. /.  WORLD TRADE  
ORGANIZATION  G/SPS/GEN/597 
10 October 2005 
 (05-4600) 
Committee on Sanitary a nd Phytosanitary Measures Original:   English 
  
 
TRADE DIFFICULTIES ENCOUNTERED IN THE EXPORT OF SRI LANKAN  
CINNAMON TO THE EUROPEAN COMMUNITIES
1 
 
Communication from Sri Lanka  
  Background 
 
1. 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 author ities have cited 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.  
2. 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 in cluded in the list of foodstuffs as at present. 
3. 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. 
Work in Codex on sulphur dioxide 
 4. Initiatives have been taken in Codex to agree to a maximum level of SO2 (500 ppm) for all 
herbs and spices including seasoning and condiment s, which should also include cinnamon.  
However, no final decision has been arrived on this  matter.  Indeed, the proposal for defining 
maximum levels of SO2 in herbs and sp ices including seasoning and condiments, is at  step 3 in the 
Codex process – suggesting that agreem ent may be some time away yet. 
5. As there are no international standards that govern  the use of SO2 in cinnamon at present, it is 
up to the individual countries to adopt their own regula tions.  It is however pertinent to mention that 
although the CAC General Standards for Food A dditives (CODEX STAN 192 – 1995 (Rev. 5 – 2004) 
states that only the food additives listed therein are permitted for use in foods, footnote 1 of the same 
document recognizes that the lack of reference to a pa rticular additive or to a particular use of an 
                                                     
 
1 Any WTO Member interested in obtaining a copy of the detailed proposal submitted by Sri Lanka to 
the WTO Secretariat may kindly approach th e Secretary of the WTO SPS Committee.   G/SPS/GEN/597 
Page 2  
 
 additive in a specific food in the General St andard as currently drafted does not imply  that the additive 
is unsafe or unsuitable for use in food. 
6. This provision in the General Standard is a cl ear demonstration that the absence of a reference 
to SO2 content in cinnamon (or for all herbs and sp ices) in the General Standards developed by Codex 
does not imply that SO2 is unsafe or unsuitable for use in food as an additive. 
7. According to this interpretation,  the mere fact that there is no international standard governing 
the use of SO2 in cinnamon does not permit the European Communities to inform the exporting 
country (Sri Lanka) that until an international standa rd is developed, Sri La nka’s exports will not be 
accommodated in its market. 
8. As per 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, both the Codex, and the European Communities itself, recogni ze maximum levels of 
SO2 content in 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  used in much larger quantities than 
cinnamon, is included in the EC list of foodstuffs and the tolerable limit of SO2 content has been 
defined as 150 mg/kg. 
Trade implications 
 
9. As the European Parliament and Council Dire ctive has not identified sulphur dioxide as a 
substance that can be present in cinnamon, the Euro pean Spice Association (ESA) is of the view that 
it would not be possible to import cinnamon from Sri Lanka into the European Communities under 
the present circumstances.  This d ecision of the ESA will drastically reduce or eliminate Sri Lanka’s 
exports to the European Communities, and may ha ve a cascading effect on other export markets. 
10. 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.  
Sri Lanka's proposal 
 
• Sri Lanka will be submitting a formal prop osal to the CAC to identify cinnamon as a 
foodstuff and to recognize SO2 as a food additive as indicated in the proposal before the Codex Commission in 2001
2 where a maximum level for SO2 had been identified for all 
herbs and spices including seasoning and condiments at 500 ppm.  
 
• Sri Lanka requests that the European Communitie s suspend its ban on Sri Lanka’s export of 
cinnamon containing SO2 and establish an interi m standard of 150 ppm until such time as the 
Codex develops a standard. 
 Sri Lanka is of the view that th is proposal would satisfy the EC obl igations on food safety vis-à-vis its 
own consumers and its obliga tions under Articles 5.5 and 10.1 of the SPS Agreement. 
 
__________ 
 
 
                                                     
 
2 Report of the 33rd Session of the Codex Committee of Food Additives and Contaminants (Alinorm 
01/12A), page 144.