3. Compositional Aspects

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3. Compositional Aspects

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Beers, RTDs, Whisky
Mongolia

This section provides the compositional requirements for the food category and/or food products in scope and information on permitted nutrients, ingredients, and additives.

3.1 Composition Requirements

The “Law on Ensuring the Safety of Food Products” outlines the following general requirements for materials used in food:

The safety of food raw materials is critical and must be ensured at all stages of the food chain, including production, processing, packaging, storage, and transportation, to prevent harm to human health when used as intended.
If food raw materials or products pose a health risk, they must be immediately withdrawn from the market. The food business operator is obligated to report such withdrawals to the relevant authorities and maintain detailed records.
Hazardous materials must be destroyed or recycled in accordance with government procedures.
Food operators must maintain accurate records to trace food raw materials and products throughout the food chain, ensuring these records are kept for a minimum period after the product's expiration date [1].

In the case of alcoholic beverages, Article 2.1.6 of the Technical Regulation of the Beverage Industry MNTR 1:2008 aligns with these broader food safety measures. It mandates that alcoholic beverage producers conduct comprehensive analyses of both raw materials and finished products at least once per quarter in an accredited laboratory. This analysis is required when starting new production, resuming production after a long break, or introducing new raw materials. In all of these cases, a comprehensive analysis must be conducted by an accredited external laboratory, ensuring that raw materials are used in production under qualified conditions [2].

Mongolian regulations do not provide a positive list of permitted ingredients, except for the main ingredients essential for determining the product name and classification as specified in the product definition. The requirements for ingredients and components are generally outlined as follows:

Product

1) Beer, 4-7% Alcohol

The raw materials, auxiliary materials, and food additives for the production of beer shall meet the standards and technical requirements of Mongolia or of the country of preparation and supply when no specific criteria are laid down in Mongolian legislation [3].

Note: Mongolia follows the Codex General Standard for Food Additives CXS 192-1995. Compliance with CXS 192-1995 on the use of food additives is acceptable in Mongolia.

2) Alcoholic ready-to-drink beverages (mainly Chuhai), 3-9% Alcohol

Raw materials and auxiliary materials must meet the standards of Mongolia or of the supplier's country when no specific criteria are laid down in Mongolian legislation. Food additives must comply with "Food Additives" MNS CAC 192:2007, aligned with the Codex General Standard for Food Additives CXS 192-1995, and be approved by the relevant authority [5].

3) Whisky, around 45% Alcohol

Same as the alcoholic ready-to-drink beverages above.

3.2 Raw Material Requirements

Product

1) Beer, 4-7% Alcohol

Malt, as the main raw material: all sensory, physical, chemical, and microbiological parameters specified in MNS 2108:2000 [4]

Table 1. Sensory parameters of malts, excerpted from MNS 2108:2000 [4]

No.	Classification	Indicator	Appearance	Color	Taste	Smell
1	Normal	Pale malt	Dry, TOOC is free of dirt. The husk of the malt was as shiny as that of the barley. The beard and fangs are completely cleaned. It should not be hardened, glassy, or wrinkled.	Light yellow or uniform color.	Mild taste. Do not accompany.	Clean and must not be moldy, musty, and burnt.
1	Normal	Black malt		Yellow-greenish or dark glow.
2	Dedicated	"Caramel"	Smooth surface without wrinkles. "Caramel" malt is glassy and bright.	Light yellow to brown intensity	The flavor of the juice is: Lightly sweet caramel, more pronounced caramel, almost bitter.	It has a distinctive aroma of malt. No external smell.
		Melan malt		Saturated color of the melanoid formation reaction.	The flavor of the juice is divided into sweet taste. No bitter or sour taste.	It has a unique aroma of malt.
		Roasted malt	When the sprout is cut, the embryo is dark brown in color. Burned seeds should not be more than 7%.	It is evenly dyed dark brown /not black/color.	Clean, coffee-flavored, not harsh or sharp.	It smells like barley coffee.

Table 2. Chemical and physical parameters of malt, excerpted from MNS 2108:2000 [4]

2) Alcoholic ready-to-drink beverages (mainly Chuhai), 3-9% Alcohol

N/A.

3) Whisky, around 45% Alcohol

Same as Alcoholic ready-to-drink beverages.

3.3 Fortification

General Food

In Mongolia, food fortification regulations aim to address micronutrient deficiencies, with a focus on improving public health by adding essential nutrients to commonly consumed foods. Mandatory fortified foods in Mongolia include wheat flour and salt which serve as vehicles for adding nutrients like iron, vitamins group B, vitamin D, Zinc, and Iodine. For instance, wheat flour is fortified with folic acid to prevent neural tube defects, while salt is iodized.

