Brussels, 16 January 2017
To: WHOM IT MAY CONCERN
Subject: GSO 05 FDS 707/2016 ‘Flavorings Permitted for Use in Foodstuffs’
The International Organization of the Flavor Industry (IOFI) represents the global flavor industry and
assists the industry in regulatory and scientific matters. IOFI has its head office in Geneva, Switzerland
and operational offices in Brussels, Belgium and Washington DC, USA. Members of IOFI are national
and regional associations of the flavor industry, as well as international companies active in the
development, production and trade of flavorings. More on the IOFI membership can be found at
www.iofi.org containing the list of IOFI member associations and companies.
In response to the WTO Notifications G/SPS/N/ARE/86, G/SPS/N/BHR/163, G/SPS/N/KWT/12,
G/SPS/N/OMN/63, G/SPS/QAT/67, G/SPS/N/SAU/218 and G/SPS/N/YEM/8, IOFI wishes to provide the
following comments and suggestions regarding the following sections of the GSO 05 FDS 707/2016
‘Flavorings Permitted for Use in Foodstuffs’:

Definitions (Section 3):
- Overall IOFI is very supportive of the alignment with the GSO 2365/2014 ‘Guidelines for the
Use of Flavorings in Food’ definitions, except for the addition of a definition for “Flavor
enhancers” (3.3).
“Flavor enhancers” are Food Additives as defined by the Codex Alimentarius ‘Class Names and
the International Numbering System for Food Additives’ (CAC/GL 36-1989) and therefore
“Flavor enhancers” should not be covered by the ‘Flavorings Permitted for Use in Foodstuffs’
standard. Moreover, as nowhere in the GSO 05 FDS 707/2016 there is any reference to flavor
enhancer use, IOFI recommends to remove the definition for Flavor enhancers from GSO 05
FDS 707/2016.
- The definition for “Flavors prepared with thermal treatment” (3.2.4) seems to be incomplete.
IOFI suggests inserting ‘with correspondingly longer times at lower temperatures, i.e. a
doubling of the heating time for each decrease of temperature by 10°C’ as follows:
Flavors prepared with thermal treatment: Are products obtained according to GMP by heating
[a mixture of components] to a temperature not exceeding 180°C for a period not exceeding
15 minutes with correspondingly longer times at lower temperatures, i.e. a doubling of the
heating time for each decrease of temperature by 10°C.

Labelling (Section 8):
IOFI noticed that this section refers to both labelling of prepackaged food containing flavorings
(8.1 and 8.2) and the labelling of the flavorings sold as such (8.3 and 8.4). Therefore, IOFI suggests
to enter a reference to GSO 2365/2014 ‘Guidelines for the Use of Flavorings in Foods’ between 8.2
and 8.3 as follows- phrase in italics to be entered:
8.2 Kind of the flavor according to what is mentioned in Item 3
Without prejudice to the labelling requirements provided in GSO 2365/2014 referenced in 2.3
the following information shall be declared on the label in Arabic of flavorings ‘sold as such’
8.3 Phrase “for food use” shall be written in case of industrial use, and mention used product
name.
8.4 Code number (if found).

Permitted flavorings (Table (3)):
All permitted flavorings appear to be listed in the Codex Alimentarius Commission (CAC/MISC 62016) List of Codex Specifications for Food Additives and/or the European Union (EU) Commission
Implementing Regulation 872/2012 adopting a list of flavoring substances. However, the list
presented in Table (3) does NOT contain the following JECFA flavoring substances listed in
CAC/MISC 6-2016: i.e. JECFA 2189, 2190 and 2192, JECFA 2194 through 2207, JECFA 2209 and
2210. These JECFA flavoring substances need to be added to Table (3) to be fully in line with
CAC/MISC 6. Moreover, the IOFI Secretariat anticipates the update of CAC/MISC 6 resulting from
the likely decision at the next Codex Committee on Food Additives meeting (CCFA 49th), which will
be held in Macao, China, 20-24 March 2017, to include flavorings evaluated at the 82nd Joint
FAO/WHO Expert Committee on Food Additives (JECFA) meeting (Geneva, 6-17 June 2016). At the
79th meeting JECFA finalized evaluations of the following flavoring substances: JECFA 2211, JECFA
2213 through 2221, JECFA 2223 through 2228, JECFA 2230 through 2233. These substances will
very likely be included in the next update of the CAC/MISC 6 after their endorsement by the Codex
Alimentarius Commission in July 2017. The enclosure to this letter provides the detailed list of
JECFA substances suggested to be included in Table (3).
