At present, China's food classification system has different food classification systems according to the needs of different professional fields. In the process of use, special attention should be paid to the fact that the same food may have different categories in different food classification systems. This article introduces China's various food classification systems, and on this basis, explains how to accurately locate food classification through examples.

　　1. Introduction to my country’s food classification system and its scope of application

　　my country's food classification system mainly includes the food classification system for food production licenses, the food classification system for food safety standards, and the food classification system in the implementation rules for food safety supervision and random inspections. The following is a detailed introduction:

　　1.1 The "Food Production License Classification Catalogue" divides food into 32 categories and specifies the subcategories and their varieties. The "Food Production License Variety List" in the "Food Production License" is filled in according to the "Food Production License Classification Catalogue". This catalogue applies to food production licenses.

　　1.2 GB 2760-2024  The food classification in the "National Food Safety Standard for the Use of Food Additives " standard adopts a grading system to divide foods into 16 major categories. The food classification system is used to define the scope of use of food additives and is only applicable to the use of this standard. If a food additive is allowed to be used in a certain food category, it is allowed to be used in all categories of food under that category, unless otherwise specified. Conversely, if a food additive is only approved for use in a subcategory, it cannot be inferred that it is also applicable to its parent food category. Therefore, when determining the food additives allowed for use in a certain food category, special attention must be paid to the hierarchical relationship between food categories.

　　1.3 Appendix A.1 Food Category (Name) Description of GB 2761-2017 "National Food Safety Standard Limits of Mycotoxins in Foods" covers 10 major categories of food, each of which is divided into several subcategories, which are in turn divided into sub-subcategories, sub-categories, etc. The food category (name) description is used to define the scope of application of the mycotoxin limit and is only applicable to this standard. When a certain mycotoxin limit is applied to a certain food category ( name ) , all categories of food within the food category ( name ) are applicable, except for special provisions.

　　1.4 Appendix A of GB 2762-2022 "National Food Safety Standard Limits of Contaminants in Foods " Food Category (Name) Description involves 22 major categories of food, each of which is divided into several subcategories, which are in turn divided into sub-subcategories, sub-categories, etc. The Food Category (Name) Description (Appendix A ) is used to define the scope of application of the contaminant limit and is only applicable to this standard. When a contaminant limit is applied to a food category (name), all categories of food within the food category (name) are applicable, unless otherwise specified.

　　1.5 Appendix A (Normative Appendix) of GB 2763-2019 "National Food Safety Standard Maximum Residue Limits of Pesticides in Foods" divides foods into 11 categories according to the source of raw materials. Food categories and measurement parts (Appendix A ) are used to define the scope of application of the maximum residue limits of pesticides and are only applicable to the use of this standard. If the maximum residue limit of pesticides is applied to a certain food category, it applies to all foods under that food category, except for special provisions.

　　1.6 Appendix D Food Category (Name) Description of GB 14880-2012 "National Food Safety Standard for the Use of Food Nutrition Fortifiers" divides food into 16 categories. D Food Category (Name) Description is used to define the scope of use of nutrition fortifiers and is only applicable to this standard. If a nutrition fortifier is allowed to be used in a certain food category (name), it is allowed to be used in all categories of food under that category, unless otherwise specified.

　　1.7 The food classification system in the National Food Safety Supervision and Sampling Implementation Rules shall be determined according to the basic standards ( GB 2760 , GB 2761 , GB 2762 , GB 2763 , GB 29921 , GB 31650 , etc.) when judging food classification. If there are other provisions in the detailed rules for various types of food, they shall be implemented in accordance with such provisions.

　　1.8 Customs HS code query, providing import and export commodity HS code query. HS code "coordination" covers the two major classification and coding systems of the Customs Cooperation Council Tariff Commodity Classification Nomenclature ( CCCN ) and the United Nations' Standard International Trade Classification ( SITC ). It is a systematic and multi-purpose international trade commodity classification system.

　　2. Progress of Revision of Food Classification Standards in my country

　　Because there is currently no unified guiding food classification system applicable to the national food safety standard system, our country is also actively promoting the establishment of a unified food classification system. In 2014 , the former National Health and Family Planning Commission initiated the standard formulation work of "Food Safety Terminology and Food Classification". In 2017 , the Food Evaluation Center and the China Food Industry Association drafted a classification system including 25 major categories of food. In 2018 , the National Food Safety Standard Review Committee internally solicited opinions on the "Food Classification System for National Food Safety Standards". However, the "Food Classification System for National Food Safety Standards" is only used as a reference for food safety risk management work, and will not replace the current classification methods in the food industry, nor will it replace the classification methods used in various food safety general standards and food safety supervision work. Therefore, food industry practitioners still need to be proficient in the various food classification systems introduced above.

