Australia New Zealand Food Standards Code – Standard 1.3.3 – Processing aids

Processing aid is defined not in Standard 1.3.3 itself but in section 1.2.13 of the Code, which is reproduced in the Note to section 1.3.3‑2. Under that definition, a substance is used as a processing aid if: (a) it is used during processing to perform a technological purpose in the course of processing; (b) it does not perform a technological purpose in the food for sale; and (c) it is identified in subsection (3) of that definition. Subsection (3) identifies two categories of substance: a substance listed in Schedule 18, or an additive permitted at GMP. The definition also covers foods used as processing aids (other than substances identified in subsection (3)), but notes that the Code does not prohibit the use of foods as processing aids. If a food is used as a processing aid and the amount used exceeds what is necessary to perform the technological purpose, the excess is not treated as a processing aid and is not exempt from ingredient declaration requirements (see Note 2 to section 1.3.3‑2). This distinction matters because the Standard’s permission regime applies only to substances; foods used as processing aids require no permission under Standard 1.3.3 but face labelling consequences.

Technological purpose is referenced throughout the Standard but not separately defined. The Standard identifies permissible technological purposes in the Schedules: anti‑foaming, catalysis, decolouring/clarifying/filtering/adsorbing, desiccating, ion exchange, lubricating/releasing/anti‑stick, carrier/solvent/diluent (noted in section 1.3.3‑5), bleaching, washing, peeling, extraction solvent, microbial control, antimicrobial, and fermentation aid.

Maximum permitted level is specified in many Schedules. Section 1.3.3‑3(b) requires that the proportion used be no more than the maximum level necessary to achieve the technological purpose under conditions of GMP. Where a Schedule sets a specific maximum permitted level (for example, in S18‑3, S18‑6, S18‑7, S18‑8, S18‑9, S18‑10, S18‑11), that level is an absolute cap. In other cases (e.g. section 1.3.3‑4 for additives permitted at GMP), the only limit is the GMP level necessary to achieve the purpose.

Additive permitted at GMP is a defined term under section 1.1.2‑11 of the Code (cross‑referenced in Note to section 1.3.3‑2(3)(b)). It refers to food additives that are permitted for use in foods generally at levels consistent with good manufacturing practice, without a specific maximum. These substances are automatically permitted as processing aids for any food under section 1.3.3‑4(2)(a), subject to the GMP limit.

The Standard also draws a distinction between processing aids that may be used in any food (Divisions 1 and 2) and those that may be used only with specified foods (Division 3). For example, substances listed in S18‑6 are restricted to packaged water or water used as an ingredient; S18‑7 substances are limited to the specific foods listed in the table (e.g. fruit, vegetables, nuts for bleaching/washing/peeling agents); S18‑8 substances are restricted to specific foods for extraction solvent uses. This tiered approach means a processing aid that is lawful in one food category may be unlawful in another. The specificity is highest for the newer permissions: cetylpyridinium chloride (section 1.3.3‑13) is permitted only for foods listed in S18‑11 and subject to residue and use conditions; dimethyl dicarbonate (section 1.3.3‑12) is permitted only for foods listed in S18‑10 and must not remain in the final food; and the shiitake fermentation aid (section 1.3.3‑14) is permitted only for pea protein, rice protein, or pea‑and‑rice protein, with detailed compositional specifications for the mycelia stock.

The Standard directly affects any person or business that processes food for sale in Australia or New Zealand and uses a substance as a processing aid. This includes manufacturers of processed foods such as baked goods, beverages, dairy products, meat and fish products, oils, sugars, water, wine, beer, and fruit and vegetable products. Specific industries are singled out by Division 3: water bottlers and manufacturers using water as an ingredient (S18‑6); producers using bleaching, washing or peeling agents on fruit, vegetables, nuts and grains (S18‑7); producers using extraction solvents for processing of fats, oils, flavourings, decaffeinated coffee and tea, and certain protein products (S18‑8); manufacturers of alcoholic beverages, non‑alcoholic beverages and other foods listed in S18‑10 who may wish to use dimethyl dicarbonate as a microbial control agent; processors of raw poultry carcasses and other foods listed in S18‑11 who may wish to use cetylpyridinium chloride as an antimicrobial agent; and manufacturers of pea protein or rice protein products who may wish to use the shiitake mycelia fermentation aid (S18‑14). The carbon monoxide restriction in section 1.3.3‑4(3) specifically targets fish processors: any use of carbon monoxide in fish processing that alters or fixes the colour of the flesh is prohibited unless the carbon monoxide is naturally present in smoke. This affects fish smoking operations and packaging of tuna and other fish where carbon monoxide is sometimes used to maintain colour.

Importers are also affected because food imported into Australia must comply with the Code, including Standard 1.3.3. If a foreign‑processed food uses a processing aid not listed in the Schedules, or uses a listed aid outside its permitted food category or above the maximum level, the food cannot lawfully be sold. Importers must verify the processing aids used in third‑country supply chains, which may involve testing or supplier declarations.