The EU Commission list of flavoring substances permitted in the EU is also a dynamic list
undergoing regular updates. Table (3) has correctly addressed recent changes to the EU list, except
for the deletion of the flavoring substance 3-acetyl-2,5-dimethylthiophene (Commission
Regulation (EU) No 545/2013). Because JECFA also concluded that 3-acetylthiophene-2,5dimethylthiophene (JECFA 1051) should not be used as a flavoring agent (79th JECFA meeting) the
substance was subsequently removed from the CAC/MISC 6 as well. Likewise, it has to be removed
from Table (3).
Addressing regular modifications of the EU and the Codex CAC/MISC 6 lists point to the need for
establishing a robust mechanism for regular update of the GSO 707 to account for deletions and/or
the introduction of new flavoring substances in Table (3). Therefore, IOFI recommends the
inclusion of appropriate text in Table (3) GSO 707/2016 with the objective of inviting users of the
standard to report about errors or omissions in the Table (3) to the attention of the GSO
secretariat.
E.g. ‘Users of this Standard are invited to inform the GSO responsible secretariat about errors or
omissions in Table (3) flavorings permitted for in foodstuffs. Please provide suggested corrections
with supporting evidence to [contact details]’ to be inserted at the top or the bottom of Table (3).
ALTERNATIVELY, IOFI suggests that in lieu of published updates of the permitted list (Table (3)) to
include new flavoring substances the final GSO 707/1216 also contains a specific approval for use
of those substances that have undergone conclusive safety evaluation by the following
authoritative bodies regarding safety of flavoring substances, i.e.:
2



Flavoring substances evaluated by the Joint FAO/WHO Experts Committee on Food Additives
(JECFA) as “posing no safety concerns at current levels of intake” (Link1) and listed in the List
of Codex Specifications for Food Additives (CAC/MISC 6-2015) or published in the JECFA
Database of Flavoring Specifications (http://www.fao.org/food/food-safety-quality/scientificadvice/jecfa/jecfa-flav/en/)
Materials that have “no safety concern at estimated levels of intake as flavoring substances”
following evaluation by the European Food Safety Authority (EFSA) (Link).
Materials that are deemed to be Generally Recognized As Safe (GRAS) under conditions of
intended use as flavoring substances or approved flavoring substances by the US Food and
Drug Administration (FDA), including GRAS determinations published by the Expert Panel of
the Flavor and Extract Manufacturer’s Association of the United States (FEMA) (Link). The
FEMA GRAS program is actually the (single) source of flavoring substances that are selected
for evaluation by JECFA.
IOFI wishes to point out that many countries in the world, including Australia/New Zealand, Egypt,
South Korea, the Philippines, Mexico and many Latin American countries have adopted such an
‘approval by reference’ approach for the permitted use of flavoring substances in their food
regulations.
In order to support the ‘approval by reference’ approach, IOFI developed the so-called IOFI Global
Reference List (GRL) that is a publicly available (www.iofi.org) and open-ended ‘positive’ list of
flavoring substances used in the global trade, based on the safety evaluation outcomes from JECFA,
EFSA and FEMA. The IOFI GRL is actively maintained by the IOFI Secretariat and it serves as the
reference list for the global flavor industry.
We thank you for your kind consideration of the IOFI comments and suggestions. The IOFI Secretariat
staff remains available for further information and discussion.
Sincerely yours,
IOFI Secretariat
International Organization of the Flavor Industry
(IOFI)
Avenue des Arts, 6
1210 Brussels, Belgium
[email protected]
Tel: +32 2 214 20 50
Enclosure: Substances to be added to GSO FDS 707/2016
3
List of Substances in MISC 06 missing in GSO FDS 707/2016
Name
CAS
Sodium 3-Methyl-2-oxobutanoate
Sodium 4-Methyl-2oxopentanoate
Sodium 3-Methyl-2oxopentanoate
FL No.