　　3. Food classification determination method

　　1. Determine by definition in product standards

　　You can refer to some product standards and search by keywords, such as classification, terminology, general rules, etc. For example, "Basic Terminology of Food Industry" (GB/T 15091-1994) , "Terminology of Aquatic Product Processing" ( GB/T 36193-2018 ), "Classification of Condiments" ( GB/T 20903-2007 ), "Classification of Pastries" ( GB/T 30645-2014 ), "Classification of Soybean Foods" ( SB/T 10687-2012 ), etc., the standards have the classification, definition and scope of application of food.

　　2. Determine by product raw materials and process

　　In addition to defining and judging by the product name in the corresponding standard, food classification can also be judged in combination with main raw materials, processes and other attributes. For example, most of the food classifications in GB 2760 are based on the main raw materials of the food and combined with the processing technology. Therefore, some product categories in the food production license classification need to be searched in the GB 2760 food classification system based on the main raw materials of the food. Examples are as follows:

　　The product implementation standard is SB/T 10379 quick-frozen prepared foods, and the product category is dish products (cooked products). The production license classification of the following two products can both be 1102 quick-frozen prepared foods, but when applying the GB2760 food classification system, the judgment should be based on the raw materials and process of the products:

　　A (Boiled Pork Slices) : Ingredients: Pork (≥ 40% ), water, bean sprouts, XX , XX , spicy sauce, XX , XX …

　　B (Shredded pork with pickled mustard greens) : Ingredients: pickled mustard greens (≥ 80% ), edible salt, water, XX , XX , pork, XX , XX …

　　Although these two products have the same product category and are both cooked products, they have different raw materials. When using the GB 2760 food classification system, factors such as the raw materials and processes of the products should be considered for judgment. Product A’s main ingredient is pork, which meets the definition of 08.03 cooked meat products in the GB 2760 classification system, which refers to meat products made from fresh (frozen) livestock and poultry meat (including offal) as the main raw material, with salt, soy sauce and other condiments added, and processed through a cooking process. The sub-category should be 08.03.09 other meat products; Product B ’s main ingredient is snow vegetable, which meets the definition of 04.02.02 processed vegetables in the GB 2760 classification system, which includes vegetables processed in all other ways except for removing the skin, pre-cutting and surface treatment, and the sub-category should be 04.02.02.08 other processed vegetables. Only by accurately determining the classification of the product can additives be used in compliance with regulations.

　　3. Determine based on the method of consumption

　　Sometimes the product category cannot be accurately determined based on the raw materials and process of the product. In this case, we can comprehensively consider the way the product is consumed. For example, "mint leaves" are considered as substitute tea when consumed by soaking or boiling; they are generally considered as spices when consumed directly. When applying for a production license, mint leaves should apply for a production license category of 1404 substitute tea when used as a substitute tea, and a production license category of 0305 seasoning when used as a spice .

　　4. Examples of confusion in food classification

　　In recent years, the incidents of adding cyclamate to steamed buns have been repeatedly banned. What is the reason? According to the "Food Production License Classification Catalog", steamed buns should be classified as hot-processed pastries among pastries. According to the classification method of production license, it is easy to think that steamed buns are also pastries in the food classification system of GB 2760-2012 "National Food Safety Standard Food Additives Usage Standard", and cyclamate can be used, with a limit of 1.6 g/kg . However, this is not the case. According to the description of food classification in GB 2760 , pastries ( 07.02 ) refer to foods made with grain, oil, sugar and (or) sweeteners, eggs, etc. as the main ingredients, with appropriate amounts of auxiliary materials added, and made through processes such as modulation, molding, and cooking. Fermented flour products ( 06.03.02.03 ) refer to flour products made through fermentation, such as steamed buns, steamed bread, and flower rolls. Therefore, steamed bread does not belong to pastry products, but should be classified as fermented flour products. Therefore, steamed bread is more in line with the definition of fermented flour products, and the GB 2760 food classification description clearly gives an example that steamed bread belongs to fermented flour products. Therefore, steamed bread should be classified as "fermented flour products ( 06.03.02.03 )" and no cyclamate is allowed to be added.

　　When adding food additives to food, it is necessary to strictly follow the provisions of GB 2760 "National Food Safety Standard for the Use of Food Additives".

　　V. Summary

　　For a certain food, although there are relevant classifications in national standards, industry standards or local standards, because there may be differences in the classification in different standards, it is necessary to match the corresponding food categories according to different purposes and classification principles. That is, the use of food additives is strictly judged according to the standard categories of GB 2760 , and pollutants and biological toxins are strictly judged according to the corresponding food categories of GB 2762 and GB 2761 standards. For the application unit category of the food production license, the corresponding application unit shall be matched strictly in accordance with the provisions of the "Announcement No. 8 of 2020 of the State Administration for Market Regulation on the Revision and Publication of the Food Production License Classification Catalog" .

　　The various food classification systems are still very easy to confuse when used. When determining the food classification, we should comprehensively consider the main raw materials, processes, implementation standards, and eating methods of the product, and determine the food classification system based on the purpose of use. Therefore, given the complexity of food classification and the diversity of new product innovation, in many cases, if the classification of food cannot be determined, it is recommended to consult or listen to the opinions of national ministries, regulatory agencies, industry associations, and third-party experts.