FDA pre-announces the addition of sulfur dioxide as a food additive, the residue limit for pickled cabbage is relaxed 3-fold, and the standard for daylily remains unchanged

On the 21st, the Food and Drug Administration of the Ministry of Health and Welfare pre-announced amendments to the "Scope, Limits, and Specifications for the Use of Food Additives," adding sulfur dioxide as a food additive, maintaining the residue standard for use in daylily at 4.0 g/kg or below, while the sulfur dioxide residue limit for pickled vegetables and fermented vegetables, such as kimchi and pickled cabbage, was adjusted from 0.03 g/kg to 0.10 g/kg or below.

Pan Chih-kuan, section chief of the Food Division of the FDA under the Ministry of Health and Welfare, explained that this was because farmers' associations applied and reported that sulfur dioxide at only 0.03 g/kg was insufficient and not effective, that vegetables easily spoiled and could not be stored long, and that their color also easily changed, resulting in low consumer willingness to buy. The FDA, after a safety assessment confirmed no impact on human safety, changed the standard.

FDA: Bleaching agents inherently produce sulfur dioxide; we are merely listing the name

According to the "Scope, Limits, and Specifications for the Use of Food Additives," bleaching agents currently legal for use include potassium sulfite, sodium sulfite, sodium sulfite (anhydrous), sodium bisulfite, sodium hydrosulfite, potassium metabisulfite, potassium bisulfite, and sodium metabisulfite. These bleaching agents are used for preservation, bleaching, and brightening color, and when added to food, they undergo chemical reactions that produce sulfur dioxide.

Foods to which the above bleaching agents may be applied include dried daylily products, dried apricots, white raisins, gelatin, dehydrated vegetables, dehydrated fruits, molasses and syrup, edible cassava starch, pickled vegetables, fermented vegetables, candied fruits, shrimp, shellfish, konjac, and others.

In the past, daylily was often found to exceed the sulfur dioxide limit, and this move by the FDA was viewed by outsiders as relaxing the standard and legalizing it. Pan Chih-kuan stressed, "Listing sulfur dioxide as a food additive and sulfur dioxide exceeding the limit are two different matters." Pan said that these legally used bleaching agents, after acting, become sulfur dioxide residue in food. "Their use was already permitted by regulation, and a sulfur dioxide residue limit standard was also set, but the country had not listed sulfur dioxide in the table of food additives, while the fact is that using these sulfites produces sulfur dioxide."

Pan explained that, for daylily, the standard has not been relaxed, and the residue standard remains 4.0 g/kg or below, with the scope and limit of sulfur dioxide use the same as before.

How is sulfur dioxide used as a food additive?

Wei Jen-ting, deputy section chief of the Food Division of the FDA, also explained that, for daylily, solid sulfites were previously used, mixed with water to become sulfurous acid solution, and the daylily was soaked in the sulfurous acid solution for bleaching purposes. During the process, sulfur dioxide is produced and remains in the daylily, and the Ministry of Health and Welfare also set a sulfur dioxide residue standard.

Wei said that now that sulfur dioxide is listed as a food additive, advantage can be taken of the property that gaseous sulfur dioxide is readily soluble in water by adding sulfur dioxide to liquid to dissolve in water, a method similar to the past use of sodium sulfite, and the residue standard is also consistent with the past. No one in the country currently uses this method, but there are already international examples.

Pan further explained that according to Codex (the Codex Alimentarius Commission) and other advanced countries, such as the United States and the European Union, sulfur dioxide is listed as the name of an additive, and products imported to Taiwan also label sulfur dioxide. "We are merely listing the name of sulfur dioxide that could already be used." Pan also pointed out that these imported foods all state on their labels that sulfur dioxide is used, but because the country had not listed the name sulfur dioxide in the regulations, "products labeled with sulfur dioxide became non-compliant and could not be imported, making Taiwan inconsistent with international standards."

