Notice of Modification to the List of 
Permitted pH Adjusting Agents, Acid -
Reacting Materials and Water Correcting 
Agents  to Enable the Use of Hydrochloric 
Acid in Unstandardized Foods  
 
Notice of Modification  – Lists of Permitted Food 
Additives  
Reference Number: NOM/ADM-0163 
March 12 , 2021 
  
Notice of Modification to the List of Permitted pH Adjusting Agent s, Acid -Reacting Materials and Water Correcting Agents  to Enable 
the Use of Hydrochloric Acid in Unstandard ized Foods – Reference Number: NOM/ADM -0163| 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 Per mitted Food Additives  that are incorporated by reference in 
the MAs and published on the Canada.ca website.  A petitioner can request that Health Canada approve a 
new additive or a new condition of use for an already approved food additive by filing a food  additive 
submission with the Department's Food Directorate.  Health Canada uses this premarket approval process to 
determine whether the scientific data support the safety of food additives when used under specified 
conditions in foods sold in Canada.  
Health Canada's Food Directorate previously completed a premarket safety assessment of the use of 
hydrochloric acid as a pH adjusting agent in specific unstandardized foods1 at a maximum level consistent 
with Good Manufacturing Practice ( GMP ). Some time ago, the Food Directorate had intended to enable the 
use of hydrochloric acid in unstandardized foods more generally at a maximum level of GMP. However, the 
decision had not been implemented.   
Since the Food Directorate has not identified any  food safety concerns with enabling the use of hydrochloric 
acid as a pH adjusting agent in unstandardized foods more generally  at a maximum level consistent with 
GMP , Health Canada has  modified the List of Permitted pH Adjusting Agents, Acid -Reacting Materials and 
Water Correcting Agents  by replacing the entry  for “Bakery fillings; Flavour emulsions; Icings”, al l of which are 
unstandardized foods, in column (2) for sub -item (3) of item H.1 in the List with “Unstandardized foods”  as 
shown in the table below.  
 
Modification to the List of Permitted pH Adjusting Agents, Acid -Reacting Materials 
and Water Correcting Ag ents 
Item 
No. Column 1  
Additive  Column 2  
Permitted in or Upon  Column 3  
Maximum Level of Use and Other 
Conditions  
H.1 Hydrochloric Acid  (3) 
Unstandardized foods  (3) 
Good Manufacturing Practice  
Rationale  
Hydrochloric acid was already permitted for use as a pH adjusting agent in certain unstandardized foods at a 
maximum level consistent with GMP. The Food Directorate did not identify any food safety concerns with 
permitting this use of hydrochloric acid in unstandardized foods m ore generally.   
Therefore, Health Canada has modified sub -item (3) to item H.1 of the List of Permitted pH A djusting Agents, 
Acid -Reacting Materials and Water Correcting Agents , as shown in the table above.  
                                                             
 
1 These foods were bakery fillings, f lavour emulsions  and i cings .  
Notice of Modification to the List of Permitted pH Adjusting Agent s, Acid -Reacting Materials and Water Correcting Agents  to Enable 
the Use of Hydrochloric Acid in Unstandard ized Foods – Reference Number: NOM/ADM -0163| 3 
 Other Relevant Information  
The Food and Drug Regulations  require that food additives , such as hydrochloric acid , that do not have 
food -grade specifications set out in Part B of the Regulations meet the food -grade specifications set out in 
the most recent  edition of the  Food Chemicals Codex  or the Combined Compendium of Food Additive 
Specifications . The Food Chemicals Codex  is a compendium of standards for pur ity and identity for food 
ingredients, including food additives, published by the United S tates Pharmacopeial Convention. The 
Combined Compendium of Food Additive Specifications , which contains specifications prepared 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 March 12, 2021, the day it was published in  the List of Permitted pH 
Adjusting Agents, Acid -Reacting Materials and Water Correcting Agents .  
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 new scientific informatio n on the safety in use o f 
any permitted  food additive, including hydrochloric acid. Anyone wishing to submit new scientific 
information on the use of this additive or to submit any inquiries may do so in writing, by r egular mail or 
electronically. If you w ish to contact the Food Directorate electro nically, please use the words " Hydrochloric 
acid (NOM -0163)" 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