draftREP24 MASe
draftREP24 MASe
draftREP24 MASe
INTRODUCTION
1. The Codex Committee on Methods of Analysis and Sampling (CCMAS) held its 43rd Session, in Budapest,
Hungary, from 14 to 18 May 2024, at the kind invitation of the Government of Hungary. The Session was
chaired by Dr Attila Nagy, Director, National Food Chain Safety Office (NFCSO) and Dr Zsuzsa Farkas, Food
Chain Data Scientist, Digital Food Institute acted as the Vice-Chairperson. The Session was attended by XX
Member countries, one Member organization and XX Observer organizations. The list of participants is
contained in Appendix I.
OPENING OF THE SESSION
2. Dr Márton Nobilis, the State Secretary of the Ministry of Agriculture of Hungary, opened the session and
extended his warmest welcome to all participants. Dr Nobilis highlighted that international food safety
standards underscored the dual mandate of Codex in protecting the health of consumers while facilitating fair
trade in food, and it was important to ensure that these standards were accessible and that they were up-to-
date. Dr Nobilis also noted that the hybrid format of this Session was an innovation that allowed delegates to
contribute to technical discussions from any location in the world.
3. Dr Haris Hajrulahovic, WHO Representative and Head of Country Office, Ms Mary Kenny, Food Safety and
Consumer Protection Officer, FAO Regional Office for Europe and Central Asia and Mr Steve Wearne,
Chairperson of the Codex Alimentarius Commission (CAC) (via video message) also addressed the
Committee.
Division of Competence
4. CCMAS43 noted the division of competence between the European Union (EU) and its Member States,
according to paragraph 5, Rule II of the Procedure of the CAC.
ADOPTION OF THE AGENDA (Agenda Item 1) 1
5. CCMAS43 adopted the Provisional Agenda as the Agenda for the Session and agreed to discuss the following
items under other business and future work (Agenda item 12), subject to the availability of time:
• The importance of harmonization of sampling and testing methods for the determination of
microplastics in foods (CRD09); and
• Areas of work for CCMAS in the future (CRD17).
MATTERS REFERRED TO THE COMMITTEE BY THE CODEX ALIMENTARIUS COMMISSION AND
OTHER SUBSIDIARY BODIES (Agenda Item 2) 2
6. The Codex Secretariat introduced the item and recalled the matters from CAC46 and the Executive Committee
of the Codex Alimentarius Commission (CCEXEC) were for information only and that the matters from the
seventh Session of the Codex Committee on Spices and Culinary Herbs (CCSCH7) had been considered by
the virtual working group (VWG) meeting on endorsement that met on 7 May 2024 and would be considered
further under Agenda item 3.
7. CCMAS43:
i. noted the matters for information referred by CAC and CCEXEC;
ii. encouraged Members and Observers to actively engage in opportunities to contribute to discussions
in CCEXEC and CAC on the Codex Strategic Plan 2026-2031 through the regional coordinators; and
iii. noted that the reply from CCSCH7 would be addressed under Agenda Item 3 (Endorsement of
methods of analysis and sampling).
ENDORSEMENT OF METHODS OF ANALYSIS PROVISIONS AND SAMPLING PLANS IN CODEX
STANDARDS (Agenda item 3) 3
8. CCMAS43 considered the recommendations on methods of analysis and sampling proposed for endorsement
and other related matters as presented in CRD02 and CRD03.
9. CCMAS43 made the following decisions which are also presented in Appendix II of the report as follows.
4 CX/MAS 24/43/3
Draft REP24/MAS 3
vi. Endorsed the Method V-8 (mould visible – cloves) as Type IV but did not endorse the ISO 927 and
requested that CCSCH should confirm whether ISO 927 would be a better Type I method. This method
had been endorsed for the same provision for certain other spices and culinary herbs (e.g. dried or
dehydrated ginger, turmeric).