Farmers' associations request relaxation of the pickled cabbage standard

Regarding outside doubts about relaxing the residue standard, Pan stressed that the sulfur dioxide testing standard is consistent. For daylily, it likewise regulates the sulfur dioxide residue standard at 4.0 g/kg or below. As for pickled cabbage, kimchi, fermented vegetables, and the like, the sulfur dioxide residue limit was adjusted from 0.03 g/kg to 0.10 g/kg or below. Pan explained that this was because farmers' associations applied and reported that 0.03 g/kg was insufficient and not effective, that vegetables easily spoiled and could not be stored long, and that their color also easily changed, resulting in low consumer willingness to buy. The FDA, after a safety assessment confirmed no impact on human safety, changed the standard.

Consumers' Foundation: If you want to relax it, you must provide scientific data

However, You Kai-hsiung, chairman of the Consumers' Foundation, pointed out that the FDA made the relaxation amendment by referring to EU standards, but the consumption habits and food uses of the people of this country differ from those of other countries. "Taiwanese businesses use sulfur dioxide to increase market appeal; when food looks good, consumers are more willing to buy it, but is the situation abroad the same? Therefore, whether it is appropriate to refer to foreign standards remains open to question."

You said that in testing of commercially sold products, inspection efforts have been increased recently, and the situation of sulfur dioxide exceeding the limit has improved. "With a certain degree of improvement, relaxing the standard again means all past efforts return to the starting point."

"Even if the daylily residue standard is the same, other fermented vegetables still have their standard relaxed." You pointed out that there is still great concern about the harm of sulfur dioxide to the body. If the standard is to be relaxed, scientific verification should first be obtained and concrete scientific data provided. "It should not simply be that whatever foreign standards are, we relax accordingly." You stressed that, from the perspective of consumer food health and safety, one should think about whether these bleaching agents must be added at all, and if they must be used, the content limit should also be reduced to the lowest figure.

Physician: Not opposed to adding sulfur dioxide to the list; the key is that it must not be excessive

"The FDA is only rectifying the name of sulfur dioxide; the residue standard is basically still the same." Yen Tsung-hai, director of the Clinical Toxicology Center at Linkou Chang Gung Memorial Hospital, said he is not opposed to listing sulfur dioxide as a food additive, but sulfur dioxide residue absolutely must not be excessive.

Yen pointed out that if sulfur dioxide is excessive, people who eat the food will experience gastrointestinal irritation and nausea. At the same time, sulfur dioxide is also an allergen, and people with sensitive constitutions may trigger asthma attacks and difficulty breathing.

What does it mean that it must not be excessive? Yen explained that, according to the ADI (acceptable daily intake per person) standard for sulfur dioxide, it must not exceed 0.7 mg per kilogram of body weight per day, meaning a 60-kilogram adult must not consume more than 42 mg of sulfur dioxide in a day.

Yen said that no matter how much the residue limit is set, it must still return to scientific principles. "But from a physician's standpoint, although it is a legal food additive, I still hope businesses use less of it." The lower the residue limit set by the competent authority, the better. Many processed foods exceed the residue limit, and he hopes health authorities will strengthen inspections and gatekeeping.

However, according to the ADI (acceptable daily intake per person) standard, calculating with the daylily sulfur dioxide residue standard of 4.0 g/kg, a 60-kilogram adult would exceed the limit after eating about 10 grams of daylily. Is this standard too lax? Pan explained that a pot of daylily and pork rib soup would not contain more than 10 grams of daylily, so the public should not consume an excessive amount, and after daylily is soaked in water, the sulfur dioxide also dissolves in the water, so the content is further reduced.

Recommend soaking in water and rinsing; open the pot lid when cooking

Yen also suggested that if people worry about consuming sulfur dioxide, because the bleaching agents are water-soluble, for daylily, after buying it they can first soak it in water for half an hour, then rinse it, and after putting it in the pot they can also open the lid to let the sulfur dioxide evaporate; also, do not buy daylily with bright colors and unnatural taste.

On the 21st, the FDA pre-announced sulfur dioxide as a food additive, with a 60-day pre-announcement period to accept comments from all sectors and collect opinions. The FDA said that health authorities continuously monitor food additives in commercially sold food. If any business is found to violate the provisions of the Scope, Limits, and Specifications for the Use of Food Additives, under Article 18, Paragraph 1 of the Act Governing Food Safety and Sanitation, a fine of NT$30,000 to NT$3 million shall be imposed under Article 47 of the same Act.