WORLD TRADE  
ORGANIZATION  G/SPS/W/187 
21 March 2006 
 (06-1269) 
Committee on Sanitary a nd Phytosanitary Measures Original:   English 
  
 
   
PROCEDURE TO MONITOR THE PROCESS 
OF INTERNATIONAL HARMONIZATION 
 
Submission by Sri Lanka
 
  
 In accordance with paragraph 6 of the provi sional procedure to monitor the use of 
international standards (G/SPS/11), Sri Lanka pr oposes that the Committee consider the attached 
issue.  
_______________ G/SPS/W/187 
Page 2  
 
   
PROCEDURE TO MONITOR THE PROCESS
 
OF INTERNATIONAL HARMONIZATION  
 
Submission by Sri Lanka  
 
 
Commodities affected: 
 Cinnamon 
Disease/problem/issue: 
 Sulphur dioxide used for fumigation of cinnamon 
Is international trade significantly affected 
because of this issue? 
 Yes, trade in cinnamon is affected – in the EC 
market. 
Does there currently exist an international 
standard for this disease/problem/issue with 
these commodities?  No 
If so: 
  
Briefly describe the existing standard: 
 N/A 
Is the international standard inappropriate? 
 N/A 
 
Description of how trade is affected by this i ssue and how the issue can be resolved through new 
or existing international standards:  
1. The practice of using SO2 (generated by burning elemental sulphur) for fumigation purposes 
has been applied by the cinnamon industry in Sri Lanka for many generations as an acceptable 
method for fumigation to obtain a better colour and also to protect the end-product from possible fungus and insects.  This practice does not require direct application of sulphur into cinnamon. 
2. Initiatives have been taken in Codex to agree to a maximum level of SO2 (500 ppm) for all 
herbs and spices including seasoning and condiments,  which should also include cinnamon (Alinorm 
01/12A, Appendix IV page 144 and Section 12.2).  However, no final decision has been reached on 
this matter. 
3. Based on the  chemical evaluation undertaken by the JECFA in 1998, it has been accepted that 
SO2 in acceptable quantities as a food additive does not produce any adverse effects on human health.  
Furthermore, accepted maximum levels of SO2  have  been established for other products in which it 
has been accepted for use as a food additive.  For example, dry ginger, which is a similar commodity 
to cinnamon and  where SO2 is used in much larger quantities than in cinnamon, is included in the EC 
list of foodstuffs and the tolerabl e limit of SO2 content has been defined as 150 mg/kg.  JECFA it has 
considers as safe an Average Daily Intake (ADI ) of  SO2 at 0.7 mg/kg of body weight.  As such the 
consumption of cinnamon even at the unlikely rate of ONE gramme per day, even on a daily basis, 
falls well below the permitted level of 0.7 mg/kg/  kg/b.w (with 500 ppm of SO2 being permitted in 
cinnamon).  We are seeking as a transitory measure a level of 150 ppm of residual SO2, and at this level the residual SO2 will be ONLY 0.150 mg/kg (as compared to the permitted level of 0.7 mg/kg). 
  G/SPS/W/187 
 Page 3 
 
 
  Trade implications 
4. At present, Sri Lanka is the single largest expor ter of true cinnamon in the world with well 
over 85 per cent share of the world market of cinna mon, and accounts for well over three quarters of 
global output.  The industry supports the livelihood of over 70,000 smallholder cinnamon growers in 
the southern province of Sri Lanka who have  depended on this trade for generations.  
5. In the absence of an international standard gove rning the use of SO2 in cinnamon, it is up to 
individual countries to adopt their own regulations.  Where trade problems are being encountered at 
this time is specifically with th e European Communities.  However , the guideline  provided by the 
WHO/FAO – JECFA for SO2 as indicated in paragra ph 3 above apparently has not been considered 
in the rejection of cinnamon by the EC member States. 
6.  Since July 2004, Sri Lanka has encountered problems with a number of consignments of 
"Ceylon Cinnamon" exported to the European Communities on the grounds that consignments 
contained sulphur dioxide (SO2).  The EC authoriti es have stated that this action was taken under a 
technical regulation relating to import of foodstu ffs to the European Communities contained in 
European Parliament and Council Directive No. 95/ 2/EC of 20 February 1995 and its subsequent 
amendments.  
7. According to the Directive, which covers food additives, only those food additives which 
satisfy the requirements set down therein can  be used in foodstuffs.  Appendix II  - Part B of the 
Regulation deals with sulphur dioxide (SO2) and sulphites and lists different sources of sulphur 
dioxides (E220 – E228) and the maximum tolerance levels of SO2, expressed in mg/kg or mg/l for various foodstuffs.  Certain types of herbs and spices, namely, ginger and mustard, which, like 
cinnamon, are used as food additives, are included in  the list of foodstuffs and the tolerable limits for 
SO2 content defined.  However cinnamon is not incl uded in the list of foodstuffs at present.  The 
European Spice Association (ESA) is of the view  that it would not be possible to import cinnamon 
from Sri Lanka into the European Communities under th e present circumstances.  This decision of the 
ESA will drastically reduce or eliminate Sri Lanka’s  exports to the European Communities, and may 
have a cascading effect on other export markets. 
Sri Lanka's proposal 
 
Sri Lanka has submitted a formal proposal to the Codex Alimentarius Commission (CAC) to identify 
cinnamon as a foodstuff  where SO2 could be used and to permit as an interim measure a maximum 
level of 150 ppm until such time as a standard is established by the Codex Alimentarius Commission 
based on their proposal of 500 ppm as indicated in th e Alinorm referred to above in paragraph 2.  
 Furthermore, in accordance with the 15 Nove mber 2004 Decision of the SPS Committee on the 
Monitoring Procedure (G/SPS/11/Rev.1), Sri Lanka  requests that the SPS Committee Chairman write 
to the CAC to inform the Commission of his inten tion to include this item in the annual monitoring 
report as per the decision of the SPS Committee at its session of 2 February 2006. 
__________