Committee on Fats and Oils (CCFO28)
11. CCMAS43:
i. Endorsed or proposed revocation of methods for olive oils and olive pomace oils as recommended in
CRD03, Appendix II, Table 1 and for fish oils (calanus oil) in Table.3;
ii. Agreed to revoke methods for iron and copper currently listed in CXS234 in light of the agreed numeric
performance criteria for these elements and inclusion of example methods (CRD03, Appendix II, Table
2);
iii. Considered pending issues from the PWG and took the following decisions:
o Endorsed the ISO 660 (section 9.1) / AOACS Cd 3d-63 / COI/T.20 Doc. No. 34 (acidity, free
(acid value)) as Type I, but did not endorse the AOCS Ca 5a-as Type IV, noting that there was
no compelling reason to have a Type IV co-exist with a Type I methods;
o Noted the intervention by OIC (as also presented in CRD22) on role of OIC, their standards
development and that OIC were easily accessible and free for use;
o Requested revocation of COI/T.20/Doc.No.30 (erythrodiol + uvaol) and COI/T.20/Doc.no.8
(halogenated solvents, traces) as these methods were no longer available and revocation of
IUPAC 2.101 (relative density) as a Type I method was already listed in CXS234;
o Did not endorse the COI/T.20/Doc.No.35 (peroxide value) as a Type I method already existed
in CXS234 and CCMAS43 generally did not endorse methods that use of hazardous reagents,
such as chloroform and thus there was no compelling reason to have a Type IV co-exist with
a Type I method;
o did not endorse the AOCS Ca 6a-40 (unsaponifiable matter) as the method was not validated
for olive oil and olive pomace oils and therefore could not determine its equivalence with the
ISO 3596 | AOCS Ca 6b 53 Type I methods endorsed for this provision. It was suggested to
consider the AOCS method should data be provided in future;
o Endorsed COI/T.20/Doc.no.28 in place of COI/T.20/Doc.no.18 (wax content) as Type II; and
o Revised the commodity for the provision on wax content in CRD03, Appendix II, Table 3 to
“fish oil (calanus oil)”.
ENDORSEMENT OF SAMPLING PLAN: Codex Committee on Contaminants in Foods (CCCF17)
(Agenda item 3.11)5
Endorsement of the Sampling Plan for Methylmercury in Fish
12. CCMAS43:
i. endorsed the Sampling Plan as outlined in CX/MAS 24/43/3 Add.1 Appendix I) with a revised definition
of the “Decision Rule.”
ii. Agreed to inform CCCF
o of the revised definition of “decision rule” as follows:
The lot is accepted if the test result is less than or equal to the Codex maximum level (ML); otherwise,
the lot is rejected.
iii. integration of the numeric performance criteria for methyl mercury and total mercury in the sampling
plan into the numeric performance criteria table developed in the fish and fishery product workable
package for inclusion in CXS234 (see agenda item 4.2).
PERFORMANCE CRITERIA FOR METHODS FOR CERTAIN PROCESSED FRUITS AND VEGETABLES
(Agenda Item 3.2)6
13. CCMAS43 agreed to:
i. endorsement of the numeric performance criteria for:
o benzoic acid in jams, jellies, and marmalades, pickled cucumbers, mango chutney;
coconut milk and coconut cream;
o calcium in canned strawberries and pickled cucumbers;
o sorbates in jams, jellies, and marmalades and pickled cucumbers;
o tin in processed fruits and vegetables and table olives; and
ii. retain current methods in CXS 234 for calcium in preserved tomatoes, canned citrus fruits, certain
canned vegetables, and citrus marmalade.
MATTERS PENDING FROM CCMAS42 (Agenda Item 3.3) 7
Review of methods of analysis for contaminants: performance criteria for lead and cadmium in foods
14. CCMAS43 agreed with the suggested example methods and principles that would meet the performance
criteria for lead (Pb) and cadmium (Cd) in foods in CRD03 Appendix III and made some additions to the
example methods and corrections to the principles.
Review of methods of analysis for irradiated foods in the General Methods for the Detection of
Irradiated Foods (CXS 231-2001) and their incorporation into CXS 234
15. CCMAS43:
i. endorsed the methods in CRD03 Appendix IV for inclusion in CXS 234; and
ii. proposed to revoke General Methods for the Detection of Irradiated Foods (CXS 231-2001).
Examples of methods that can meet numeric performance criteria for aflatoxins in certain cereals and
cereal-based products including foods for infants and young children
16. CCMAS43 agreed to:
i. recommend to CCCF to include EN 17641 as an example method in the numeric performance criteria
table contained in the sampling plan for aflatoxins in certain cereals and cereal-based products
including foods for infants and young children in CXS 193 with the following footnote:
The sampling plan specifies a test portion size of 25.0 g and EN 17641 uses a test portion size of 5.0
g. No alternative method was found that meets the performance criteria, therefore EN 17641 is
included as an example method as it is the best possible method at this time. The smaller test portion
size may introduce additional variation in the test result.
ii. request CCCF to consider transferring all methods numeric performance criteria in sampling plans in
CXS193 to CXS 234 once the review of numeric performance criteria exercise in CCCF is completed.
