fermented noodle products. Therefore, steamed bread should be “fermented noodle products (06.03.02.03)” category judgment, not allowed to add sweeteners.

(ii) Flavored wine

Article 3.1 of SB/T 10416-2007, “Flavored Wine”, defines flavored wine as “a liquid condiment made from fermented wine, distilled wine or edible alcohol with edible salt added (plant spices can be added)”, which is basically the same as the definition of “GB 2760-2014 Implementation Guidelines” for “Flavored Wine and Products”. This definition is basically consistent with the definition of “cooking wine and products” in the “GB 2760-2014 Implementation Guidelines”, and according to the GB 2760-2014 food classification system, cooking wine products should be categorized as “cooking wine and products” under the major category of seasonings (food classification number 12.07); however, there are still some cooking wine producers who believe that the SC licensed unit of cooking wine is liquid seasoning, and thus cooking wine should be classified according to the GB 2760-2014 liquid composite seasoning. However, some wine manufacturers still believe that the SC-certified unit of wine is liquid seasoning, and thus wine should use additives according to the provisions of GB 2760-2014 for liquid compound seasoning (food classification number 12.10.03). In accordance with the rules for determining food additives, each food additive determined according to GB 2760 should adopt the classification system in GB 2760 to determine the food classification.

(III) Walnut powder

According to the GB 2760-2014 food classification system, brewable walnut powder food can be categorized as solid beverages (food classification number 14.06) or other processed nuts and seeds under the category of Processed Nuts and Seeds (food classification number 04.05.02.05), whereas walnut powder belongs to convenience food according to the SC classification system, which is currently not available in GB 2760-2014. Therefore, convenience foods such as walnut flour, almond soup, and mixed grain porridge are more difficult to grasp their classification in GB 2760 due to the uncertainty of the food ingredients, process, or method of consumption.

(iv) Peanut candy

According to GB 2760-2014 food classification system, peanut-based, sugar-assisted processing of peanut sugar is different from sugar, starch syrup (or other sugar), sugar alcohols or other sweeteners allowed to be used as the main raw material for the production of ordinary confectionery, peanut sugar should be categorized as GB 2760-2014 processed nuts and seeds under the category of other processed nuts and seeds (Food Category No. 04.05.). 02.05), but according to the SC classification system, peanut sugar belongs to candy and is mostly licensed as candy. Therefore, such as peanut sugar, sesame sugar, sugar melon seeds and other nut products, due to the difficulty of confirming the food raw material pairing, easy to cause confusion about their additives food classification.

2. Part of the food category in GB 2760 and the corresponding product standards in the conflict case

(I) Cold fruits and candied fruits

According to GB 2760-2014 food classification system, cold fruits and candied fruits are divided into 5 subcategories, in which cold fruits are defined as dry products according to GB 2760-2014 Implementation Guidelines: GB/T 10782-2006 General Rules for Candied Fruits (to be abolished) divides candied fruits into 7 subcategories, and compared with GB 2760-2014, there are more frosting categories and other categories, in which cold fruits are defined as semi-dry products. The category is defined as semi-dry products. For some enterprises implementing the standard production of “General Rules for Candied Fruits”, frosting products can not be classified according to GB 2760-2014, and cold fruit products are in the definition of dry and semi-dry state. (Note: 2760-2014 will be repealed soon, the new standard to remove the frosting category)

(ii) Non-fermented soybean products

GB/T 22106-2008 “non-fermented soybean products” contains soybeans and water as raw materials, pure soybean milk processed by pulping, sterilizing and other processes, as well as flavored soybean milk with added flavor substances, according to the national standard, soybean milk belongs to non-fermented soybean products undoubtedly. According to GB 2760-2014 food classification system, non-fermented soybean products (food classification number 04.04.01) does not include liquid soybean milk products, soybean milk belongs to the beverage category under the vegetable protein drinks (food classification number 14.03.02): In addition, GB/T 22106-2008 does not include non-pulping process of soybean meat, cooked beans and other soybean products are also included in GB 2762-2014. In addition, soybean products not covered by GB/T 22106-2008, such as soybean vegetarian meat processed by non-pulping process and cooked beans, are also included under the non-fermented soybean products category of GB 2762-2014.

