Q: 1. The inclusion of DHA algal oil in the Catalogue of Health Food Raw Materials (2023 Version) released on June 14, 2023, does it mean that DHA algal oil can be used as a raw material for both general food and health food?
2. Article 75 of the Food Safety Law stipulates that the raw materials listed in the catalogue of health food raw materials can only be used for the production of health food and shall not be used for the production of other foods. In this article, can "raw materials included in the catalogue of health food" be understood as "raw materials not included in the scope of ordinary food raw materials, only included in the scope of health food raw materials"?
3. On March 1, 2021, the State Administration for Market Regulation released the Interpretation of the Use Supervision of Ordinary Food Raw Materials into the Catalogue of Health Food Raw Materials, saying that the raw materials, dosage and efficacy in the catalogue of health food raw materials are one-to-one correspondence, and the raw materials, dosage and corresponding efficacy included in the catalogue of health food raw materials can only be used for the production of health food, and cannot be used for the production of other foods. If the raw materials and dosage in the catalogue of health food raw materials are added into general food, but does not claim the corresponding efficacy, it does not meet the one-to-one correspondence between the three, and can it continue to be produced and sold as general food?
A: In the Catalogue of Health Functions that Allow Health Food to be Claimed Nutrient Supplements (2023 Version), the health functions of DHA are interpreted as follows:
1. n-3 polyunsaturated fatty acids provide essential fatty acids for human body. 2. Dietary n-3 polyunsaturated fatty acids should account for 0.5% ~ 2% of total energy. 3. Help maintain healthy levels of blood lipids (triglycerides).
In general food, DHA Algal Oil has been approved as a novel food (Announcement No. 3 of 2010 of the former Ministry of Health), and its use in infant food should meet the requirements of relevant standards. The recommended dosage is ≤300mg/day (as pure DHA).
In addition, as a nutritional fortification substance, it can be used in formulated milk powder for children and maternal and cereal-based complementary foods for infants and young children. The raw materials, dosage and efficacy in the catalogue of health food raw materials are one-to-one corresponding relations.
The formulation of the catalogue of raw materials helps standardize the management of health food products and lays a good foundation for the implementation of the management system combining registration and filing. Although some ordinary food raw materials are included in the catalogue of health food raw materials, the catalogue of health food raw materials not only specifies the name of the raw materials, but also specifies the dosage of raw materials and the corresponding efficacy, therefore, the raw materials, dosage and corresponding efficacy included in the catalogue of health food raw materials can only be used for the production of health food, and cannot be used for the production of other foods.
Relevant reading
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Source: Shanghai Market Supervision Department
Note: This article is compiled by Antion. Please indicate the source for reprint.