Adoption
in MISC
06
631.1
08.051
2008
633.1
08.052
2008
632.1
08.093
2008
JECFA
FEMA
2-Ethoxy-3-isopropylpyrazine
72797-16-1
2129
4632
2013
Cassyrane
1-Cyclopropane¬methyl-4methoxybenzene
871465-49-5
2189
4731
-
2015
16510-27-3
2190
4759
-
2015
2,4-Nonadiene
56700-78-8
2192
4292
-
2015
4-Methyl-cis-2-pentene
691-38-3
2194
4650
-
2015
1-Nonene
124-11-8
2195
4651
-
2015
1,3,5,7-Undecatetraene
Mixture of methyl cyclohexadiene
and methylene cyclohexene
116963-97-4
2196
4652
-
2015
30640-46-1
2197
4311
-
2015
2,2,6,7Tetramethyl¬bicyclo[4.3.0]nona4,9(1)-dien- 8-ol
97866-86-9
2198
4521
-
2015
dl-Camphor
76-22-2
2199
4513
-
2015
l-Fenchone
7787-20-4
2200
4519
-
2015
2,2,6,7Tetramethyl¬bicyclo[4.3.0]nona4,9(1)-dien- 8-one
Ethyl 3-(2-hydroxyphenyl)
propanoate
97844-16-1
2201
4522
-
2015
20921-04-4
2202
4758
-
2015
3-[3-(2-Isopropyl-5methylcyclohexyl)-ureido]-butyric
acid ethyl ester
1160112-208
2203
4766
-
2015
4-Amino-5-(3-(isopropylamino)2,2-dimethyl-3- oxopropoxy)-2methylquinoline-3-carboxylic acid
1359963-680
2204
4774
-
2015
Triethylthialdine
54717-17-8
2205
4748
15.054
2015
2-Isopropyl-4-methyl-3-thiazoline
67936-13-4
2206
4767
-
2015
Myricitrin
17912-87-7
2207
4491
-
2015
1-(2,4-Dihydroxyphenyl)-3-(3hydroxy-4- methoxyphenyl)
propan-1-one
50297-39-7
2209
4764
-
2015
(−)-Matairesinol
580-72-3
2210
4762
-
2015
-
2015
2014;
2015
4-Amino-5-(3-(isopropylamino)2,2-dimethyl-3- oxopropoxy)-2methylquinoline-3-carboxylic acid
hemisulfate monohydrate salt
Nerolidol oxide
2204
1424-83-5
2137
4536
-
4
List of Substances evaluated by JECFA in 2016 (82nd meeting)
Name
Ethyl alpha-acetylcinnamate
CAS
620-80-4
JECFA
2211
FEMA
4597
Ethyl 2-hydroxy-3-phenylpropionate
15399-05-0
2213
4598
Cinnamaldehyde propyleneglycol
acetal
2-Phenylpropanal propyleneglycol
acetal
9-Decen-2-one
895950
2214
4596
67634-23-5
2215
4595
35194-30-0
2216
4706
Yuzunone
1009814-14-5
2217
4691
1,5-Octadien-3-ol
83861-74-9
2218
4732
3,5-Undecadien-2-one
68973-20-6
2219
4746
3-Methyl-5-(2,2,3-trimethylcyclopent3-en-1-yl)pent-4-en-2-ol
(±)-Cyclohexylethanol
67801-20-1
2220
4775
1193-81-3
2221
4794
beta-Angelicalactone
591-11-7
2222
4438
2-(2-Hydroxy-4-methyl-3cyclohexenyl)propionic acid gammalactone
2-(2-Hydroxyphenyl)
cyclopropanecarboxylic acid deltalactone
N1-(2,3-Dimethoxybenzyl)-N2-(2(pyridin-2-yl)ethyl) oxalamide
(R)-N-(1-Methoxy-4-methylpentan-2yl)-3,4-dimethylbenzamide
(E)-N-[2-(1,3-benzodioxol-5-yl)ethyl]3-(3,4- dimethoxyphenyl)prop-2enamide
(E)-3-Benzo[1,3]dioxol-5-yl-N,Ndiphenyl-2-propenamide
2,5-Dimethyl-3(2H)-furanone
57743-63-2
2223
4140
5617-64-1
2224
4270
FL No.
evaluated
by JECFA
2016
2016
2016
2016
07.262
2016
2016
02.194
2016
2016
2016
2016
08.006
2016
10.057
2016
2016
851670-40-1
2225
4741
851669-60-8
2226
4751
2016
2016
125187-30-6
2227
4773
1309389-73-8
2228
4788
1440-67-0
2230
4101
2,5-Dimethyl-4-ethoxy-3(2H)furanone
5-Methyl-3(2H)-furanone
65330-49-6
2231
4104
3511-32-8
2232
4176
Ethyl 2,5-dimethyl-3-oxo-4(2H)-furyl
carbonate
39156-54-2
2233
4546
2016
2016
13.119
2016
13.117
2016
2016
2016
5