Key regulations include:

Law on Fortified Foods [7]
List of Officially Fortified Foods [8]
Law on Iodinated Salt and Prevention of Iodine Deficiency [9]

Apart from specific regulations on the addition of vitamins and minerals to flour and salt, Mongolia has not yet established a comprehensive list of nutrients permitted for addition to other foods.

Category

Alcohol

Alcoholic beverages are not explicitly addressed within the country's regulations on fortified foods.

3.4 Other Permitted Ingredients

Not specified by the regulations.

3.5 Permitted Additives

Article 2.2 of the 'Law on Ensuring the Safety of Food Products' establishes that international treaties to which Mongolia is a party take precedence over national legislation in cases of conflict. As a result, Mongolia’s food safety policies align with Codex standards, ensuring compliance with global norms, especially in the absence of a national list of approved food additives. This alignment facilitates Mongolia's integration into international food safety frameworks [1].

Article 17 of the same law assigns the central state administrative body the responsibility to establish safe levels and conditions for food additive use.

According to MNS CAC 192:2015, only food additives that have been evaluated and deemed safe by the Joint Expert Committee on Food Additives (JECFA) and the World Health Organization (WHO), and that meet the criteria for acceptable daily intake (ADI), are permitted for use in food. MNS CAC 192:2015 aligns with the Codex Standard CXS 192-1995 General Standard for Food Additives and references its latest official version in the event of any revisions. Therefore, the use of food additives in compliance with Codex standard CXS 192-1995 is considered consistent with Mongolia's regulatory requirements. [6, 10]

In applying Codex guidelines for alcoholic beverages, the use of food additives, including colors, within specified limits adheres to the provisions outlined in the Codex General Standard for Food Additives (CXS 192-1995), particularly in the following Codex food categories:

14.2 Alcoholic beverages, including alcohol-free and low-alcoholic counterparts
14.2.1 Beer and malt beverages
14.2.2 Cider and perry
14.2.3 Grape wines
14.2.3.1 Still grape wine
14.2.3.2 Sparkling and semi-sparkling grape wines
14.2.3.3 Fortified grape wine, grape liquor wine, and sweet grape wine
14.2.4 Wines (other than grapes)
14.2.5 Mead
14.2.6 Distilled spirituous beverages containing more than 15% alcohol
14.2.7 Aromatized alcoholic beverages (e.g. beer, wine, and spirituous cooler-type beverages, low-alcoholic refreshers)

3.6 Permitted Flavors and Colors

Colors

Similar to the content outlined for food additives in Section 3.5, Permitted Additives, above.

Flavors

Mongolia’s food safety legislation does not provide specific regulations for the use of flavors in food products. However, the Law on Ensuring Safety of Food Products requires that all food ingredients, including flavors, meet general safety guidelines. These guidelines mandate compliance with international food safety standards. In practice, in the absence of explicit national regulations on flavors, those that have been evaluated and approved by internationally recognized bodies—such as the Codex Alimentarius, the European Union (EU), and the U.S. Food and Drug Administration (FDA)—are commonly accepted in Mongolia.

3.7 Permitted Processing Aids

Mongolia does not have a dedicated positive list of processing aids in its national regulations. Instead, it aligns with international standards, primarily those from the Codex Alimentarius. Mongolia likely follows the Codex Standard CXG 75-2010 Codex Guidelines on Substances Used as Processing Aids, which provides advice on the safe use and regulation of processing aids in food production [10].

3.8 Additional Notes

Product

1) Beer, 4-7% Alcohol

The sensory parameters of beer are specified in Table 3 and the physical-chemical parameters in Table 4, respectively [3].

Table 3. Sensory parameters of beer excerpted from MNS 0181:2017 [3]

No.	Indicator	Requirements
1	Taste	It has a unique taste suitable for the category. Does not contain foreign taste. Unfiltered, unsterilized beer may have a faint yeasty taste.
2	Fragrance	It has a unique fragrance suitable for the category. Does not contain external odor.
3	Clarity	Filtered beer is sparkling, clear, and free of foreign impurities, and during storage, unknown protein precipitates may form. Unfiltered beer is cloudy and has yeast sediment. The clarity of a unique beer is appropriate for its category.
4	Foam	The foam is homogeneous and dense.
5	Appearance	It has a specified amount of filling, the label is affixed correctly, it has a good appearance, and it has a strong filling.
Note: Top-fermented, unfiltered beers can change from light to dark, or dark to light, depending on the temperature.

