The hottest opinions on the formulation of two new

Opinions on the formulation of two new national standards for milk by the National Standards Commission

on January 20, 2007, the author obtained the exposure draft of two new national standards for dairy products, liquid milk (liquid milk) and yogurt (yogurt), which were drafted by the national dairy standardization Center entrusted by the National Standards Commission. After carefully reading and studying the two standards, I believe that there are many defects and errors, and these problems are even enough to lead to and affect the unenforceability and the necessity of formulating the new standards. At the same time, I believe that the introduction of these two new standards has a complex background, and it is a reproduction and continuation of the "fresh food ban". Even from another level, this is a disguised "ban on fresh food". It is a new action played by the fresh food ban faction when the "fresh food ban order" was opposed and could not be implemented. The new standard binds pasteurized milk and sterilized milk together, collectively referred to as "liquid milk", and does not mention "fresh milk". On the surface, it seems fair, but in fact, it blurs the standard, confusing the attributes and differences of the two milk products, so as to achieve the purpose of eliminating fresh milk. Now we will comment on the errors or problems existing in the above two new national standards as follows:

first, it is inappropriate to replace the original national standards GB 5408.1-1999 pasteurized milk and GB 5408.2-1999 sterilized milk with liquid milk. Pasteurized milk and sterilized milk are two kinds of dairy products with different raw materials and processing technology. It is against common sense to classify them into the same standard. Moreover, according to the definition of the International Dairy Federation (IDF), liquid milk is the general term of pasteurized milk, sterilized milk and sour milk. If China adopts liquid milk, which only includes pasteurized milk and sterilized milk, as the national standard, it will make the technical standards of China's dairy industry different from foreign countries and unable to communicate with the world's dairy industry

second, the cancellation of "raw material requirements" in the standard of liquid milk is a principled error, which is not only not negative to consumers, but also extremely detrimental to the development of China's dairy industry. There is no "raw material requirement" in the dairy product standard, which means that dairy production enterprises can use some raw materials that cannot be used at will, including unqualified raw milk, milk powder, or milk that is about to expire or has expired. This will not protect the rights and interests of consumers, and the abuse of additives and the massive use of reduced milk cannot be curbed

third, "liquid milk" lacks a clear definition and concept. It is more appropriate to call liquid milk liquid milk. Liquid milk itself is not a specific variety existing as an independent body. It is just a general term for a large category of products, including pasteurized milk, ultra-high temperature sterilized milk, maintained sterilized milk, yogurt, etc. If we formulate a "virtual" standard for a non-existent product that is not a specific physical product, or implement a de facto non-existent product standard for multiple products of different product categories, there are unclear standard subjects, unreference and unenforceability

IV. the core of liquid milk is the ingredients and proportion in milk and the source of ingredients in milk. Any product must reflect these information. In particular, the source of ingredients in milk is the most important. For example, the nutritional value and quality of milk protein from fresh milk and milk powder are very different; Although reconstituted milk and fresh milk can be used in yogurt processing, their nutritional value and quality vary greatly; The above information or situation should be clearly known to consumers. When formulating national standards, enterprises should also be required to clearly indicate the following contents:

(1) the source and quantity of ingredients: first, the source and attribute of raw materials should be clear. If it is raw fresh milk, it can be directly marked with raw fresh milk and the content should be given; If it is reduced milk, it should be clearly indicated that it is water, milk powder and other ingredients, and the content should be given. The products produced by fresh milk and reduced milk should not be collectively referred to as "pure milk" in the new standard, which will erase the difference between "fresh milk" and "reduced milk". This practice is very inappropriate, because "reduced milk" has been subjected to heat treatment for more than two times, and the nutritional value is completely different

(2) sterilization method: clearly indicate whether pasteurized milk or ultra-high temperature sterilized milk. Different sterilization methods have different nutritional values. In fact, both "fresh milk" and "reduced milk" can be used to produce "pasteurized milk" and "sterilized milk", but their nutritional values are also different. The State Council's 2005 state Office Circular No. 24 has corrected the errors in the guidelines, and pasteurized milk is not allowed to use reconstituted milk. It is suggested that the state should prohibit the use of the processing method of "ultra-high temperature sterilization plus flashing". Because this processing method will inevitably destroy the flavor and nutrition of milk, forcing enterprises to use and add too much essence. In addition, this processing method will directly lead to a greater increase in ash and furosine in milk products, which is harmful to human health

v. the absence of nitrate, nitrite and other health indicators in the standard of liquid milk is a decline and relaxation of the quality requirements of raw milk sources, and has caused a lack of basic protection for the health of consumers. In order to be responsible for the health of consumers, the state has set health indicators or requirements for the control of nitrates, nitrites, etc. in the original GB 5408.1-1999 and GB 5408.2-1999 standards. Now these health indicators and requirements, these protective barriers, are cancelled, which is easy to cause consumers to distrust and drink milk products, which is very detrimental to the active consumption of milk and the cultivation of the milk consumption market. The original quality assurance threshold cannot be removed. On the contrary, it is also recommended to add detection methods for adulterated milk to the "test methods" in the standard, such as detection methods for pasteurized milk and sterilized milk mixed with fat powder, essence, glycine, hydrolyzed protein, etc

