AMCHAM FOOD & AGRI ALERT: FOOD ADDITIVES

VOL. 4 of  October 19, 2023

The World Health Organization (WHO) defines “Food Additives” as substances added to food to maintain or improve its safety, freshness, taste, texture, or appearance.

Many different food additives have been developed to meet the needs of food production, as producing food on a large scale is very different from making food on a small scale at home. Additives are needed to ensure processed food remains safe and in good condition throughout its journey from factories or industrial kitchens and during transportation to warehouses, shops, and finally to consumers.

The updated Thai food regulations released this month pertain to the country’s food additive laws.

1. Notification of the Ministry of Public Health Re: Food Additives

The Thai FDA prepared this draft notification in 2022. It has already passed the public hearing stage twice.

Even though Thailand’s food additive laws have been in place for a long time, and there have been many versions, there are still many food entrepreneurs in Thailand who do not know that the use of food additives in Thailand must comply with the positive list of food additives prescribed in the Thai FDA regulations. This positive list applies information from the Codex General Standard for Food Additives and is combined with existing information in order to allow the safe use of food additives in Thailand.

On October 5, 2023, the Thai FDA announced on their website the preparation stages for the upcoming food additive regulation. This notification will be published in the Government Gazette soon. This draft notification provides a positive list of food additives for use in food, along with conditions for their use. The latest changes are as follows:

• Expanding the scope of food to allow the use of certain food additives.
• Removing certain food categories to allow the wider use of certain food additives.
• Changing the conditions, functions or limitations of using food additives.
• Adding new food additives for use in food (i.e., advantame, brilliant black (black PN), brown HT, partially hydrolyzed lecithin, methacrylate copolymer, paprika extract (INS 160c(ii)), Steviol glycosides from fermentation (INS 960b), enzymatically produced steviol glycosides (INS 960c), glucosylated steviol glycosides (INS 960d), synthetic zeaxanthin).
• Removing certain food additives from the positive list (i.e., canthaxanthin and sodium sorbate (INS 201)).

2. Notification of the Ministry of Public Health (No. 443) B.E. 2566 (2023) Re: Enzymes Used in Food Production

This notification was published in the Government Gazette on 15 August 2023 and went into effect the next day. Enzymes are food processing aids (of which one type is the category of food additives) that play an important role in many types of food production. The Thai FDA also set out an updated positive list of enzymes for use in food.

The Thai FDA allows the use of enzymes according to the conditions set out in following documents:

• Appendix 1 of this notification
• JECFA Combined Compendium of Food Additive Specifications
• Notification of the Ministry of Public Health Re: Food Additives
• Thai FDA Approval Letter on a case-by-case basis

In order to produce food to meet the required standards in accordance with Thai law, food additives and
enzymes should be studied carefully before use.