SFDA: Using sulfur to fumigate roses is an illegal act

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Recently, the **Food and Drug Administration invited several experts to analyze the risks associated with roses treated with sulfur fumigation, stating that such practice is illegal. 　　**The National Medical Products Administration invited Zhang Jianbo, director of Room 3 of the Food Safety Risk Assessment Center and a researcher, Chen Fang, professor at the College of Food Science and Nutrition Engineering of China Agricultural University, Yuan Xiaomei, deputy director of the Food Quality Supervision and Inspection Center and a professor-level engineer, and Cao Yanping, professor at the School of Food Science of Beijing Technology and Business University, to provide insights on the issue of roses treated with sulfur fumigation. 　　Sulfur is a food additive permitted for use in China, and it has functions such as bleaching and preserving foods. According to China’s \"Food Safety Standards – Standards for the Use of Food Additives\" GB2760-2014, sulfur is permitted for use in food categories such as dried fruits, preserved and candied fruits, dried vegetables, fresh edible mushrooms and algae that have undergone surface treatment, sugar, and konjac flour. Food that has been fumigated with sulfur is allowed to have a certain level of residual sulfur dioxide, with the levels of this residue in such food ranging from 100 mg/kg to 900 mg/kg. 　　However, roses fall under the category of tea products (including flavored teas and substitute teas) in the GB2760 food classification system, and according to the regulations, sulfur is not allowed to be used for fumigation in such products. Fumigating roses with sulfur constitutes illegal use of food additives, and regulatory authorities should step up oversight. However, it must also be taken into account that sulfur is one of the elements found in nature, and roses, as a food product, may contain certain levels of sulfur dioxide residues originating from either the roses themselves or their environment. Therefore, it is necessary to conduct supervision and oversight during the production process to determine whether there is any illegal use of food additives. 　　At the same time, the aforementioned experts noted that whether used as a medicinal material or a food ingredient, roses have corresponding standards that specify limits on sulfur dioxide content. According to the 2010 supplement to the Pharmacopoeia of the People’s Republic of China, except for 11 traditional Chinese medicinal materials (Chinese yam, achyranthes root, pueraria root, asparagus root, gastrodia tuber, kansui root, trichosanthes root, bletilla striata, white peony root, atractylodes macrocephala, and codonopsis pilosula) which must be fumigated with sulfur dioxide during processing, with residual levels not exceeding 400 mg/kg, for other traditional Chinese medicinal materials and herbal slices that have not been fumigated but for which background levels exist, the specified limit for sulfur dioxide residues is 150 mg/kg. FAO/WHO also stipulates that the sulfur dioxide residue in herbs and spices shall not exceed 150 mg/kg; therefore, if roses are used as medicinal materials, they must meet this limit of 150 mg/kg. Furthermore, although sulfur fumigation is not allowed during the processing of roses used as food, due to the presence of sulfur dioxide in roses from natural sources, the industry has established the standard \"Industry Standard for Substitutive Teas of the People’s Republic of China\" GH/T 1091-2014, which stipulates that the sulfur dioxide content in roses used as substitutive teas should not exceed 100 mg/kg. At present, there is no unified **standard** for determining the sulfur dioxide content in rose tea used as a substitute tea. 　　Whether sulfur dioxide can cause harm to the human body depends on the amount consumed. Whether sulfur or sulfites are used as food additives in foods, they ultimately end up present in the foods as residual sulfur dioxide, and the human body absorbs sulfur dioxide by consuming foods containing such residual sulfur dioxide. Once sulfur dioxide enters the body, it is converted into sulfites, which are then oxidized to sulfates by sulfite oxidase in tissue cells. After normal detoxification processes, these sulfates are excreted from the body through urine; therefore, a small amount of sulfur dioxide entering the body can be considered safe and harmless. 　　If consumed in excess, sulfur dioxide can damage the digestive and respiratory tracts, impair the mucous membranes of these organs, and cause gastrointestinal symptoms such as nausea and vomiting. Prolonged excessive intake can cause chronic poisoning, impair the activity of enzymes in the body, and affect calcium absorption. From a production perspective, using sulfur to dry roses results in a lightening of their color as well as an odor of sulfur dioxide; subsequent steps are required to remove this odor and add fragrance. This will increase the cost of fraud significantly. However, if there is evidence proving that roses were indeed fumigated with sulfur, it should be treated as the illegal use of food additives. 　　Experts recommend that (1) food production enterprises must strictly comply with relevant standards and regulations; if it is truly necessary to use unapproved food additives in the food production process, applications should be submitted through the proper channels. Food manufacturers should use food additives within the scope specified by GB2760. While ensuring the desired effects, they should minimize the amount of such additives used in foods, and provide proper labeling for them. If a company truly needs to use unapproved food additives or those not permitted for use in a particular category of foods during the food production process, it may, in accordance with the Food Safety Law and related regulations, as well as provisions such as the Measures for the Administration of New Food Additives and the Rules for the Submission and Acceptance of Applications for New Food Additives, prepare documentation on safety assessments and the necessity of such use. It must then submit an application following the established procedures, and such additives can only be used upon approval. 　　(II) Consumers should not overemphasize the visual features of products, and should make rational purchases of food. Due to functions such as bleaching possessed by food additives like sulfur dioxide, some food producers and operators overuse these additives beyond the prescribed limits and amounts in order to cater to consumers’ irrational tendency to prioritize appearance. Therefore, it is recommended that consumers consume rationally, avoiding an excessive focus on the sensory characteristics of food; instead, they should understand food ingredients and sensory quality from scientific and natural perspectives. (Responsible Editor: Zhi Yanrong)