Import and Export Rules for Citric Acid: What Traders Need to Know

May 22, 2023

Citric acid is a commonly used ingredient in various industries, including food and beverage, pharmaceuticals, and cosmetics. As the demand for citric acid continues to grow, it is essential to stay up-to-date on the constantly evolving regulations governing its trade. We will delve into the current regulatory landscape for citric acid, explore key food safety regulations and import/export rules, and provide a comprehensive guide to navigating the complex world of citric acid labeling. We will also discuss the importance of keeping up with future regulatory changes and embracing regulatory compliance as a key business strategy.

1.  Understanding the Regulatory Landscape for Citric Acid

1.1 The Importance of Compliance in Citric Acid Trade

In today's globalized world, regulatory compliance in the citric acid trade is more than just a legal necessity; it's a crucial element for maintaining a competitive edge. Non-compliance can lead to serious consequences, including:

1.  Legal implications: Violating trade regulations can lead to hefty fines, sanctions, or even a ban on future trade activities.

2.  Reputation damage: Non-compliance can tarnish your company's image and erode customer trust.

3.  Financial losses: The cost of non-compliance can be high, with potential revenue losses due to delayed or canceled shipments.

1.2 Global Regulatory Authorities and Their Role

Regulatory authorities play a pivotal role in safeguarding public health and ensuring fair trade practices. These include international bodies such as the World Trade Organization (WTO) and the Food and Agriculture Organization (FAO), as well as national organizations like the FDA in the U.S. and the CFSA in China. These entities establish and enforce regulations related to food safety, labeling, and import/export rules for citric acid and other food additives.

1.3 Citric Acid Regulations Globically

Citric acid, recognized as a safe food additive by the FDA and the European Food Safety Authority (EFSA), is subject to various regulations globally. These encompass its usage levels in different food categories, labeling requirements, and import/export rules. For instance, in the U.S., citric acid used in food must comply with the specifications outlined in the Food Chemicals Codex (FCC).

2.  Food Safety Regulations and Citric Acid

2.1 Citric acid in the food industry related regulations

Citric acid, a natural preservative, is widely used in the food industry due to its ability to extend shelf life and enhance flavor. It is found in a variety of products, including soft drinks, candies, and baked goods. However, its usage is subject to food safety regulations:

1.  Usage levels: Regulations specify the maximum levels of citric acid that can be used in different food categories.

2.  Purity requirements: The citric acid used must meet specific purity requirements to ensure it's safe for consumption.

3.  Processing and handling: Regulations also cover the handling and processing of citric acid to prevent contamination.

2.2 The International Food Standards

The Codex Alimentarius, established by the FAO and the World Health Organization, develops harmonized international food standards. These standards aim to protect consumer health and promote fair practices in the food trade. For citric acid, the Codex specifies purity standards and usage levels in various food categories.

2.3 Key Food Safety Regulations

In the U.S., the FDA regulates the use of citric acid in food under the Food Additives Amendment of 1958. In China, the CFSA oversees food safety regulations, including those related to citric acid. In the European Union, the EFSA regulates citric acid usage.

In the following sections, we will delve deeper into the regulatory scenario in key importing countries, import/export rules, and citric acid labeling requirements.

3.  The Regulatory Scenario in Key Importing Countries

3.1 Food Safety and Standards Authority of Vietnam

Vietnam's food safety regulations are overseen by the Vietnam Food Administration (VFA).    For citric acid, the VFA refers to international standards like the Codex Alimentarius.    However, Vietnam has specific labeling requirements, such as the obligation to label genetically modified food ingredients, that exporters should be aware of.

● Food Safety Law 2010

This is the primary law regulating food safety in Vietnam.    It establishes the general safety and hygiene standards for food products, including citric acid.

● Circular No. 8/2015/TT-BNNPTNT

This circular provides guidelines for food additive management, including the permitted food additives and their usage levels.

3.2 State Service of Ukraine on Food Safety

The State Service of Ukraine on Food Safety and Consumer Protection oversees Ukraine's food safety regulations. Ukraine follows the Eurasian Economic Union's technical regulations for food additives, including citric acid.

Technical Regulation on Food Additives (TR EAEU 029/2012): This regulation outlines the rules for food additives, including their usage levels, labeling, and safety assessments.

Law of Ukraine on Basic Principles and Requirements for Safety and Quality of Food Products: This law establishes the main principles for ensuring food safety and quality.

3.3 Panama's Food Safety Authority

The Panamanian Food Safety Authority (AUPSA) oversees food safety regulations in Panama. The regulations for citric acid align with international standards, but Panama has specific import requirements that exporters should be aware of.

● Executive Decree No. 157 (2006)

This decree establishes the health and safety requirements for food imports, including citric acid.

● Resolution No. 003-2006 (DGCS)

This resolution lists the permitted food additives and their maximum usage levels.

3.4 Pakistan National Accreditation Council

The Pakistan National Accreditation Council (PNAC) oversees food safety regulations in Pakistan.They follow the guidelines provided by the Codex Alimentarius for food additives, including citric acid.

Pakistan Pure Food Rules 1965: These rules regulate the standards of food, including food additives, in Pakistan.

Pakistan Standards and Quality Control Authority Act, 1996: This act sets the standards for different goods, including food products, ensuring their safety and quality.

4.  Import and Export Rules for Citric Acid

4.1 Impact of International Trade Agreements on Citric Acid Business

International trade agreements can significantly impact the citric acid business. For instance, agreements like the ASEAN-China Free Trade Area (ACFTA) and the China-Pakistan Free Trade Agreement (CPFTA) can lower tariff barriers, making citric acid exports more profitable.

