Food additives, enzymes and processing aids

Differences in the lists of additives and enzymes approved by Japan and other major markets are still common. Examples of these are iodised salt, amidated pectin and TBHQ. While the EBC has seen progress in Japan’s approval of additives, the approval process still remains an obstacle,. EU and Japan should use the EPA to further strengthen the work in this field. Despite announcements that the EPA would result in faster approval times, there are still areas of improvement. Some of the usage lacks logic, such as sorbic acid in jams is OK, while if the jam is diluted (hence less sorbic acid), it is not allowed.


  • Japan should harmonise its definition of food additives to exclude processing aids which as per its definition technical function does not remain active in the product after it has been produced. Japan should ensure that standards of use in Japan are not in conflict with international standards of use, such as potassium sorbate and nutrition fortifiers.
  • Japan should also harmonise the specifications of food additives, such as purity, definition of specific food additives and size of molecules.
  • Japan should not set up unique requirements/practices for enzyme registration. An example is artificial gastric digestion data.
  • Japan should explicitly communicate why commonly used additives are not approved for use in Japan. Japan should make certain that approval times are decreased as discussed in the EPA. Currently, the consultation period can be very long.