Notice of Modification to the List of 
Permitted Preservatives  to Enable the 
Use of Benzoic Acid and its Salts  in 
Oyster -Flavoured Sauce  
 
Notice of Modification  – Lists of Permitted Food 
Additives  
Reference Number: NOM/ADM -0147 
May 5 , 2020 
 Notice of Modification to the  List of Permitted Preservatives  to Enable the Use of  Benzoic Acid and its Salts  in Oyster -Flavoured Sauce 
– Reference Number: NOM/A DM-0147| 2 
 Summary  
Food additives are regulated in Canada under Marketing Authorizations  (MAs) issued by the Minister of 
Health and the Food and Drug Regulations  (Regulations) . Approved food additives and their permitted 
conditions of use are set out in the Lists of Permitted Food Additives  that are incorporated by reference in 
the MAs and published on the Canada.ca website.   
Health Canada may identify the need to make changes to the Lists of Permitted Food Additives  in order to 
correct minor errors, to adjust wording in the interest of clarity, to ensure consistency in terminology, or to 
make changes that are required as a consequence of amen dments to the Regulations or emerging scientific 
developments related to the effectiveness and/or safety of an approved food additive.  
Benzoic acid and its salts , namely potassiu m benzoate and sodium benzoate, are permitted for use in 
unstandardized foods , with the exception of unstandardized preparations of meat and meat by -product 
(Division 14 ), fish and meat ( Division 21 ) and poultry meat and poultry meat by -product ( Division 22 ), at a 
maximum level of use of 1,000 ppm.   
Health Canada’s Food Directorate received a request seeking approval for the use of sodium benzoate , the 
sodium salt of benzoic acid,  as a preservative  used at a maximum level of 1,000 ppm  in oyster -flavoured 
sauce. Oyster -flavoured sauce is regulated as an unstandardized fish product in Canada , and consequently, is 
not permitted to contain either benzoic acid or salts of benzoic acid .  
The Food Directorate conducted an internal review of its files  to understand  the rationale behind the 
establishment of the above -noted exceptions where food additives are permitted for use in unstandardized 
foods , and found no scientific evidence to soundly rationalize the establishment of these exceptions. 
Therefore, Health Canada has modified Part 2 of the List of Permitted Preservatives  to extend the use of 
benzoic acid and its potassium and sodium salts by addin g the entry shown below to the L ist.  
Modification to Part 2 of the List of Permitted Preservatives   
Item 
No. Column 1  
Additive  Column 2  
Permitted in or Upon  Column 3  
Maximum Level of Use and Other 
Conditions  
B.1 Benzoic Acid  (4) 
Unstandardized oyster -flavoured 
sauce  (4) 
1,000 p.p.m.  
 
The listings for potassium benzoate  (item P.1)  and sodium benzoate  (item S.1)  in Part 2 of the List of 
Permitted Preservatives  indicate that these two additives are permitted for use in the same foods as listed for 
benzoic acid  and at a maximum level of use of 1,000 ppm, calculated as benzoic acid. Therefore, updating the 
permitted uses of benzoic acid will  as a consequence  updat e the permitted uses of  potassium and sodium 
benzoate, and the listings for the two latter additives do not need to be modified.  
Rationale  
The Food Directorate conducted an internal review of its files to understand the rationale behind the 
establishment o f the above -noted exceptions where food additives are permitted for use in unstandardized 
foods. The limited information available revealed that the above -noted exceptions were established prior to 
1964 when pre -market requirements for food additives were introduced and suggested, at the time, a Notice of Modification to the  List of Permitted Preservatives  to Enable the Use of  Benzoic Acid and its Salts  in Oyster -Flavoured Sauce 
– Reference Number: NOM/A DM-0147| 3 
 general understanding that benzoic acid and its salts are relatively ineffective as fish preservatives since fish 
are normally not sufficiently acidic for benzoic acid and its salts to exert any significant anti -microbiological 
activity.  
Emerging scientific developments have demonstra ted the effective anti -microbiological  activities of benzoic 
acid and its salts when used for the preservation of meat, poultry and fish products, and no information 
suggesting potentia l health risks from the use of benzoates in unstandardized preparations of meat and meat 
by-product, fish and meat, and poultry meat and poultry meat by -product was found.  
Therefore, the Department has enabled the requested use of sodium benzoate by modif ying the provisions 
for benzoic acid described in Part 2  of the List of Permitted Preservatives , as shown in the  above table. This 
modification will also enable the use of potassium benzoate in oyster -flavoured sauce, as described above.   
Other Relevant Information  
The Food and Drug Regulations  require that food additives such as benzoic ac id and its  potassium and 
sodium  salts  that do not have food -grade specifications set out in Part B of the Regulations meet the most 
recent food -grade specifications set out in the Food Chemicals Codex  or the Combined Compendium of Food 
Additive Specifications . The Food Chemicals C odex  is a compendium of standards for purity and identity for 
food ingredients, including food additives, published by the United St ates Pharmacopeial Convention. The 
Combined Compendium of Food Additive Specifications , which contains specifications prepar ed by the Joint 
FAO/WHO Expert Committee on Food Additives (JECFA), is published by the Food and Agriculture 
Organ ization of the United Nations.  
Implementation and Enforcement  
The above modification came into force May 5 , 2020 , the day it was published in  the List of Permitted 
Preservatives .  
The Canadian Food Inspection Agency is responsible for the enforcement of the Food and Drugs Act and its 
associated regulations with respect to foods.   
Contact Information  
Health Canada's Food Directorate is committed to reviewing any new scientific infor mation on the safety in 
use o f any food additive, including benzoic acid and its  potassium and sodium salts . Anyone wishing to 
submit new scientific information on the use of these additives  or to submit any inquiries may do so in 
writing, by r egular mail or electronically. If you wish to contact the Food Directorate electro nically, please use 
the words " Benzoic acid and its salts NOM -0147 " in the subject line of your e -mail.  
Bureau of Chemical Safety, Food Directorate  
251 Sir Frederick Banting Driveway  
Tunney’s Pasture, PL: 2202C  
Ottawa, Ontario K1A 0K9  
E-mail: hc.bcs -bipc.sc@canada.ca