WORLD TRADE  
ORGANIZATION   
G/SPS/N/CAN/574 
14 December 2011  
 (11-6475) 
Committee on Sanitary and Phytosanitary Measures Original:   English/ 
 French 
 
 
NOTIFICATION 
 
1. Notifying Member:  CANADA 
If applicable, name of local government involved:    
2. Agency responsible:  Health Canada 
3. Products covered (provide tariff item numbe r(s) as specified in national schedules 
deposited with the WTO;  ICS numbers should be provided in addition, where applicable):  Calcium acid pyrophosphate in st andardized baking powder and 
unstandardized foods, including unstandardized  bakery products (ICS Codes:  67.040, 
67.060, 67.220) 
4. Regions or countries likely to be affected, to the extent relevant or practicable: 
[X] All trading partners   
[ ] Specific regions or countries:    
5. Title of the notified document:  Information Document on Health Canada's Proposal to 
Amend the Food and Drug Regulations  to permit the use of calcium acid pyrophosphate in 
standardized baking powder and unstandardi zed foods, including unstandardized bakery 
products  Language(s):  English and French  Number of pages:  8 
6. Description of content:  This document provides informati on on Health Canada's proposal 
to amend the Food and Drug Regulations  ("Regulations") to permit the use of calcium acid 
pyrophosphate in standardized baking pow der and unstandardized foods, including 
unstandardized bakery products. 
A request has been submitted to Health Canada  to allow the food additive use of 'calcium 
acid pyrophosphate' (chemical formula CaH 2P2O7) as an acid-reacting material and 
leavening agent in standardized baking po wder and unstandardized foods, including 
unstandardized bakery products. 
Calcium acid pyrophosphate is not currently lis ted as a permitted food additive in Canada.  
However, provisions currently exist for a num ber of phosphate salts in Table X, Division 
16 of the Regulations, including two sodium phosphate salts with a similar technological 
function to that of calcium acid pyrophosphate.  Both of these permitted additives contain sodium.  Therefore, calcium acid pyrophosphate  would provide an alternative additive that 
does not contain sodium. 
Health Canada's Food Directorate has completed a safety assessment of the relevant 
information, including information provided in support of the proposed use of calcium acid 
pyrophosphate as described in the submission, and determined that there are no health or 
safety concerns with the use of this add itive in baking powder or unstandardized foods, 
including unstandardized bakery products. G/SPS/N/CAN/574 
Page 2  
 
  Calcium acid pyrophosphate would be used in unstandardized foods  and baking powder, 
and levels in the finished food would range fro m approximately 0.8 per cent to 1.5 per cent.  
However, it is considered that the maximum leve l of use of this additive can be governed in 
the Regulations by Good Manufacturing Prac tice (GMP).  The food additive listings for 
other phosphates with similar technological f unctions set a maximum use level at GMP;  
however, a need to specify a numerical limit on calcium acid pyrophosphate was not 
identified. 
Therefore, it is proposed that the Regulations be amended to permit the use of calcium acid 
pyrophosphate at levels consistent with GMP in baking powder a nd unstandardized foods 
as outlined below. 
Specifically, amendments to Table X (Food add itives that may be used as pH adjusting 
agents, acid-reacting materials and water co rrecting agents) of Division 16 would be 
required to provide for the use of calcium ac id pyrophosphate as an acid-reacting material 
and leavening agent in standardized baking powder and in unstandardized foods (which 
includes unstandardized bakery products). 
7. Objective and rationale:  [X] food safety, [ ] animal health, [ ] plant protection, 
[ ] protect humans from animal/plant pest or disease, [ ] protect territory from other damage from pests.    
8. Is there a relevant international stan dard?  If so, identify the standard:  
[X] Codex Alimentarius Commission (e.g.  title or serial number of Codex standard 
or related text) Calcium acid pyrophosphate (calcium dihydrogen diphosphate;  
INS 450 vii) is considered to be covered by the 2001 JECFA safety evaluation of 
phosphates.  Under the Codex General Standard for Food Additives (GSFA), 
provisions for specific phosphate salts in  food are defined at the food additive 
group level, i.e., 'phosphates'.  This means that any phosphate salt recognized in the 
GSFA is permitted for use in those foods  in which phosphates are allowed.  
Currently, twenty-nine phosphate salts ar e listed in the GSFA for use in many 
different foods.  Calcium acid pyrophospha te is recognized under the GSFA in 
three functional classes:  emulsifier, rais ing agent (leavening agent), and stabilizer. 
As the Codex GSFA continues to be devel oped, it is expected that additional uses 
for phosphates will be listed as there are a number of proposed uses for phosphates in a variety of foods currently at Steps 3 and 6 of the Codex Step Procedure. 
Available in English and French: 
http://www.fao.org/ag/agn/jecfa- additives/details.html?id=842   (English) 
http://www.fao.org/ag/agn/jecfa-a dditives/details.html?lang=fr&id=842   (French) 
[ ] World Organization for Animal Health (OIE) (e.g. Terrestrial or Aquatic 
Animal Health Code, chapter number)    
[ ] International Plant Protection Convention (e.g. ISPM number)    
[ ] None Does this proposed regulation conform to the relevant international standard?   
 [X] Yes   [ ] No 
 If no, describe, whenever possible, how and why it deviates from the 
international standard:     G/SPS/N/CAN/574 
 Page 3 
 
 
  9. Other relevant documents and language(s) in which these are available:  Health 
Canada's Food and Nutrition - 'Public Invol vement and Partnershi ps' Website, posted on 
3 November 2011 (available in English and French): http://www.hc-sc.gc.ca/fn-a n/consult/index-eng.php  (English) 
http://www.hc-sc.gc.ca/fn-an/consult/index-fra.php  (French)   
10. Proposed date of adoption (dd/mm/yy) :  Normally within four to five months from the 
posting of the information documen t on the Health Canada website. 
Proposed date of publication (dd/mm/yy) :    
11. Proposed date of entry into force:  [ ] Six months from date of publication , and/or  
(dd/mm/yy) :  The Regulations come into force on the day on which they are adopted in the 
Canada Gazette , Part II. 
[ ] Trade facilitating measure   
12. Final date for comments:  [ ] Sixty days from the date of circulation of the notification 
and/or (dd/mm/yy) :  16 January 2012 
Agency or authority designated to handl e comments:  [ ] National Notification 
Authority, [X] National Enquiry Point.  Address, fax number and e-mail address (if 
available) of other body:    
13. Texts available from:  [ ] National Notification  Authority, [X] National Enquiry Point.  
Address, fax number and e-mail add ress (if available) of other body:   The electronic 
version of "Information Document on H ealth Canada's Proposal to Amend the Food and 
Drug Regulations  to permit the use of calcium acid pyrophosphate in standardized baking 
powder and unstandardized foods, including un standardized bakery products" can be 
downloaded at:  
"http://www.hc-sc.gc.ca/fn-an/consult/food-a dditives/calcium-acid-pyrophosphate/consult-
calcium-acid-pyrophosphate-eng.php "  (English)  
"http://www.hc-sc.gc.ca/fn-an/consult/food-a dditives/calcium-acid-pyrophosphate/consult-
calcium-acid-pyrophosphate-fra.php "  (French)