Determination of food classification

1. Determination through definitions in product standards

You can learn from some product standards and find them by searching keywords, such as classification, terminology, general rules, and so on. For example, the “Basic Terminology of the Food Industry” (GB/T 15091-1994), “Aquatic Products Processing Terminology” (GB/T 36193-2018), “Classification of Seasonings” (GB/T 20903-2007), “Classification of Confectionery” (GB/T 30645-2014), and “Classification of Soybean Foods” (SB/T 10687-2012), etc., in the standard There are classification, definition and scope of application of food.

2. Determination by product raw materials and process

In addition to the definition of food classification by the product name in the corresponding standard, it can also be combined with the main raw materials and processes and other attributes to judge. For example, most of the food classification in GB 2760 is based on the main raw materials of food and combined with the processing technology for classification, therefore, in the food production license classification of some product categories need to be based on the main raw materials of food in the GB 2760 food classification system to find. Examples are as follows:

The product implementation standard is SB/T 10379 Frozen Prepared Foods, and the product category is dish products (cooked products), the production license classification of the following two products can be 1102 Frozen Prepared Foods, but when applying the GB 2760 Food Classification System, it should be based on the raw materials of the product and the process to be determined:

A (boiled sliced pork): ingredients list: pork (≥40%), water, bean sprouts, XX, XX, spicy sauce, XX, XX…

B (Shredded Pork with Snow Vegetables): Ingredients list: pickled snow vegetables (≥80%), salt, water, XX, XX, XX, pork, XX, XX…

These two products, although the same product category and are cooked products, but the raw materials are different, in the use of GB 2760 food classification system to consider the raw materials of the product, process and other factors to determine, A product main ingredient is pork, in line with the GB 2760 classification system in the definition of 08.03 Cooked meat products with fresh (frozen) livestock and poultry meat (including offal) as the main raw material, adding salt, soy sauce and other seasonings, the Meat products made by the cooked process, sub-category should belong to 08.03.09 Other meat products; Product B, whose main ingredient is snow lettuce, conforms to the definition of 04.02.02 Processed vegetables in GB 2760 classification system, which includes all other processed vegetables except peeling, pre-cutting and surface treatment, and sub-category should belong to 04.02.02.08 Other processed vegetables. It is important to determine the exact classification of the product in order to be able to use the additive in a compliant manner.

3. Combined with the method of consumption to determine

Sometimes according to the raw materials and processes of the product can not be accurately determine the product category, then we can take into account the way the product is consumed, for example, “mint leaves”, to soak or boil the way to eat is a substitute tea; direct consumption is generally a spice. When applying for a production license, mint leaves as a substitute tea to apply for 1404 substitute tea production license category, used as spices to apply for 0305 seasoning production license category.

Summarize

For a certain food, even if there is a relevant classification in the national standards, industry standards or local standards, but because of its classification in different standards may be different, so it is necessary to match the corresponding standards and the need for the corresponding food category.

That is, the use of food additives is judged strictly according to the standard categories of GB 2760, and contaminants and biotoxins are judged strictly according to the corresponding food categories of GB 2762 and GB 2761 standards. For the category of application unit of food production license, the corresponding application unit is matched strictly according to the “Announcement of the General Administration of Market Supervision on Revision and Publication of Classification Catalogue of Food Production License No. 8 of 2020”.

Each food classification system is still extremely confusing to use, and we should comprehensively consider the main raw materials of the product, the process, the implementation standards, the method of consumption, etc., and determine the food classification system according to the purpose of use when determining the food classification. Therefore, in view of the complexity of food classification and the multiplicity of new product innovations, in many cases, it is recommended to consult or listen to the opinions of national ministries and commissions, regulatory agencies, industry associations and third-party experts if the classification of a food product cannot be determined.