Table 4. Physical and chemical characteristics of beer excerpted from MNS 0181:2017 [3]

No.	Classification	Initial density of the juice, %	Alcohol, % by volume	pH	Color		CO2		Foam
No.	Classification	Initial density of the juice, %	Alcohol, % by volume	pH	0.1 N iodine	by EBC-H unit	%	g/l	Thickness, mm	Stability, min
1	Pale	7-14	2-10	4.0 – 4.8	0.11-1.4	2-20		3.3-6.5	>15	2
2	Dark	11-18	2-10	4.0 – 4.8	1.5-6.1	21-60		3.3-6.5	>15	2
3	Black	11-18	2-10	4.0 – 4.8	6.3-13	Not less than 61		3.3-6.5	>15	2
4	Unique	7-30	0-25	3.0 – 5.2	-	-		3.3-6.5	>15	2
The density and alcohol content of the original peony juice can vary by ±0.3%.

2) Alcoholic ready-to-drink beverages (mainly Chuhai), 3-9% Alcohol

Ready-to-drink beverages meet the requirements specified in Table 5 for sensory characteristics and Table 6 for physico-chemical characteristics:

Table 5. Sensory parameters of ready-to-drink beverages, excerpted from MNS 5253:2003 and MNS 5984-2009 [5, 12]

No.	Indicator	Carbonated	Non-Carbonated	Fruit, Fruit-Based Cocktails
1	Taste	10-12	12-14	The product has a distinctive taste and aroma based on its raw materials and food additives. The product has a unique taste and smell suitable for its category. No external/strange taste or smell
2	Aroma	9-12	11-14
3	Color	6-8	3-4	The color depends on the raw materials; it should be clear but not completely transparent. The color matches the name of the product.
4	Carbonation	3-4	-	Carbonated low-alcohol beverages should be packaged under pressure.
5	Appearance	4-6	6-8	Should be free of sediment, evenly filled, with no floating particles, and properly sealed to prevent external contamination. It is filled to the prescribed level, the label is properly affixed, and the stopper is secure. Non-precipitated food additives can be dissolved or in physical form.
6	Total Score	32-40	32-40

Table 6. Physico-chemical characteristics of ready-to-drink beverage, excerpted from MNS 5253:2023 and MNS 5984-2009 [5, 12]

No.	Indicator, Measurement Unit	Acceptable Range
1	Ethanol Content, % by volume	2.0 – 9.0 (MNS 5253:2023) 5.0 – 12 (MNS 5984:2009) The ethanol content may vary by ±0.2% from the stated amount.
2	Total Solids Content, %	7.0 – 13.0 The dry matter content may vary by ±0.4%.
3	Acidity, g/L	1.5 – 5.0
4	Carbon Dioxide Content, % minimum (Applies to carbonated alcoholic soft drinks)	0.25
5	Amount of extract, g/100 cm³	0 – 10
6	Amount of sugar, g/100 cm³	0 – 10
7	Acidity, g/100cm³ (the amount of NaOH used to neutralize 100 ml of alcohol)	0.2 – 0.7

Note: Test methods:

Acidity, solid content, and alcohol content: "Analytical Methods for Various Types of Liquor" MNS 2117:89.
Carbon dioxide content: "Various Beverages. General Technical Requirements" MNS 687:98.

3) Whisky, around 45% Alcohol

The sensory parameters of whisky meet the requirements specified in Table 7, physical-chemical parameters in Table 8, and permissible variation of physical and chemical parameters of alcohol in Table 9, respectively.

Table 7. Sensory parameters of whisky, excerpted from MNS 5984-2009 [5]

No.	Indicator	Requirements
1	Taste and Fragrance	Product has a unique taste and smell suitable for its category. No external/strange taste or smell.
2	Color	The color matches the name of the product.
3	Appearance	It is filled to the prescribed level, the label is properly affixed, and the stopper is secure. Non-precipitated food additives can be dissolved or in physical form.

Table 8. Physical and chemical parameters of whisky, excerpted from MNS 5984-2009 [5]

Product	Food alcohol content and volume percentage	Amount of extract, g/100 cm³	Amount of sugar, g/100 cm³	Acidity, g/100cm³ (the amount of NaOH used to neutralize 100 ml of alcohol)
Whisky (Hard Liquor)	35	25	25	0 – 0.5

Table 9. Permissible variation of physical and chemical parameters of liqueurs and liqueur-type alcohols excerpted from MNS 5984-2009 [5]

No.	Indicator	Permissible variation (in the amount of extracts and sugars, g/100 cm³)
No.	Indicator	Above 30	15-30	Up to 15
1	Food alcohol content and % by volume	±0.5	±0.5	±0.5
2	Content of extracts and sugars, g/100 cm³	±0.8	±0.6	±0.3
3	Acidity, g/100cm³ (amount of NaOH used to neutralize alcohol).	±0.03	±0.03	±0.03

Testing methods [5]:

Alcohol content: "Analytical Methods for Various Types of Liquor" MNS 2117:89.
Sensory parameters: "Method for Sensory Evaluation of Food-Grade Ethyl Alcohol, Spirits, and Wine Products" GOST R 52522:2006.