VI. the standard of liquid milk is contrary to the spirit of the notice of the State Office No. 24. In this standard, the use of "reconstituted milk" has been legalized and can be widely used. In order to be responsible for consumers and conducive to the development of China's national dairy industry, the State Council required dairy enterprises to use or not use "reconstituted milk" as little as possible in 2005, and even formulated a filing system for the use of "reconstituted milk" and implemented a "reconstituted milk" labeling system to curb the use of "reconstituted milk". However, the standard of "liquid milk" has opened up a market for "reduced milk" and provided legal support for its survival

VII. It is absolutely unacceptable to cancel the index of "perceptibility" in the standard of "liquid milk". Food (including milk products) has and relies on the characteristics of "color, aroma and taste", which are also a form of basis for consumers to judge products when purchasing products. If these sensory indicators are cancelled, on the one hand, it means that consumers have lost or reduced a form and basis for judging product quality from now on, that is, when there are some milk products that change color, taste, deterioration or special flavor, they can not be regarded as unqualified products; Secondly, some enterprises can randomly add some additives that can change the flavor, color and taste of the original milk according to this article. In this way, the quality of milk lacks basic guarantee. Canceling sensory indicators is like canceling a certain quality standard of food, because food quality standards include sensory indicators and microbial indicators

VIII. In the "yogurt" standard, fermented yogurt products are classified as sterilized and non sterilized, which has lost the characteristics of fermented yogurt, also violates the common sense of yogurt, and is very inconsistent with the relevant national standards of our country. Looking at the global dairy processing, from turning off the oil pump and power supply internationally to domestically, from the past to the present, and even in the future, there is no "post sterilization" or "re sterilization" in the production and processing of yogurt, and the fermented yogurt does not need to be re sterilized. Moreover, the standard does not specify what sterilization method and sterilization temperature to use. If some newly invented products are sterilized after fermentation now or in the future, such products can only be called by another name, and the traditional yogurt must not be stolen

IX. in the standard of liquid milk, the provision of "no preservative added" in the original sterilized milk is canceled, which means that in the future, manufacturers can legally use preservatives in milk, and the resulting consequences are a threat to the health of consumers or even a hazard. In order to be responsible for the health of consumers, it must be emphasized that preservatives should not be added or used in sterilized milk and yogurt

X. in the standard "liquid milk", it is allowed to use or add food additives and food nutrition enhancers in pure milk, which has made pure milk lose the meaning of "pure". Adding these exogenous additives to milk will lead to the original pure milk being impure, and selling things that are not pure as "pure", which is a typical consumer deception. In addition, the "pure milk" itself lacks a clear definition. For example, Mengniu uses the "flash" technology to extract 10% of the water from the milk and adds essence to the milk. Is it still "pure"? Similarly, the definition of "pure yogurt" in the standard of yogurt is also unscientific. Can it be said that yogurt is "pure" with additives and nutritional fortifiers? The words "pure milk" and "seasoned milk" appearing in Clauses 3.1 and 3.2 lack small English labels

Xi. In the new standard, for example, the upper limit of the index of some skimmed milk is set to be less than 3.1%, which is a little high. There is no obvious difference or advantage between this index and the whole milk index of 3.1%. Since there is little difference between the two, it is of little significance to set and produce skimmed milk products

XII. Abolishing the index of impurity content in seasoned milk (the content index specified in the original standard is 2ppm) is a relaxation and degradation of the quality of seasoned milk products, a reminder of the disability of the national milk industry, and will inevitably lead to the decline in the quality of such products or the lack of quality safety assurance. In addition, in the "liquid milk" standard, the impurity index in the original standard is adjusted from 2 to 0.25, which is too large. I'm afraid that most ordinary enterprises can't meet such high standard requirements. The revision of the impurity index is unreasonable, which clearly reflects that only the small interests of individual major interest groups are taken into account, and the above indicators are formulated from this perspective. For example, large enterprises producing pure milk can reduce the impurities to a very low level by using equipment such as milk purifiers due to the large scale of the industry, while the development level of dairy enterprises across the country is different, and the application of milk purifiers is not popular, More importantly, the index of impurity degree is also safe for human body within the original range. Even if it needs to be revised, it should be reviewed and approved by the Ministry of health and industry associations on the basis of extensive investigation and comprehensive balance; For seasoned milk, various additives are needed, and the number of fish will reach 812 9.9 billion tons. It is also a good practice for big interest groups to completely remove the original indicators for self-interest. The conclusion of the impurity index of seasoned milk set in the original national standard must be based on evidence, and it cannot be simply removed for the sake of an interest group

XIII. In the standard of liquid milk, there are no processing workers who set the product heating degree or some restrictions on the processing processes such as pasteurization and sterilization