This article was published in World Food Regulation Review, November 2022, p. 30-34.

By Christophe Leprêtre¹ (Keller and Heckman LLP)

The 6th session of the Codex alimentarius Committee on Spices and Culinary Herbs (CCSCH6), chaired by India, concluded on several important commodity standards while meeting virtually end September 2022. CCCSH6 concluded on new Codex standards on Saffron; Nutmeg; Dried Chilli Peppers and Paprika. It also revised labelling sections of several standards already published in response to endorsement question from the Codex alimentarius Committee on Food Labelling (CCFL). It also advanced its work on three other commodity standards covering (i) Small Cardamon; (ii) Turmeric; and, (iii) dried fruits and berries such as Allspice, Juniper berry, Star anise, as well as Vanilla. No other new work was identified.

The 6th session of the Codex Committee On Spices And Culinary Herbs (CCSCH6), Chaired by India, was held still in a “virtual” mode, from 26 to 30 September during five times three-hour sessions handled through Zoom and it adopted its report on October 3, 2022 also by Zoom. The session was preceded by five different virtual (ex-physical) working group help mid-December to discuss four different standards, with two sessions dedicated to chilli peppers and paprika.

SAFFRON as part of the Standard on (DRIED FLORAL PARTS)

• Main outcome

CCSCH6 agreed to forward the draft Standard for dried floral parts – saffron for its final adoption as a Codex alimentarius “commodity” standard by the forthcoming (45th) plenary session of the Codex alimentarius Commission (CAC45)². The provisions on labelling and methods of analysis are sent to CCFL and CCMAS for their respective endorsement. The USA expressed reservations on two main provisions retained in the final text but they did not express a formal reservation for its final adoption. 

• Main points of discussion

Two main (recurrent) points were discussed, one was on “Extra class”, the other one about mandatory labelling of the country of origin and the country of harvest.

Indeed, the delegation of the USA expressed its reservations for retaining an “Extra class” in the standard arguing that this provision was neither science-based nor included in major published international or national standards and that “Extra class” was not universally/internationally implemented and/or recognized and therefore the US delegation believed its inclusion would lead to confusion in trade.

The second main contentious point was on country of harvest and country of origin, which was retained as a mandatory provision in the standard put forward for final adoption. On that provision, the US delegation, supported by Jamaica and Mexico, also expressed its reservation about the mandatory nature of the provision, because it would impose an extra burden and ‘risk’ to food businesses.

In their view, providing the “Country of Origin” was easier to verify based on legal documents accompanying a given consignment, while determining the exact country of harvest for saffron, in their view, could not be scientifically verified by inspectors and thus mandatory labelling would not help in preventing food fraud. It would also create a precedent, as “country of harvest” is not defined in the Codex alimentarius. Finally, this mandatory provision would reverse the customary large companies practice in the trade of SCH, which are typically imported in bulk and need further processing before offering them for sale under their own labels as the product of the country of processing without indication of the country of harvest CCSCH6 also agreed to delete the requirements for saffron powder while adding that “Saffron powder shall be safe and suitable for human consumption and free from living insects and practically free from extraneous and foreign matter in amounts which may represent a hazard to human health.” In the meantime, CCSCH6 deleted the draft provision about the ban of use of any artificial colouring, because no food additive at all is permitted in that standard. It also added the Procedural Manual standardized text to the section on Methods of Analysis and Sampling to read “For checking the compliance with this standard, the methods of analysis and sampling contained in the Recommended Methods of Analysis and Sampling (CXS 234-1999)³ relevant to the provisions in this standard, shall be used.”

NUTMEG as part of a standard on DRIED SEEDS

• Main outcome

CCSCH6 agreed to forward the draft “Standard for Dried Seeds – Nutmeg” for its final adoption as a Codex alimentarius “commodity” standard by CAC45 and re-submit the methods of analysis to CCMAS for endorsement considering the changes that had been introduced.

