The globalisation of the food industry is driving the harmonisation of ingredient regulations, though its still a jungle out there, as IFT conference delegates learnt last week.
"There are similarities and boundaries in many countries and blocs, such as the EU, the US, China and Japan," said Environ International Claire Kruger.
"There is growing pressure to get new products out and onto the global these markets."
A global strategy is therefore key in order to take advantage of an increasingly harmonised world market.
"In the global market place, there are four universal points - safety, benefit, legality and economic viability," said Kruger. "The processes might be different between countries, but the goals are the same.
"The bottom line is the growing importance of global marketing to food companies."
But a global marketing strategy should be informed not only by an awareness of what countries have in common, but also by the obstacles and challenges that persist in the global marketplace.
In Japan for example, functional foods come under the food sanitation law. Similar to the EU, there is a positive list of food additives.
But it has historically been very difficult to gain approval for new food additives that are not on this positive list, even if they have been developed and approved outside Japan. This is something to think about when rolling out an ingredient to Asia.
Things are changing though. Kruger said that the emergence of the FOSHU (foods for specific health use) labelling system in 1993 is a clear sign of recognition that easy access to health food is beneficial to a country whose population is getting older and more susceptible to disease.
In the US, flavour and fragrance labelling goes back to 1958 with the Food Additives Amendment. This established two categories food additives and GRAS (generally recognised as safe) substances.
While food additives must be scientifically reviewed to be approved, No FDA pre-market approval is needed for GRAS products.
Charles Manley, vice president of science & technology at Takasago International Corporation USA, told delegates that there are now over 2,000 flavour and fragrance ingredients on GRAS list. Since 1995 there has been a significant increase, and the reason for this is globalisation.
European regulations are of course different. Within the EU there are regulations and directives. Directives are binding to desired results, but are subject to national interpretations unlike regulations. National differences therefore persist.
Debate over the EU flavour registry is also ongoing. Established in 1999, the period of review has been extended to 2008.
"Frankly, completion could be later," said Manley. In addition, he pointed out that while EFSA was established in 2004 to provide risk assessment, EC remains the authoritative body.
"Unlike the FDA, it has no teeth," he said.
However, important steps have been made towards global regulatory harmonisation in a number of sectors. JECFA, the Joint FAO/WHO Expert Committee on Food Additives, which has been engaged in collecting and evaluating scientific data on food additives and making recommendations on safe levels of use since 1956, is an ongoing process.
Some food scientists are hopeful that the work of JECFA could lead to a harmonised system under the UN, whose recommendations would hopefully be taken on by all WTO members.
Food labelling is another matter, and there seems little ground for global harmonisation.
"The Codex committee of food labelling has been considering this since 1988," said Peggy Rochette, director of international policy at the Food Products Association (FPA).
"There is no prospect of consensus. This underscores the long standing differences in global views for even the most basic approach to food labelling."
In addition to different regulatory environments, food ingredients firms should also be aware that trends can also differ between regions. While the western world is concerned about weight, many Asian countries put a great deal of emphasis on gastro health.
There are also cultural aspects to this in Japan, it is generally not socially acceptable to admit to tiredness, and so products aimed at alleviated stress or tiredness will not do as well as in Europe.
"There are many things to think about when you are marketing globally," said Kruger. "You need to go through the steps methodically what products are needed, what claims are permitted, what regulatory requirements are required - and whether your product has economic viability."