Methods of analysis for determination of moisture content in dried milk
17. CCMAS43 agreed to develop a discussion paper on the application of the determination of moisture content
in whey powder by New Zealand, Uruguay, Brazil, IDF, Australia and the EU, to:
i. gather the full data, including outliers, from studies on determination of moisture in whey powders
according to the 102°C method and the data related with ISO 5537|IDF 26 validation and share within
the group;
ii. gather additional comparison data on determination of moisture in whey powders according to both
methods (102°C method contained in CXS 234 – Appendix III, ISO 5537|IDF 26), to be provided, and
share within the group, if it is necessary;
6 CL 2024/18-MAS; CX/MAS 24/43/3 Add.2; CX/MAS 24/43/3 Add.3 (Comments of Brazil, Colombia, Costa Rica,
Egypt, Guatemala, Guyana, Paraguay, Peru, Philippines, Saudi Arabia, Uruguay and IOC, NMKL)
7 CL 2024/08-MAS; CX/MAS 24/43/3 Add.4 rev.1 (Comments of Australia, Chile, Ecuador, Egypt, Guatemala, Iraq,
Peru, Philippines, United Arab Emirates and GOED, IOC, MoniQA Association, NMLK)
Draft REP24/MAS 5
iii. evaluate, based on this data, if the 102°C method could be exceptionally listed as Type IV for
determination of moisture in whey powders, with the note “Due to accessibility to equipment and
calibration of the method ISO 5537 | IDF 26, the method as described in Appendix III is listed as Type
IV”; and
iv. provide a recommendation for consideration by the Physical Working Group on Endorsement prior to
CCMAS44.
18. CCMAS43 agreed not to continue the consideration of the application of the determination of moisture content
in dairy permeate due to insufficient data.
Conclusion
19. CCMAS43 noted that the methods for DAGs and PPP could be recommended for use but could not be included
in CXS234 and encouraged Members/Observers to inform their counterparts at national level who would be
responsible for generation of data that these methods were the preferred methods of analysis.
20. CCMAS43 agreed to:
i. submit the methods of analysis and numeric performance criteria for sorbates, benzoic acid and
calcium for selected processed fruits and vegetables for adoption/revocation by CAC47, incorporating
them into CXS234 and the sampling plan for methylmercury in fish for adoption by CAC47 for inclusion
in the General Standard for Contaminants and Toxins in Food and Feed (CXS 193-1995) (Appendix
II, Parts 1 and 2);
ii. request CAC47 to revoke the General Methods for the Detection of Irradiated Foods (CXS 231 -2001);
iii. update CXS234 by including example methods and principles that meet the numeric performance
criteria for lead and cadmium in foods and to forward them to CAC47 for information;
iv. advise CCCF of the recommendation to include an example method that will meet the numeric
performance criteria table for determining MLs for aflatoxins in certain cereals and cereals-based
products in the related sampling plans in CXS193-1995 (see para **);
v. inform CCCF, CCFH, CCFO and CCSCH of the respective decisions taken at the session (paras xxx,
xxx, xxx) and refer relevant requests to CCSCH (para xxx);
vi. request the Codex Secretariat to issue CLs as identified in paras xxxx;
vii. develop a discussion paper on the application of the determination of moisture content in whey powder;
and
viii. re-establish the PWG on methods endorsement chaired by Australia and co-chaired by USA and
Hungary, working in English, French and Spanish, to meet immediately prior to CCMAS44 to consider
all methods of analysis and sampling submitted by Codex Committees for endorsement, including the
proposals on the workable packages: Fruit juices and Cocoa products and chocolate (see Agenda
item 4); methods deferred by this session; and any other matters referred by other Codex Committees
or submitted by Members and Observers.
REVIEW OF METHODS OF ANALYSIS IN CXS 234 (Agenda Item 4)
21. CCMAS43 recalled that the recommendations from the electronic working group (EWGs) on the three workable
packages: fats and oils, cereals, pulses and legumes; and fruit juices had been considered by the PWG on
endorsement. CCMAS43 considered the recommendations presented in CRD03.
CEREALS, PULSES AND LEGUMES WORKABLE PACKAGE (Agenda item 4.1) 8
22. CCMAS43:
i. Endorsed the methods for:
o particle size in gari and edible cassava flour;
o Colour in pearl millet flour and sorghum flour;
o Moisture in quinoa;
o Fat and crude protein in soy protein products and vegetable products.
8 CL 2024/14-MAS; CX/MAS 24/43/4; CX/MAS 24/43/4 Add.1 (Comments of Burundi, Colombia, Ecuador, Egypt,
Guatemala, Indonesia, Jamaica, Panama, Papua New Guinea, Paraguay, Peru, Philippines, Sierra Leone, ICUMSA
and USP)
Draft REP24/MAS 6
ii. Endorsed the method for protein in quinoa as Type IV, noting that the typing could be reconsidered if
more information were provided. CCMAS43 was informed that seven (7) countries had provided
validation data for ISO 1871 for determination of protein in quinoa. Based on the data, the method
could be retyped. It was explained that normally protein methods are endorsed as Type I or Type IV
and that ISO 1871 had been validated for quinoa (a pseudocereal) and the validation data was not in
question. However, to reconsider the typing, additional information would be required on the specific
chemicals used for the catalysts, the different reagents and their concentrations that were used and
what conditions for the method were used corresponding to the validation data provided. It was agreed
that a circular letter could be issued requesting the additional information for consideration by the PWG
on endorsement to determine if the method could be retyped as Type I;
iii. Did not endorse the methods for ash in sorghum flour, sorghum grains, degermed maize (corn) meal
and maize (corn) grits, durum wheat semolina ,durum wheat flour, pearl millet flour, sorghum flour,
sorghum grains, soy protein products, vegetable protein products, wheat flour, wheat protein products
including wheat gluten, whole and decorticated pearl millet grains, whole maize (corn) meal and
couscous as there was no consensus on these methods; and noted that:
o the current methods for ash for the aforementioned commodities in CXS234 would remain
unchanged; and
o further information on the intent of ashing temperatures in the relevant commodity standards,
would be needed to assist CCMAS to endorse the proposed methods or approval would be
needed to change the provisions for ash, e.g. ash at 550 oC and ash at 900 oC, to allow
endorsement of both sets of methods as Type I.