• Main points of discussion

CCSH6 made significant changes in various parts of the standards, such scope (e.g., to exclude products intended for further processing); definitions (e.g., to characterize further the terms “appropriate degree of development”); styles (e.g., “broken seed” and “Ground/powdered seed” are “obtained from the seed only”); chemical characteristics (e.g., quality parameters limits are applicable “on a dry basis”; no more calcium limit); physical characteristics (e.g., two separate criteria for “Mould visible % w/w (max)” and “Insect defiled/ infested % w/w (max)” and assigning limit of 5 obtained as test result set in ISO 6577:1990 standard; extraneous fragments cover shell fragments; insects fragments provisions, despite some criticisms⁴; Methods of analysis (applicability of ISO 939 to all parameters; adding a method specific for the determination of the amount of Insect defiled/infested as well as for the criteria “off size, when sized” and “broken/ damaged” set in style “whole”).

CHILI PEPPERS AND PAPRIKA (DRIED OR DEHYDRATED)

• Main outcome

CCSCH6 agreed to forward the draft “Standard for Dried or Dehydrated Chilli Peppers and Paprika” for its final adoption as a Codex alimentarius “commodity” standard by the forthcoming CAC45 and send the provisions on labelling and methods of analysis to CCFL and CCMAS for their respective endorsement.

• Main points of discussion

While recognized that chilli peppers and paprika were produced in many parts of the world under diverse agro-climatic conditions resulting in differences in chemical and physical characteristics and that its popularity around the world created diverse expectations, 

CCSCH6 amended several parts starting with adding a reference to Capsicum species of the botanical family of Solanaceae to the product definition as well as several synonyms names with distinction between the Common name and the Trade name; noting that the Common name includes only two broad categories i.e. a) Chilli pepper or hot pepper, and b) Paprika; and for Trade names, a non-exhaustive list of varietal names for chilli pepper or hot pepper (such as Ancho, Pasilla, Habanero, Serrano, Piquin, Manzano), and naming of Paprika or Hot paprika as trade names for paprika were adeed (“poblano” reference was deleted for chilli pepper or hot pepper as it applied to fresh chilli, which is outside the scope of the standard; and for “Cayenne Pepper” (not listed), it was noted that the list of trade names was non-exhaustive).

Other amendments dealt with sections on “style”⁵; “composition”; “sizing (optional)”; “chemical requirements”⁶ ; “physical requirements”⁷; “methods of analysis”⁸ (despite the reservations raised by the Syrian Arab Republic).

SMALL CARDAMOM

• Main outcome

CCSCH6 agreed to advance the proposed draft Standard for Dried Small Cardamom at the next step for intermediate approval by CAC45 and forward the respective provisions on labelling and methods of analysis to CCFL and CCMAS for their endorsement. The draft Standard for Dried Small Cardamom will then be further worked out by an inter-session EWG, chaired by India and co-chaired by Guatemala and Iran (Islamic republic of).

• Main points of discussion

CCSCH6 renamed the standard, i.e., for “dried small cardamom” and the term ‘dehydrated’ from the scope. CCSCH6 also amended sections on “product definition”⁹, “styles”¹⁰, “composition” (editorial change), “chemical characteristics” (e.g., total ash max 9.5% style seed; AIA% max 2.5% for the style whole and max 3% for the style seed), “physical characteristics” (volatiles expressed as mL/100g on a dry basis, setting minimum of 1 and 3 mL/100g for style ‘powdered seeds’ and a footnote to the value of 1 mL/100g stating “for steam treated seeds”; count per 100 capsule for empty and malformed capsules; specific discussion for specific foreign materials such as whole insects, moulds; etc.); and “methods of analysis” (application of ISO 927).

ALLSPICE, JUNIPER BERRY, STAR ANISE, VANILLA, as part of the Standard on SPICES DERIVED FROM DRIED FRUITS AND BERRIES

• Main outcome

CCSCH6 agreed to advance the Proposed Draft Group Standard for Spices derived from Dried Fruits and Berries – Allspice, Juniper berry, and Star anise for intermediate approval by CAC45 and forward the provisions on labelling and methods of analysis to CCFL and CCMAS for their endorsement, respectively for the draft standard for spices derived from dried fruits and berries – Allspices, Juniper berry, on the one hand and Star anise on the other hand. Provisions applicable to Vanilla were returned for complete redrafting and further comments. Both will be further worked out by an inter-session EWG, led by the USA, and co-chaired by Madagascar, Mexico and India.

