The new version of GB/T 18186 for approval no longer quotes GB 2717, what should companies do?

 

Food Partners.
com has studied the text of the "General Rules for the Quality of Brewed Soy Sauce" for approval (hereinafter referred to as GB/T18186) and found that it did not quote the GB 2717-2018 "National Food Safety Standard Soy Sauce" (hereinafter referred to as GB 2717)
.
So, some netizens may have doubts.
Is it necessary to implement GB/T 18186 without implementing GB 2717? Does the implementation of GB 2717 ignore the amino acid nitrogen index? Today we will analyze together, if the new version of GB/T 18186 that is officially released in the future no longer references GB 2717, what will the enterprise do?

 

In order to clarify this issue, let's first look at what is the national food safety standard
.

 

" Food Safety Law " Article 25 of the Food Safety Standards enforced
.
Except for food safety standards, no other mandatory food standards shall be formulated
.

 

　　This regulation clarifies the legal status of GB 2717, that is, no matter what standards the company claims to implement (recommended standards, local standards, corporate standards, group standards), whether it claims to implement GB 2717, regardless of whether the company’s product labels indicate GB 2717, The soy sauce products it produces must meet the requirements of GB 2717.
This is the principle and bottom line of the company's soy sauce production.
There is no doubt about this
.

 

　　In this way, there is no need to repeatedly quote GB 2717 in GB/T 18186
.
According to the news provided by Mac_OS_X, a netizen on the Food Partner Network Food Forum , in fact, this is a requirement that the National Standards Committee began last year
.
We think this is also based on GB 2717's mandatory status considerations
.

 

　　Can the company mark GB 2717 and GB/T 18186 on the label? If it is marked, what responsibilities and obligations should be assumed respectively? Let's analyze them separately
.

 

　　I can tell you with certainty that the labels of soy sauce products can either identify GB 2717 or GB/T 18186
.
Both of these identification methods are compliant
.
Let's analyze it in detail below
.

 

　　In the first case, GB 2717 is marked
.
According to the Food Safety Law and GB 7718 General Principles of Prepackaged Food Labeling Questions and Answers, the implementation standard for food labels can be national food safety standards
.
This means that the company's products meet the minimum requirements for food safety and have not made any commitments to its quality
.
Someone may ask, how can the product quality be guaranteed by only marking GB 2717? Don’t worry about this.
The labeling GB 2717 only clarifies the compliance requirements in terms of food safety.
GB 2717 only puts forward the minimum requirements for the minimum value of amino acid nitrogen and the total number of colonies and coliforms for soy sauce products.
Currently, the label GB is on the market.
2717 soy sauce products are also rare, most companies mark GB/T 18186
.
This shows that most companies promise consumers that their products are not only safe, but also meet certain quality requirements
.

 

　　In the second case, mark GB/T 18186
.
This shows that companies claim that their products meet higher quality requirements on the basis of safety
.
GB/T 18186 stipulates the classification and grading of soy sauce and the quality requirements in terms of sensory, total nitrogen, solids and amino acid nitrogen in different grades of soy sauce (each grade is much higher than the requirements specified in GB 2717)
.
Marking GB/T 18186 is currently the practice of most companies
.
What needs to be repeated again is that even if only GB/T 18186 is marked, soy sauce products must meet the requirements of GB 2717 and GB 2762, GB 29921 and other national food safety standards
.

 

　　Of course, in addition to these two situations, companies can also identify industry standards, local standards, corporate standards, and so on
.

 

　　At this point, the question is not over: For products with the label GB/T 18186, how to judge the quality index during random inspection? From the food sampling inspection and analysis system of the Food Partner Network, it is found that the official expressions for the sampling of amino acid nitrogen are very rigorous.
The conclusion is that "amino acid nitrogen (calculated as nitrogen) content meets the requirements of the national food safety standards, but does not meet the product labeling requirements
.
" For the total nitrogen (total nitrogen) index sampling results that do not meet the requirements of GB/T 18186, the random inspection announcements of most provincial market supervision departments directly judge the quality index as unqualified
.