I am finding it difficult to believe in your case that the chlorine dioxide is regarded as an additive, even in Japan ...... Flour yes
Clearly you are are using chlorine dioxide as a water treatment chemical not an additive.
Can you direct us to the regulations you are referencing.
Below is "food additive" definition based on Japan Food Sanitation Act ( http://www.mhlw.go.j...ives/index.html ) :
The FSA, in the first Chapter, defines ''food additive'' as
(i) substances used in or on food in the process of manufacturing food, or
(ii) substances used for the purpose of processing or preserving food.
Consequently, ''food additive'' includes both substances remaining in the final products, such as food colors and preservatives, and substances not remaining in the final products, such as microorganism control agents and filtration aids.
Regardless of whether they are from natural origin, all substances used for the above purposes are categorized as food additives in Japan
The scope of food additives referred to by the FSA is different from that defined by the Codex Alimentarius Comission (CAC). The substances given below, which are not defined by the CAC as food additives, are all categorized as food additives in Japan.
(i) Processing aids,* like infiltration-supporting agents
(ii) Vitamins, minerals, and amino acids
(iii) Flavoring agents
* Processing aid means any substance or material, not including apparatus or utensils, and not consumed as a food ingredient by itself, intentionally used in the processing of raw materials, foods or its ingredients, to fulfill a certain technological purpose during treatment or processing and which may result in the non-intentional but unavoidable presence of residues or derivatives in the final product (CAC, Procedural Manual, “Section I : Definitions for the purpose of the Codex Alimentarius”)
They classified chlorine dioxide as designated food additive ( http://www.ffcr.or.j...ist-desin.add-x )
Edited by avila muncar, 08 May 2014 - 07:55 AM.