Conclusion
23. CCMAS43 agreed to:
i. submit the methods for adoption/revocation by CAC47 (Appendix II, Parts 1 and 2);
ii. request advice from CAC47 on whether CCMAS could have assistance in determining the original
intent for ashing temperature in cereals, pulses and legumes standards, and if not, whether two
provisions for ash at 550 oC and 900 oC for some commodities (i.e. CXS 152, CXS 154, CXS 155,
CXS 172, CXS 173, CXS 202) could be acceptable to allow CCMAS to endorse recommended
methods for these provisions as Type I; and
iii. request the Codex Secretariat to issue a circular letter requesting the information outlined in para. Xxx
for consideration by the PWG on endorsement.
FISH AND FISHERY PRODUCTS WORKABLE PACKAGE (Agenda item 4.2) 9
24. CCMAS43:
i. Agreed to remove methods for which there were no provisions in corresponding fish and fishery
product standards; or for which numeric performance criteria had been developed;
ii. Endorsed the methods as recommended in CRD03 Appendix VII, Table1 and took the following
decisions:
o the AOAC 920.04 and AOAC 920.03 methods for the determination of amino acid nitrogen in
fish sauce, currently listed in CXS234 were retained unchanged as no replacement methods
could be found at this stage; and
o noted that these AOAC methods determined ammoniacal nitrogen and not amino acid
nitrogen and agreed to request clarification from CCFFP for the intended use of the provision
in order to determine more appropriate methods for this provision.
Numeric Performance Criteria
i. Agreed to retain the numeric performance criteria for histamine as contained in CXS 234 unchanged
and included additional example methods and principles to the existing list that meet the numeric
performance criteria (see CRD03 Appendix VII, Table.2) As a consequence, the typed methods listed
in CXS234 were recommended for revocation;
9 CL 2024/15-MAS; CX/MAS 24/43/5; CX/MAS 24/43/5 Add.1 (Comments of Australia, Brazil, Ecuador, Egypt,
Guatemala, Indonesia, Iraq, Jamaica, Japan, Norway, Panama, Paraguay, Peru, Philippines, Sierra Leone, United
Arab Emirates and NMKL, USP)
Draft REP24/MAS 7
ii. Corrected the recover (%) in the numeric performance criteria for determination of toxin analogues by
chemical methods (biotoxins in live and raw bivalve mollusc) and included additional example methods
to the list of methods that meet the numeric performance criteria (see CRD03 Appendix VII, Table
3);and
iii. Endorsed the numeric performance criteria for sodium chloride and for salt determined as chloride and
expressed as sodium chloride and agreed with the example methods that meet the performance
criteria (see CRD03 Appendix VII, Table 4). As a consequence, the typed methods listed in CXS234
were recommended for revocation.
25. CCMAS43 noted that with these decisions work on the fish and fishery products had been concluded and
thanked Norway, chair of the EWG and members of the EWG for their contribution.
Conclusion
26. CCMAS43:
i. agreed to submit the methods of analysis and new and/or amended performance criteria for adoption
/ revocation/information by CAC47 (Appendix II, Parts 1 and 2); and
ii. to request CCFFP to clarify the intended use of the provision for amino acid nitrogen in the Standard
for Fish Sauce (CXS 302-2011).
FRUIT JUICES WORKABLE PACKAGE (Agenda item 4.3) 10
27. Germany presented this item, highlighting the inactive status of CEN/TC174 responsible for developing
methods of analysis for fruit and vegetable juices, including the 30 EN methods listed in CXS 234 and currently
only IFU methods remained available. Germany suggested re-establishing the EWG to review the methods in
the fruit juices workable package, stressing the need to: (i) decide whether to start with the remaining methods
or adopt a method performance criteria approach; (ii) remove all EN methods from the testing methods in fruits
juices; and (iii) ensure access to IFUMA/IFU methods for all EWG members to verify their accuracy and
description.
28. IFU clarified that old CEN methods listed in CXS 234 and the General Standard for Fruit Juices and Nectars
(CXS 247-2005) were no longer available, but conventional methods were similar to IFU ones. While some
isotopic methods were withdrawn, IFU agreed with CEN to publish three as IFU methods. IFU expressed their
willingness to assist the EWG in evaluating methods for fruit juice quality and authenticity.
