Guidelines for Food Safety???تعليمات بخصوص سلامة الاغذيه المستورده

I recently received the attached document, produced by the Ministry of Trade in Baghdad, from the Kurdistan Regional Government. These are Guidelines for Food Safety Regulations and itemise those products that should not be imported and/or those substances which, if present in a food product, render it unfit for import/consumption in Iraq. These guidelines if flowed will have serious implications for food imports into Kurdistan.

There are 69 separate items listed in the document but the translation from the Arabic is not good and the result is a poor description of the item and the majority of the text can be interpreted in more than one way as shown by the examples below:-

·        no. 2:  refers to ‘tea source’ but no further explanation

·        no. 6: ‘prohibited fresh fish’  - what species of fish, what origin of fish? We call know that most fish on sale here comes from outside Iraq.

·        no.18:  ‘Sun-up’ presumably syrup/ juice but incorrect spelling and reason for ban is?

·        no.29 and 30: refer to ‘lifting ban on red meat’, from USA?, no details

·        no. 43: tree seedlings cannot be imported unless the government imports them but no reference to species

·        no.50: ‘all expired drugs and foods’

·        no.63: refers to poultry imports stating that all chickens, eggs etc from countries with Avian Influenza must not be imported, including that from Iran. (Most of the poultry products entering Kurdistan come from Iran!)

In addition the first page lists food additives that are to be banned. Each additive is listed by its European Food Additive Number (or E number) and various reasons are given for the banning of the product. As each additive is referred to only by its number it is necessary to refer to EU legislation to identify the additive, its uses in food and to discover any health problems related to that additive. Some of the additives listed here have indeed been banned for use by EU food agencies e.g. E103, E105, E126, E128, E130, E152, E181, E206, E217, E231, E232, E233, E272, E374, E422 and E430 yet the remainder remain in use

 Some of these substances have been shown to generate undesirable side effects in some people especially if consumed in large amounts but are still regarded as safe. An example is E420, which is sorbitol, a naturally occurring sweet substance found in various fruits and used to produce food and drinks that contain less sugar (sucrose) and are therefore suitable for diabetics or for people who need to reduce their body weight. On this document E420 is listed as being produced from pigs yet sorbitol is produced by the breakdown of starch! E330 is citric acid, E334 is tartaric acid both naturally occurring substances present in normal diets. E251 and E252 are respectively sodium and potassium nitrates and these salts are used in the preservation of substances such as cooked meats. Indeed these salts can lead to raised blood pressure if eaten in excess and the same can be said of sodium chloride which we all know as normal table and cooking salt. E463, E464 and E465 are products that contain cellulose and are used as thickening agents in food processing and here these compounds are identified as causing a cholesterol related problem. Cellulose is the fibrous carbohydrate that makes the cell walls of plants and forms the fibre in our diet. We are encouraged to eat fibre in our diets to reduce cholesterol levels these additives are some of the substances investigated in research into cholesterol control in humans.

Some of the confusion with regard to food additives comes from the wealth of information available from scientific research but also from the many internet sites where individuals put forward their own, non scientific based, viewpoints on what we should or should not eat.  However it seems that further confusion comes from individuals who question the source of food additives and whether substances are Halal or Haram.