• Main points of discussion

CCSCH6 discussed whether Vanilla should be considered as a separate stand-alone document. CCSCH6 also discussed amendments to the group standard sections on ‘scope’ (clarifying terms used as ‘food processing’ or ‘industrial processing’); ‘description’ (addition in square brackets for further discussion a trade name ‘Vanilla Maya’ from botanical Vanilla cribiana as well as “Seeds/vanilla caviar” as a style); ‘labelling’ (reference to country of harvest as optional, but “mandatory for vanilla” pending further consideration, while recognizing this product was a high value product and buyers were influenced by the country and region of harvest); ‘methods of analysis’; ‘chemical characteristics for dried fruits and berries’¹¹; ‘physical characteristics for dried fruits and berries’¹².

TURMERIC as part of the standard on DRIED ROOTS, RHIZOMES AND BULBS

• Main outcome

CCSCH6 agreed to return the Proposed Draft Standard for Dried Roots, Rhizomes and Bulbs – Turmeric for further drafting and work out by an inter-session EWG, chaired by Iran (Islamic Republic of) and co-chaired by India, noting that the current draft was not subject to sufficient consideration and some of its provisions and associated values would need further accuracy checks.

• Main points of discussion

CCSCH6 discussed only some hot spot pieces of the draft text which resulted from the inter-session work.

In particular, it discussed sections on ‘product definition’ (proposed increased of the quality tolerance for fingers from 7 % (min) of pieces (rhizomes of length less than 15 mm and screenings or fragments) to 10% (min) with reference to ISO 5562; all transferred in the table on ‘physical characteristics’ for dried or dehydrated turmeric under “other factors”); ‘composition’ (editorial); ‘Labelling’ (‘may’ changed to ‘shall’ in section ‘8.2.3’ to refer to “Trade name, variety or cultivar shall be listed on the label”, opened question on ‘scientific name’; alignment of the non-retail container statement with the procedural manual-yet-to-be-up-dated)¹³; and ‘physical characteristics’¹⁴.

Other Business and Future Work on Spices and Culinary Herbs

CCSCH6 also agreed to forward for adoption by CAC45, the proposed amendments to the labelling provisions of non-retail containers in the eight existing spices and culinary herbs (SCH) standards and inform the Codex Committee on Food Labelling (CCFL) accordingly. That update was to add cross-reference to the newly published Codex General Standard for the Labelling of Non-Retail Containers of Foods (CXS 346, current version: 2021)¹⁵.

The USA delegation informed the Committee that they would prepare and submit a proposal for new work for a group standard for dried roots, rhizomes and bulbs and called upon Members to provide relevant trade and scientific data to facilitate the work of CCSCH.

In the meantime, the USA, as chair of the CCSCH’s WG on Updating the Template for Spices and Culinary Herbs (SCH) Standards highlighted that all the updated sections of the template had been agreed upon during a parallel virtual meeting. Main changes were agreed upon (i) “Chemical Characteristics” where maximum (max) or minimum (min) limits of the chemical parameters are indicated; and (ii) “Physical Characteristics” where columns were rearranged, grouping similar type of defects next to each other for ease of application. It was reminded that the second table on “Physical Characteristics” related to defects (e.g., foreign matter; mould damage; filth etc.) and not to the physical nature of the product such as its shape; colour; or other characteristics.

The new proposed template for SCH Standards will be discussed again at the CCSCH7, in particular to align the further standardized way of numbering these two types of “Tables” in draft and proposed draft standards on SCH.

No new work had been identified at the time of the session and therefore the next CCSCH meeting (7th) has tentatively been scheduled to be held within 18 months’ time (meaning not earlier than in April 2025), subject to confirmation by the future host country and in consultation with the CAC Secretariat.