Conclusion
29. CCMAS43 agreed to re-establish the EWG, chaired by the Germany, working in English to review the workable
package for fruit juices for consideration by CCMAS44.
30. The report of the EWG should be made available to the Codex Secretariat at least three months prior to
CCMAS44.
Other matters
31. In view of the completion of the review of the cereals, pulses and legumes and fish and fishery products
workable packages, CCMAS43 agreed to:
i. start the review of methods in the cocoa products and chocolate workable package; and
ii. establish an EWG chaired by Serbia and co-chaired by the United States of America, working in
English to review the cocoa products and chocolate workable package.
32. The report of the EWG should be made available to the Codex Secretariat at least three months prior to
CCMAS44.
10 CX/MAS 24/43/6
Draft REP24/MAS 8
11 CL 2024/16-MAS; CX/MAS 24/43/7; CX/MAS 24/43/7 Add.1 (Comments of Australia, Canada, Ecuador, Egypt,
European Union, Indonesia, Iraq, Japan, Peru, Philippines, Sierra Leone)
Draft REP24/MAS 9
ii. develop a discussion paper on the review of all sampling plan in CXS 234, to:
o determine what information should be included in CXS 234, and in the format of this
information.
iii. The discussion paper:
o will provide review current procedures for the inclusion of sampling plans in CXS 234
o consider sampling plan information that may be included in CXS234 for sampling plans that
will be developed under CXG50-2004 and sampling plans from other sources noting that
sampling plans are subject to endorsement by CCMAS prior to inclusion in CXS 234.
NUMERIC PERFORMANCE CRITERIA FOR THE DETERMINATION OF NITRATE AND NITRITE IONS IN
CERTAIN FOOD MATRICES (Agenda item 6)12
40. The United States of America, speaking also on behalf of Australia, introduced the item, highlighting the
document was prepared in response to some questions from the Codex Committee on Food Additives (CCFA).
The USA suggested considering the recommendations in the document and continuing work on the matter
due to late availability of the document and incomplete response to CCFA's questions.
41. A Member proposed re-evaluating the precision value (RSDR) (%) for nitrite in Food Category 01.6.4,
suggesting it might be 20.4 instead of 18.4 and requested further verification.
42. The Codex Secretariat explained that after multiple sessions’ discussions, CCFA51 decided to establish in-
going and residual levels for nitrates and nitrites in the General Standard for Food Additives (GSFA, CXS 192-
1995). Subsequently, CCFA52 requested CCMAS to address specific questions related to testing methods,
including development methods for determining proposed residual levels for representative provisions in dairy
(cheese), meat, and seafood. It was emphasized that the recommendations from CCMAS were crucial for
CCFA's ongoing work and that the discussion paper (CX/MAS 24/43/8) did not comprehensively address
CCFA's questions (e.g. the numeric performance criteria for methods to determine the proposed residual levels
for nitrate and nitrite).
43. CCMAS43 noted that further work was needed to respond to CCFA's questions and agreed to continue its
efforts on this matter.
Conclusion
44. CCMAS43 agreed:
i. to re-establish the EWG chaired by the USA, and co-chaired by Australia, working in English only, with
the following terms of reference:
o to establish numeric performance criteria for the determination of nitrate and nitrite ions in the
food matrices listed in CX/FA 21/52/7 Appendix 5, Annex 2 including adopted MLs in the GSFA
and the lowest proposed residual levels;
o to review the methods in CX/FA 21/52/7 Appendix 5, Annex 1 and determine if these methods
meet the numeric performance criteria established for the matrices in CX/FA 21/52/7 Appendix
5, Annex 2 for both adopted MLs in the GSFA and lowest proposed residual levels;
o to discuss if the methods determine both nitrate and nitrite ions and if so, whether the methods
detect each ion separately or only in combination; and
o to discuss if the different determination schemes (i.e. separate or combined) could have an
impact on the precision and accuracy of the methods.
ii. the report of the EWG should be made available to the Codex Secretariat at least three months before
CCMAS44; and
iii. to inform CCFA that CCMAS was continuing its work on this matter.
12 CX/MAS 24/43/8
Draft REP24/MAS 10
13 CX/MAS 24/43/9
14 Abbott M, Hayward S, Ross W, Godefroy SB, Ulberth F, Van Hengel AJ, Roberts J, Akiyama H, Popping B, Yeung
JM, Wehling P, Taylor SL, Poms RE, Delahaut P. Validation procedures for quantitative food allergen ELISA
methods: community guidance and best practices. J AOAC Int. 2010 Mar-Apr;93(2):442-50. PMID: 20480889.
15 Dr. Latimer, George W, Jr. (ed.), 'Validation Procedures for Quantitative Food Allergen ELISA Methods: Community
Guidance and Best Practices', in Dr. George W Latimer, Jr. (ed.), Official Methods of Analysis of AOAC
INTERNATIONAL, 22nd Edition (New York, 2023; online edn, AOAC Publications, 4 Jan. 2023).
