JOINT FAO/WHO FOOD STANDARDS PROGRAMME CODEX COMMITTEE ON PROCESSED FRUITS AND VEGETABLES
Agenda Item 4(e) CX/PFV 04/22/8
PROPOSED DRAFT STANDARDS FOR PROCESSED FRUITS AND VEGETABLES
Standard for Soy Sauce (At Step 3 of the Procedure)
COMMENTS OF THE INTERNATIONAL ASSOCIATION OF CONSUMER FOOD ORGANIZATIONS (IAFCO)
Traditional soy sauce is made from soy beans. The key feature of this product is
fermenting or brewing, which can take three months or more, depending on the flavor and
consistency that the manufacturer wants to achieve. By contrast, so-called "soy sauce" products
made by some American companies are produced through a quicker process using inferior
ingredients hydrolyzed vegetable protein (HVP), caramel coloring, corn syrup, and various
additives. HVP consists of vegetable protein that has been chemically degraded to the amino
acids of which it is composed.
The proposed Codex standard accurately reflects this distinction by requiring the use of
descriptive terms such as "naturally brewed," "short-term brewed," "non brewed," or "mixed,"
in conjunction with the term "soy sauce." It should be the responsibility of manufacturers of
non-traditional products to inform consumers through labeling that the item that they may be
purchasing is made in a non-traditional manner. Hence, the term "non brewed" should appear on
the labels of "soy sauce" products that are not fermented.
We oppose the United States’ position that the modifiers "brewed" or "natural" be
optional. That approach would place the burden on manufacturers of traditional soy sauce to
inform consumers that their product is authentic. Further, we oppose the position of the
International Hydrolyzed Protein Council that disputes the need for any kind of standard. There
is clearly a need for a standard in this area given the sale of imitation soy sauces products. The
development of a standard is fully consistent with a key element of Codex’s mission, which is to
ensure fair practices within the food trade.
We believe that if a product purporting to be soy sauce is not produced using the
traditional method, that product should not be labeled simply as "soy sauce." Doing so would
mislead consumers. In the United States were both brewed and non-brewed products are labeled
as "soy sauce," there is evidence of significant consumer confusion. This problem should not be