4.2 Custom Duties and Taxes

Custom duties and taxes vary by country and can affect the cost of importing citric acid.    For example, in Vietnam, import duties for citric acid range from 0-5%, while in Pakistan, the customs duty is 20%.

4.3 Country-Specific Changes in Import/Export Rules

The import and export rules for citric acid vary by country and are subject to change over time. As a supplier, it is crucial to monitor these changes to ensure your business remains compliant and competitive. Here, we will discuss the most recent changes in import and export rules for citric acid in Vietnam, Ukraine, Panama, and Pakistan.

● Vietnam

In 2021, Vietnam implemented Decree No. 15/2021/ND-CP, which updated the regulations for the import of food additives, including citric acid. The decree requires that suppliers obtain a Certificate of Food Safety for their products.

Furthermore, the country has introduced a new risk-based inspection system, which may affect the time and cost of importing citric acid into Vietnam.

● Ukraine

Ukraine recently adopted a new law, "On Information for Consumers on Food Products," which came into force in 2020. This law has implications for labeling food additives, including citric acid. Suppliers must ensure their labels meet the new requirements.

Additionally, Ukraine has streamlined its customs clearance procedures, which may result in a more efficient import process for citric acid suppliers.

● Panama

Panama has updated its chemical control regulations in recent years, requiring suppliers to adhere to new standards for the storage, transportation, and handling of hazardous substances, including citric acid.

The country has also introduced a new electronic customs system, e-Tax, to streamline the customs clearance process for imported goods, including citric acid.

● Pakistan

In 2020, Pakistan introduced the "Pakistan Standards and Quality Control Authority (Food) Rules, 2020," which updated the food safety and quality requirements for food additives, including citric acid. Suppliers must ensure their products meet these new standards.

Additionally, Pakistan has recently signed several Free Trade Agreements (FTAs) and Preferential Trade Agreements (PTAs), which may impact the tariff structure and market access for citric acid suppliers.

5.  Labeling Requirements for Citric Acid

5.1 Mandatory Labeling Requirements of Vietnam

In Vietnam, citric acid, like all food additives, must meet specific labeling requirements outlined by the Ministry of Health in Decree No. 43/2017/ND-CP.

1.  Product's Name: The product's name should be written, in this case, "Citric Acid."

2.  List of Ingredients: Citric Acid, a single-ingredient product, only requires its name on the list.

3.  Country of Origin: The country where the citric acid was manufactured, i.e., China, should be indicated.

4.  Importer's Details: The name and address of the importing company in Vietnam.

5.2 Labeling According to EAEU Regulations of Ukraine

Ukraine follows the EAEU’s labeling regulations, detailed in TR EAEU 022/2011 On Food Product Marking.

1.  Product's Name

2.  Net Quantity

3.  Date of Manufacture

4.  Shelf Life

5.  Storage Conditions

6.  Name and Location of Manufacturer

7.  Name and Location of Importer

5.3 AUPSA's Labeling Guidelines of Panama

Panama's AUPSA provides guidelines for food product labeling under Decree Law 11 of 2006.

1.  Product's Name

2.  List of Ingredients

3.  Country of Origin

4.  Net Content

5.  Date of Minimum Durability or 'Use By' Date

6.  Special Conditions for Storage or Use

7.  Identification of the Lot

8.  Name or Business Name and Address of the Manufacturer, Packer, Distributor, Importer, Exporter, or Vendor

5.4 PSQCA's Labeling Requirements of Pakistan

Pakistan's PSQCA enforces labeling requirements under the PS: 3733-1999 Food Hygiene - Code of Labeling.

1.  Product's Name

2.  List of Ingredients

3.  Name and Address of Manufacturer

4.  Name and Address of Importer

5.  Net Quantity

6.  Batch Identification

7.  Date Marking

8.  Storage Instructions

Product's Name
List of Ingredients-
Country of Origin--
Net Quantity-
Date of Manufacture---
Shelf Life--
Storage Conditions--
Name & Address of Manufacturer-
Name & Address of Importer
Special Conditions for Storage or Use---
Identification of the Lot---
Batch Identification---
Date Marking---
Storage Instructions---

Please note: The "✓" symbol indicates that the requirement is mandatory in the respective country. A "-" symbol indicates that this requirement is not explicitly stated in the respective country's guidelines.

6.  Keeping Up with Regulatory Changes

6.1 Subscribing to Regulatory Update Newsletters

Staying up-to-date with the latest regulatory changes is crucial for any citric acid exporter.    Subscribing to newsletters from food regulatory agencies, such as the VFA in Vietnam or AUPSA in Panama, can help you receive timely updates.

6.2 Joining Trade Associations

Trade associations often provide their members with updates on regulatory changes that could impact their businesses. For citric acid exporters, joining a trade association like the China Chamber of Commerce for Import and Export of Medicines and Health Products could be beneficial.

6.3 Consulting with Legal Experts

Legal experts specializing in food regulations can provide in-depth insights and assist with compliance. They can help interpret complex regulations and guide import/export rules.

In conclusion, understanding the regulatory landscape for citric acid in your key markets is crucial for smooth business operations. By keeping abreast of food safety regulations, import/export rules, and labeling requirements, you can ensure your citric acid business remains compliant and profitable.

In summary, the importance of understanding and abiding by the regulations surrounding the import and export of citric acid cannot be overstated. Changes in these regulations directly impact the trading dynamics between countries. Stay tuned for more updates on regulations and industry trends.

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