16 EN 17855:2024(Main) Foodstuffs - Minimum performance requirements for quantitative measurement of the food
allergens milk, egg, peanut, hazelnut, almond, walnut, cashew, pecan nut, brazil nut, pistachio nut, macadamia nut,
wheat, lupine, sesame, mustard, soy, celery, fish, molluscs and crustaceans.
17 REP23/MAS, para. 17
Draft REP24/MAS 11
HARMONIZATION OF NAMES AND FORMAT FOR PRINCIPLES IDENTIFIED IN CXS 234 (Agenda item
8)18
51. Brazil introduced the item and recalled the lack of consistency in determining what information should be
captured in the principles outlined in CXS 234. Consequently, CCMAS42 decided that Brazil would prepare a
discussion paper to consider harmonization of the name and format for the principles and provision names
identified in the CXS 234.
52. To guide the work, Brazil suggested that the name of the principle reflects only descriptions of techniques
directly relevant to determining the test result. The techniques used for sample preparation, extraction and
separation, for example, would not be included as they are already specified within the method and thus not
considered part of the principle name . In preparing the discussion paper it was realised that some definitions
were needed regarding descriptions of the analytical methods (e.g. colorimetric, sensory, etc.) to help in future
work on this topic.
53. Brazil explained the criteria used to develop harmonized principles and based on these criteria; proposals were
made for harmonized principles (Appendix I of CX/MAS 24/43/8).
54. Noting that further work was needed to build on the recommendations in the discussion paper, Brazil proposed
that CCMAS43 should establish an EWG to continue developing the discussion paper and to provide
definitions for descriptions of analytical methods; harmonized names and format for the principle and provision
names and to present these revised harmonized principles and provision names in CXS234 for consideration
by CCMAS44.
Conclusion
55. CCMAS43 agreed to establish an EWG chaired by Brazil and co-chaired by Chile, working in English, to further
develop:
i. definitions for descriptions of analytical methods;
ii. harmonized names and format for principles and provision names in CXS234; and
iii. Prepare a revised CXS234 presenting the proposed harmonized principles and provision names.
56. The report of the EWG should be made available three months prior to CCMAS44.
APPROACH FOR THE PLACEMENT OF NITROGEN CONVERSION FACTORS (Agenda item 9) 19
57. Chile, speaking also on behalf of Brazil, introduced the item, and explained that the determination of the protein
content in foods is based on the quantification of the nitrogen contained in the foods which is calculated by
applying a nitrogen conversion factor (Nx). It was therefore necessary to be clear about the Nx that should be
used. Therefore, considering practicality and accessibility, it was recommended to include in CXS 234-1999
an annex in which information on Nx that have been determined by Codex committees could be accessible.
58. Chile further highlighted other recommendations in CX/MAS 24/43/11, including the need to confirm Nx for
certain commodities.
Discussion
59. CCMAS43 considered the recommendations outlined in CX/MAS 24/43/11 and noted the following views.
Positioning of nitrogen conversion factors in Codex texts
60. CCMAS43 noted there was general support to include Nx as an Annex to CXS 234, as this would provide
clarity and accessibility, especially to food laboratories that would need to determine the protein content of
samples using methods that require calculation.
61. An Observer, while supporting an annex to CXS 234, noted that the proposed Annex would need to be modified
whenever a Nx was updated in the relevant standard, and expressed their preference for the Nx values to be
presented as a list as reflected in CX/MAS 24/43/11 Appendix II. The Observer expressed that it would not
support the harmonization of the provision name if CCMAS decided to present the Nx values in a table, as the
necessary consequential change to the provision names in the commodity standards could cause confusion.
62. CCMAS43 agreed to amend “Vegetable Protein Source” to “Plant Protein Source” and to include the Nx value
for fish and fish products as 6.25.
18 CX/MAS 24/43/10
19 CX/MAS 24/43/11
Draft REP24/MAS 12
75. Members also supported the use of the “dot” convention in indicating decimal points. While one Member noted
that it was a legal requirement in their country to use the “comma” convention instead, the Chairperson
explained that the dot convention was used in international standards and Members would be free to make
formatting changes in their national standards as appropriate.
