A Food Labeling Nightmare

Food companies find it hard to comply with a rule on the listing of ingredients.  

In the food industry lexicon, a “carry-over” is a substance – either a food ingredient or a food additive – that is present in a food product only because it is a subcomponent of another ingredient. The carry-over performs no significant technological function in the final product and is often present in only minute quantities. Examples of such carry-overs are edible oil such as corn oil used as a dispersant or solvent for a food colorant, or corn starch or corn syrup used as a carrier for a food flavoring.

In other countries around the world, carry-overs do not need to be included among the ingredients listed on the label of a food product. But in another example of a unique-to-Taiwan regulation that poses hardships for multinational corporations operating in many markets, the Taiwan Food and Drug Administration (TFDA) is requiring that carry-overs be listed on product labels.

As last amended in the wake of the spate of food scandals to hit the Taiwan market in recent years, Article 22 of Taiwan’s Act Governing Food Safety and Sanitation set the principle that every ingredient in a food product must be listed on the product label. When issuing the enforcement regulations for the law, the TFDA exempted carry-overs officially classified as “food additives” from that requirement so as to simplify the process. But it did not provide the same waiver for those carry-overs that are food ingredients.

Related Story: Requiring stricter GMO Food Labeling

Companies serving the Taiwan market with processed food products made abroad are now faced with an arduous – and in some cases impossible – task. Since carry-overs do not need to be identified in the United States, the European Union, and other countries among Taiwan’s major trading partners, the original label from overseas does not contain the information the Taiwan regulations are requiring to be disclosed. In fact, the information often is not even readily available. Importers or manufacturers will have to go through a complicated and costly procedure to inquire about each minute ingredient, and sometimes the supplier will refuse to divulge the information, treating it as a trade secret.

Even if the information can be obtained, companies will have to go to the trouble and expense of preparing special labels just for this relatively small market. The process will slow down the delivery time of imported products and their availability for Taiwan consumers.

Problems are also foreseen in the customs-clearance process if Customs officials seek further documentation or explanation from foreign suppliers and local importers about the subcomponents listed among the food ingredients. Shipments may be held up as the overseas exporters scramble to provide satisfactory answers.

AmCham Taipei’s Retail Committee has called attention to Taiwan’s treatment of carry-over labeling as a potential technical barrier to trade in violation of WTO rules. The Committee urges the Taiwan government to harmonize its regulation with international practice by granting carry-over food ingredients an exemption from Article 22 requirements.

One comment

  1. Taiwan should continue to require the complete listing of carry-overs. Also, other countries should require the same. This practice benefits consumers, and is more important than relieving food businesses of the inconvenience of needing to provide full disclosure.

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