All Codex texts elaborated by the CCSCH and currently ‘in force’ are all compiled at: https://www.fao.org/fao-who-codexalimentarius/committees/committee/related-standards/it/?committee=CCSCH 

CCSCH6 report is to be accessible at http://www.fao.org/fao-who-codexalimentarius/meetings/en/ and all CCSH6 working documents are available at: https://www.fao.org/fao-who-codexalimentarius/meetings/detail/en/?meeting=CCSCH&session=6 

The six standards discussed at CCSCH6 are currently subject to opened comments before CAC45 and are available in Circular Letters. See Circular letters CL 2022/63/OCS-SCH to CL 2022/68/OCS-SCH at: https://www.fao.org/fao-who-codexalimentarius/resources/circular-letters/en/

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¹ Food Safety Specialist, i.e., Senior Regulatory and Scientific Affairs Counsellor at Keller and Heckman LLP Brussels office.

² CAC45 is to be held mainly in person at the FAO Headquarters in Rome (Italy) from 21 to 25 November 2022 with a remote participation (via Zoom) possible for listening; while verbal interventions will be subject to an approval of the participating Members at the beginning of the CAC45. The report adoption will take place by virtual means on Monday 12 December and Tuesday 13 December 2022

³ In fact, the 2021 lastest version of CXS 234-1999 (i.e. CXS 234, current version: 2021 https://www.fao.org/fao-who-codexalimentarius/sh-proxy/en/?lnk=1&url=https%253A%252F%252Fworkspace.fao.org%252Fsites%252Fcodex%252FStandards%252FCX-S%2B234-1999%252FCXS_234e.pdf 

⁴ That is: — the values for both “insect fragments” (100/10g) and “mammalian and or other excreta” (11mg/kg) in the style “broken” were too high; (ii) the value for “insect fragments” was not consistent with the ISO 6577:1990 standard; (iii) the parameters related to insect should be grouped together; and (iv) the table should be reordered to present the parameters related to dead and live insects and insect fragments side by side.

⁵ Ground chilli pepper is the product obtained by grinding whole dried chilli with or without the placenta, seeds, calyx and stalk, and without any other added matter; Ground paprika is the product obtained by grinding whole dried paprika excluding the placenta, seeds, calyx and stalk, and without any other added matter.

⁶ Moisture: max 11% w/w (except for some varieties at max 15% in all styles). Pungency levels (SHU): were endorsed as proposed i.e. ≥900 for all styles of chilli peppers, ≤ 480 for all styles of paprika, and 480<900 for all styles of hot paprika. However, the symbol “greater than” (>) was inserted in front of the minimum values for hot paprika (> 480 <900) in order to create a clear distinction between the maximum values for pa-prika (≤ 480) and minimum values for hot paprika (> 480). Acid insoluble ash: for ground/powdered products containing anticaking agents (max 2% w/w), and up to max 3.0% in paprika and max 3.6% in hot paprika.

⁷ “insect defiled/infested” renamed into “insect damage”. Mould damage and insect damage combined value for whole chilli peppers at max 3 % (w/w). New column for “other factors” such as “5% off size max., 10% other similar varieties max, and 10% broken max” for whole chilli peppers and whole paprika and hot paprika. New provisions added for “rodent hair” (i.e. max 6 counts in 25 g) and “insect fragments” (max 50 counts in 25 g) for the two product styles. New footnote explaing that “N/A” referred to “Not applicable”, which meant currently no value could be set and it was therefore not equal to “zero”.

⁸ Method ASTA 21.3 (A chromatographic type IV method) included as the method of analysis for the provision “Pungency Scoville Heat” units. Method AOAC 945.94 included (as a visual examination type I method) for “mould damage”.

⁹ Scientific name of small cardamom added as Elettaria cardamomum (L.) Maton of the biotanical family Zin-giberaceae and new column to Table 1 for trade name “cardamom” noting that the word “cardamom” was normally used in trade to refer to small cardamom; and that this would differentiate it from large cardamom which was normally referred to as “black cardamom” in trade.

¹⁰ Pending further submission of relevant data and discussion, words “opened capsules” under style ‘whole’ and “whole capsule powder” under style ‘seed powder’ added in squared brackets.