Conclusion
76. CCMAS43 agreed to:
i. forward the document titled “Nitrogen to protein conversion factors“ for adoption by CAC47 and
inclusion as an Appendix to CXS 234-1999 (Appendix II, Part 3);
ii. inform the relevant commodity committees about the "Nitrogen to Protein Conversion Factor"
document and remind them that it was their responsibility to identify and report the proposed nitrogen
conversion factors to CCMAS to facilitate the endorsement process;
iii. recommend that relevant commodity committees consider revoking Nx values in their commodity
standards;
iv. request that CCNE consider whether it was appropriate to set the Nx value of 5.71 for Tehena;
v. request the agreement of CAC47 to task the Codex Secretariat with reviewing the current nitrogen
conversion factors in commodity standards from the relevant Codex commodity committees, which
have been adjourned sine die, and propose the revocation of the corresponding Nx values; and
vi. amend the information document titled "Comprehensive Guidance for the Process of Submission,
Consideration, and Endorsement of Methods for Inclusion in CXS 234" by incorporating the following
text under Section 3.2 Acceptance of Methods of Analysis (Appendix IV):
When methods for protein determination based on total nitrogen followed by calculation are
submitted for endorsement, a nitrogen conversion factor should be provided. If the method is
endorsed and included in CXS234, the nitrogen conversion factor will be made available in an annex
to CXS234.
LISTING OF TYPE IV METHODS IN CXS 234 WHEN A TYPE I METHOD IS LISTED FOR THE SAME
COMMODITY AND PROVISION (Agenda item 10)20
77. Uruguay, Chair of the EWG, speaking also on behalf of the co-Chair, Brazil, introduced the item, providing
background and history of discussions on this subject. The EWG Chair highlighted that: (i) there was no strict
rule against endorsing a Type IV method when a Type I method existed, provided the performance data
supports suitability; ii) as regulated in the Information Document titled "Comprehensive guidance for the
process of submission, consideration and endorsement of methods for inclusion in CXS 234," (hereafter,
referred as Information Document), only one Type I method was typically listed per commodity and provision,
unless there were complementary or identical methods. The Chair explained how the EWG had conducted its
work, provided discussions on the necessity of coexistence between Type I and Type IV methods for the same
commodity and provision. The Chair further proposed to i) continue with the selection of Type IV methods on
a case-by-case basis when a “justifiable and motivating reason” was provided until appropriate selection
criteria were developed; and ii) re-establish the EWG to develop co-existence or equivalence criteria for Type
I and Type IV methods.
Discussion
78. CCMAS43 considered the recommendations and noted the following views.
Endorsement of Type I and Type IV method for the same commodity provision
79. An Observer, speaking on behalf of Standards Development Organizations (SDOs) and referring to CRD08,
indicated that combining Type IV methods with Type I methods for specific commodities and provisions was
inappropriate as Type I methods were generally fully validated and determined a value that could only be
arrived by the method, and is used for resolving trade disputes, while Type IV methods, lacking validation,
should only be used when essential and validated alternatives were unavailable. It was emphasized that CXS
234 did not aim to comprehensively cover all globally available methods but was a collection of methods
endorsed by the CAC. Outside of dispute situations laboratories might use any analytical method they
preferred. Therefore, these Observers were of the opinion that adopting Type IV methods when there was
already a Type I method in place for a certain commodity and provision should be considered an exception
rather than on a case-by-case basis.
20 CX/MAS 24/43/12
Draft REP24/MAS 14
80. Another Observer underscored the importance of relying on established procedures and validated methods in
Codex and cautioned against prioritizing personal preferences or regional convenience over validated
methods, as this could lead to unresolved disputes. This Observer also drew the attention of CCMAS to the
report of CCMAS37 which stated that work in determining equivalence falls on the Standards development
Organizations (SDO) and encouraged CCMAS participants to consult with member of SDOs when the need
arises to validate new methods, or to determine the bias between any two methods.
81. A Member proposed that the coexistence could be allowed only to ensure inclusiveness due the following
considerations:
i. there was no alternative method for Type I method according to its definition and earlier discussion in
CCMAS; therefore, CCMAS should not endorse a Type IV method that has the same provision/analyte
combination as a Type I method unless the method was really necessary;
ii. Since Type IV method might give different analytical value from the Type I method, endorsement of
both methods should be exceptional and strictly limited to avoid unnecessary disputes;
iii. Codex standards should be ready for all Members to utilize in their regulations. If some Members who
wanted to use Codex standards have faced serious difficulties to implement them, Codex needed to
consider how to solve the situation; and
iv. the coexistence of Type I and Type IV methods would represent a compromise aimed at assisting
Members facing significant implementation challenges.
82. Other members pointed out that according to the Procedural Manual (PM), a Type I method should typically
be the sole method for establishing the accepted value. However, exceptions might arise, such as non-
availability of reagents or legal restrictions on chemical use, justifying coexistence with a Type IV method.
83. The view that coexistence on a case-by-case basis might be necessary was also noted.
84. CCMAS43 agreed that endorsing a Type IV method when a Type I method exists should be approached as
an exception, and should not lead to a proliferation of Type IV methods when a Type I method already existed.
Development of co-existence or equivalence criteria for Type I and Type IV methods
85. The following views were expressed:
i. Clear criteria are essential to address concerns regarding case-by-case scenarios. Defining when to
apply this approach would enhance clarity and consistency;
ii. Implementing a criteria-based approach for when a Type IV method could complement a Type I
method may lead to confusion and complications;
iii. Considering the adoption of a Type IV method alongside a Type I method for a specific commodity
and provision as an exception, rather than addressing it on a case-by-case basis, is suggested.
