3. Compositional Aspects
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3. Compositional Aspects

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Mixture of Food Additives
Bangladesh


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 

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3.2 Raw Material Requirements

Category

Food

Raw materials or substances used in the primary production or manufacturing of foods are not clearly defined under the Bangladesh Food Act except for mentioning that the quality of the food is kept intact without using any adulterant or contaminant [1] or unless as detailed in Bangladesh standards for food products [4]. 

As for food safety regulations concerning safety parameters like contaminants, toxins, and harmful residues [2] governing the end product use, these are in place to ensure the safety of the finished product rather than the raw materials used.

Since Bangladesh followed Codex Alimentarius closely, the food additive can follow the standard of identity of each specific raw material in the monograph provided in the FAO JECFA database [3] or the specific additives standards that are found in the list of Bangladesh standards [4].

Product

Mixture of Food Additives

As an example, the standards of identity of each of the below raw materials since not stated for these food additives in the Bangladesh standards and as provided by the FAO JECFA under CODEX ALIMENTARIUS [3] are as follows:

  1. Tertiary butylhydroquinone, TBHQ (INS 319) - https://www.fao.org/food/food-safety-quality/scientific-advice/jecfa/jecfa-additives/details-simple/en/?ins_id=319
  2. Citric acid (INS 330) - https://www.fao.org/food/food-safety-quality/scientific-advice/jecfa/jecfa-additives/details-simple/en/?ins_id=330
  3. Propylene glycol (INS 1520) - https://www.fao.org/food/food-safety-quality/scientific-advice/jecfa/jecfa-additives/details-simple/en/?ins_id=1520

Vegetable oil (soybean oil) as a carrier is classified as an ingredient with the following specifications found in Bangladesh standards [4] to ensure compliance.

  1. BDS 1736:2003            Crude degummed soybean oil 
  2. BDS 1769:2014            Fortified Soybean oil (1st Revision), Amend-1, 2021

3.3 Fortification

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3.4 Other Permitted Ingredients

Category

Food

There is no positive list and any additional ingredient will need to be subject to safety and fit for human consumption assessments, etc. per the stipulated regulations.

Product

Mixture of Food Additives

Same as "Category" above.

3.5 Permitted Additives

Category

Food

There is a list of permitted additives with various functions of use stipulated in S.R.O No. 34/2017 [5] where Codex Alimentarius is taken into consideration.

The Use of Food Additives Act [5] includes a list of the positive additives that are permitted for use in food. The authorized uses of additives are listed according to the category of additives such as color, preservatives, flavor enhancer, antioxidant, stabilizer, non-nutritive agent, sweetener, acid or acidity regulator, anti-foaming agent, foaming agent, firming agent, thickener, anti-caking agent, sequestrant, gelling agent, emulsifier, bulking agent, flour treatment agent, glazing agent, humectant, raising agent, and propellant. 

The level or amount of additive to be used in food produced locally is approved by BSTI and they follow the Standards Catalogue, 2022 of BSTI [4], Codex standards, and International Organization for Standardization (ISO) standards. 

If new additives are not available in the Bangladesh Standards, then the permissible level should be based on Codex standards for food additives or other internationally approved standards.

The application of food additives is governed by two main provisions:

1. Section 23 and 27 of the Food Safety Act 2013 [1]. Section 23 prohibits the usage of any intoxicated additives or processing aids, which may cause injury or toxicity to human health in any article of food. Section 27 prohibits the use or inclusion of any additive or processing aid in violation of the maximum acceptable limit prescribed by regulations in any article of food or food ingredient.

2. Sections 3-9 of the Use of Food Additives Act 2017 [5] which permits the use of additives in food or beverages to refer to the standards prescribed in the latest version of the Codex Standard for Food Additives 192-1995 included in the Codex Alimentarius and to other internationally recognized food additives that do not cause internationally recognized poisoning.

Product

Mixture of Food Additives

As mentioned in the regulation [5], where no limits are stipulated, GSFA [3] can be followed where its uses and limits are determined based on the end product – the specified food category accordingly for the specific food additives below as an example:

1. Tertiary butylhydroquinone, TBHQ (INS 319) 20 % as an antioxidant will follow the limits as permitted in the specified food category published in the General Standard for Food Additives (GSFA) of the Codex Alimentarius Commission [3] https://www.fao.org/gsfaonline/additives/details.html?id=190  

2. Citric acid (INS 330) 10 % depending on its function whether acidity regulator, antioxidant, color retention agent, or sequestrant, will follow the limits as permitted in the specified food category published in the General Standard for Food Additives (GSFA) of the Codex Alimentarius Commission [3] - https://www.fao.org/gsfaonline/additives/details.html?id=173

3. Propylene glycol (INS 1520) 5% which has functions as a carrier, emulsifier, glazing agent, and humectant will follow the limits as permitted in the specified food category published in General Standard for Food Additives (GSFA) of the Codex Alimentarius Commission [3] - https://www.fao.org/gsfaonline/additives/details.html?id=214

4. Vegetable oil (soybean oil) as carrier 65% classified as an ingredient and following the requirements as a raw material as stated in Section 3.2 above.

3.6 Permitted Flavors and Colors 

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3.7 Permitted Processing Aids 

Category

Food

There is no permitted list of processing aids. However, the application of processing aids needs to be interpreted by referring to similar provisions as outlined in Section 3.5 above. Food additives specified under Sections 23 and 27 as defined for processing aids under the Food Safety Act 2013 [1]. 

Product

Mixture of Food Additives

Same as "Category" above.

3.8 Additional Notes 

Category

Food

None. 

Product

Mixture of Food Additives

Same as "Category" above.

3.9 References

1. The Food Safety Act, 2013

https://www.dpp.gov.bd/upload_file/gazettes/16173_23175.pdf 


2. S.R.O. No.  183 act/2017 Regulation on Food Safety (Chemical contamination, toxin and harmful residue), 2017 http://bfsa.gov.bd/sites/default/files/files/bfsa.portal.gov.bd/law/81690675_9a69_483b_8915_1fe8f6b2ddd0/Food-Safety-(Contaminants,-Toxins-and-Harmful-Residues)-Regulations,-2017.pdf


3. CODEX ALIMENTARIUS Codex General Standard for Food Additives (GSFA) Online data base

https://www.fao.org/gsfaonline/additives/index.html


4. List of Bangladesh Standards (BDS) on Agricultural and Food Products (January 2022)

https://bsti.portal.gov.bd/sites/default/files/files/bsti.portal.gov.bd/page/b5ede8e7_aff6_4651_82a4_94ee498ca073/2022-02-08-09-09-ab56f97111f7bc385f23fc48f0f1f1bb.pdf


5. S.R.O. NO. 34-act/2017 Use of Food Additives Act, 2017 (Bangladesh Gazette)

https://www.dpp.gov.bd/upload_file/gazettes/20582_55095.pdf 


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