¹¹ Endorsed all proposed values for different styles (‘whole’, ‘cut/broken’, ‘ground/powdered’) for Allspice, Juniper berry, and Star anise. Clarified that total ash, acid insoluble ash and volatiles limits were all expressed on a dry basis. For Allspice in the style ground/ powdered, the proposed limit of 8.5 % w/w (in “other factors”) needed further clarification (whether is a minimum or a maximum level). For Star anise, the acid insoluble entry for style cut/broken put in square brack-ets for further consideration. For Vanilla, endorsed all proposed values, except for the vanillin content in the style ‘whole’, all being put in square brackets for further consideration.

¹² All proposed provisions for the different styles for Allspice, Juniper berry, and Star anise were validated, except for the extraneous matter for Juniper berry in styles cut/broken, and ground/powdered; and for Star Anise in style ground/powdered; (both put in square brackets for further consideration). Proposed combined provisions for vanilla style ‘whole’, (i.e. dead whole insect; excreta mammalian; mould damage; insect defiled) put in square brackets for further consideration. Several delegations noted that the provisions “other characteristics” for Vanilla had not been included in the proposed draft standard and reaffirmed desire to have a separate standard for this product.

¹³ “The labelling of non-retail containers should be in accordance with the General Standard for the Labelling of Non-Retail Containers of Foods (CXS 346-2021).”

¹⁴ Separate provisions for “Mould visible %w/w(max)” and “Insect defiled/Infested %w/w (max)”; “Mould visible %w/w(max)” cannot be set at zero or N/A; provision for “Insect fragments, count/10g (max)” not applicable to turmeric presented in style ‘whole’ or the value for this provision should be changed from 2.5 to 3, i.e., should be expressed in whole number and not fractions; the value 2 for “Insect fragments, count/10g (max)” was set based on the ISO 5562, standard and should not be changed; new column “Other factors” in Table and transfer information from section 2.1.2 (i.e. 7 % (m/m) of pieces (rhizomes of length less than 15 mm and screenings or fragments); and 5 % (m/m) of bulbs) to this provision).

¹⁵ CXS 326 (black, white and green peppers), 327 (cumin), 328 (thyme), 342 (dried oregano), 343 (dried or dehydrated ginger), 344 (cloves), 345 (dried basil), 347 (dried or dehydrated garlic)

UPCOMING EVENT

Food Hygiene – Codex Committee (CCFH) – Upcoming 53rd Meeting

By Christophe Leprêtre Food Safety Specialist, i.e., Senior Regulatory and Scientific Affairs Counsellor at Keller and Heckman LLP

The 53rd session of the Codex alimentarius Committee on Food Hygiene (CCFH53), chaired by the USA, is expected to meet at the end November 2022 to finalize two new Guidelines on (a) the Control of Shiga Toxin-Producing Escherichia Coli (STEC) in raw beef, fresh leafy vegetables, raw milk and raw milk cheeses, and sprouts and (b) the use and reuse of water. CCFH53 will also consider discussion papers proposing the first revision of two other Codex guidelines on (i) the application of general principles of food hygiene to the control of pathogenic Vibrio spp. in seafood (CXG 73, current version: 2010) and (ii) the application of general principles of food hygiene to the control of viruses in food (CXG 79, current version: 2012). In addition, CCFH53 may consider proposals for (a) a new guidance (guideline or a code of practice) for food hygiene control measures in traditional food markets and (b) a series of possible revisions of existing texts on e.g., Campylobacter and Salmonella in Chicken Meat (current version: 2011); Listeria monocytogenes in Foods (current version: 2009); or, the Code of Hygienic Practice for Powdered Formulae for Infants and Young Children (current version: 2009), among many others. The 53rd CCFH and all its in-session physical working groups will be held in person from November 27 to December 2, for the first time since the Covid-19 worldwide outbreak spread in March 2020, while being webcasted for those still unable or unwilling to travel to California. However, the adoption of the report of the plenary session will be held virtually on December 8.

Codex texts elaborated by the CCFH and currently ‘in force’ are all compiled at https://www.fao.org/fao-who-codexalimentarius/committees/committee/related-standards/it/?committee=CCFH 

All working documents for the preparation of CCFH53 are available at https://www.fao.org/fao-who-codexalimentarius/meetings/detail/en/?meeting=CCFH&session=53