Therefore, selection criteria for these exceptional situations are deemed unnecessary and should not
be pursued further; and
iv. the physical working group on endorsement could be tasked to review existing methods and potentially
eliminate outdated ones was proposed to reduce the prevalence of Type I and Type IV methods.
86. In response to the proposal for tasking the physical working group on endorsement to review existing methods
(see para **), the Codex Secretariat clarified that CCMAS was currently reviewing all testing methods package
by package which included the aforementioned task. Proposals emanating from this work were being
considered by the WG on endorsement, therefore it was not necessary to specifically task the WG on
endorsement.
87. CCMAS43 agreed not to develop the criteria for the co-existence of Type I and Type IV methods.
Revision of the PM or the Information Document
88. In response to the suggestion of revising the PM to address the co-existence of Type I and Type IV methods
for the same commodity and provision, the Codex Secretariat proposed that making changes to the PM should
be avoided due to the process involved. Alternatively, revision to the Information Document was a simpler
internal process, particularly for exceptional cases.
89. CCMAS43 agreed to amend the Information Document: Comprehensive guidance for the process of
submission, consideration and endorsement of methods for inclusion in CXS234 to address the endorsement
of Type IV methods when there were existing Type I methods for the same commodity and provision.
Draft REP24/MAS 15
Conclusion
90. CCMAS43 agreed to
i. Continue with the endorsement of Type IV methods when there were Type I methods for the same
commodity and provision on exceptional basis when there were justifiable and motivating reasons;
and
ii. insert the following bullet point in the Information Document: Comprehensive guidance for the process
of submission, consideration and endorsement of methods for inclusion in CXS234 under section 3.9
Type IV methods and their transitioning to other method types (Appendix IV):
v. Under exceptional circumstances, a Type IV method can be endorsed when there is an existing
Type I method for the same commodity and provision provided there is a justifiable reason.
REPORT OF AN INTER-AGENCY MEETING ON METHODS OF ANALYSIS (Agenda item 11) 21
91. AOAC, as Vice-Chair of the Inter-Agency Meeting (IAM), introduced the IAM report on behalf of the Chair of
the IAM. AOAC highlighted the various issues discussed in the IAM with respect to the work of CCMAS and
other related matters, i.e. the review of methods of analysis for cereals, pulses and legumes in CXS 234; the
numeric performance criteria for the determination of nitrate and nitrite ions in certain food matrices; methods
of analysis for precautionary allergen labelling; placement of nitrogen conversion factors; listing of Type IV
methods in CXS 234 when a Type I method was listed for the same commodity and provision; and methods
of analysis for microplastics in food, as described in CRD04. AOAC added that some conferences, symposia,
and workshops organised by IAM Members could be relevant to Members and it would be useful to share this
information among Members. IAM was looking into how it could compile this information into a more usable
document to share with CCMAS.
92. CCMAS43 noted that several of the issues raised in CRD04 had been considered under relevant agenda
items.
Conclusion
93. CCMAS43 thanked the members of IAM for their valuable contribution to the work of the Committee.
OTHER BUSINESS AND FUTURE WORK (Agenda item 12)
The importance of harmonization of sampling and testing methods for the determination of microplastics in
foods (CRD09)
94. The representative of FAO introduced the item, highlighting FAO’s ongoing work in microplastics, the related
discussions at the 19thth FAO Subcommittee on Fish Trade, and the need for appropriate testing methods to
better understand the dietary risk associated with microplastics. The FAO representative also shared that ISO
24187:2023, while not recommending an analytical method, outlined several key principles in microplastic
sampling and sample preparation. CCMAS was requested to consider recommending methods of analysis and
sampling for microplastics.
95. A Member highlighted that besides fish and fish products, microplastics could be found in mineral water
packaged in plastic bottles. The Member noted that it would be challenging to recommend methods of analysis
at this time without an associated provision in relevant standards and suggested the possibility of inviting
international metrological institutions to establish microplastic reference materials and collaborate with national
competent authorities.
96. An Observer added that it would be working to establish methods of analysis for microplastics in foods in the
future, but recognized the complexities of this issue.
97. In line with the CCMAS43’s decision on methods of analysis for 1,2-DAG and PPP where there was no
associated provision in the relevant commodity standard, the Chairperson suggested that in the future, CCMAS
could consider recommending methods of analysis for microplastics to assist in data collection without
including them in CXS 234.
Conclusion
98. CCMAS43 noted the information provided by the FAO representative, requested SDOs to keep the Committee
updated on initiatives on microplastics and that the Committee would consider how to make efforts in this
regard once more information on possible methods became available.
21 CRD04
Draft REP24/MAS 16