Suppliers of processing aid substances (chemical manufacturers, enzyme producers, fermentation preparation suppliers) are indirectly affected because their customers (food processors) demand substances that are listed in the Schedules. A substance not listed has no market for that use in Australia or New Zealand unless an amendment application is made to FSANZ. The cost of obtaining a new permission (including safety assessments, public consultation, and FSANZ decision) is borne by the applicant industry.

Enforcement agencies also interact with the Standard. Food regulators in Australian states and territories (e.g. NSW Food Authority, Victorian Department of Health) and New Zealand Food Safety (Ministry for Primary Industries) enforce compliance through inspections, product testing, and prosecution. The Standard does not itself create enforcement mechanisms; those arise under the Food Standards Australia New Zealand Act 1991 (Cth) and corresponding state and territory food acts.

In terms of private economic effects, the Standard imposes a compliance burden on food businesses that must maintain internal registers of processing aids used, check each against the Schedules, and ensure documentation of GMP levels. Smaller businesses may lack the technical capacity to assess whether a substance falls within the “additive permitted at GMP” category, or whether a technological purpose is genuinely performed only during processing. The specificity of permissions for newer aids like cetylpyridinium chloride and shiitake mycelia creates niche entry barriers for processors who are not the original applicants.

Duties are directed at persons who use or sell food to which a processing aid has been added. The primary duty, derived from paragraph 1.1.1‑10(6)(c) read with Standard 1.3.3, is not to sell food containing a substance used as a processing aid unless that substance is permitted for that food by Standard 1.3.3. This duty is strict: there is no defence of ignorance. The Standard imposes additional duties: (a) under section 1.3.3‑3(b), the proportion used must be no more than the maximum level necessary to achieve the technological purpose under GMP, even if the Schedule does not specify a numeric maximum; (b) where a Schedule specifies a maximum permitted level, the substance must not be present in the food above that level (sections 1.3.3‑5, 1.3.3‑8, 1.3.3‑9, 1.3.3‑10, 1.3.3‑11, 1.3.3‑12, 1.3.3‑13); (c) for carbon monoxide used in fish processing, a duty not to use it in a way that changes or fixes the colour of the fish flesh unless it is naturally occurring in smoke (section 1.3.3‑4(3)); (d) for dimethyl dicarbonate, a duty that it must not be present in the food for sale (section 1.3.3‑12(2)); (e) for cetylpyridinium chloride, a duty to comply with any conditions for use specified in S18‑11 (section 1.3.3‑13(2)); (f) for the shiitake fermentation aid, a duty to use only from a glycerol stock meeting specific compositional specifications for heavy metals and aerobic plate count (section 1.3.3‑14(4)), and a duty to use no more than the maximum level necessary under GMP (section 1.3.3‑14(3)).

Rights granted by the Standard include: the right to use any substance listed in section S18‑2 (including additives permitted at GMP) as a processing aid in any food, subject to the GMP condition (section 1.3.3‑4); the right to use substances listed in S18‑3 in any food for the stated technological purposes, subject to maximum permitted levels (section 1.3.3‑5); the right to use enzymes listed in S18‑4 from their specified sources for any technological purpose (section 1.3.3‑6); the right to use substances listed in S18‑5 as microbial nutrients or adjuncts in any food (section 1.3.3‑7); the right to use water‑specific processing aids (S18‑6) in packaged water or water as an ingredient (section 1.3.3‑8); the right to use bleaching, washing, or peeling agents (S18‑7) for specific foods (section 1.3.3‑9); the right to use extraction solvents (S18‑8) for specific foods (section 1.3.3‑10); the right to use substances in S18‑9 for their stated technological purposes in specified or any foods (section 1.3.3‑11); the right to use dimethyl dicarbonate in foods listed in S18‑10 as a microbial control agent, subject to non‑presence in the final food (section 1.3.3‑12); the right to use cetylpyridinium chloride in foods listed in S18‑11 as an antimicrobial agent, subject to residue limits and use conditions (section 1.3.3‑13); and the right to use the shiitake mycelia fermentation aid in pea protein, rice protein, or both, subject to specifications (section 1.3.3‑14).

Businesses also have a right to use a food (as opposed to a substance) as a processing aid without needing a permission under Standard 1.3.3, but they must be careful about the amount used: if the amount exceeds that necessary for the technological purpose, the excess is not exempt from ingredient labelling (Note 2 to section 1.3.3‑2). This creates a tension: overshooting the GMP level converts the processing aid into an ingredient that must be declared on the label, potentially revealing a trade secret or causing consumer confusion.

Standard 1.3.3 does not itself prescribe penalties; it is a standard made under the Food Standards Australia New Zealand Act 1991 (Cth). Enforcement and penalty provisions therefore come from that Act and from state and territory food legislation, as well as from the New Zealand Food Act 2014. Under section 47 of the FSANZ Act, a person must not sell food that does not comply with a standard. A contravention is a criminal offence under section 48, carrying a maximum penalty of 1,000 penalty units (currently $313,000 for an individual, or five times that for a body corporate, under the Crimes Act 1914) or imprisonment for up to two years. State and territory food acts, such as the Food Act 2006 (Qld) and the Food Act 2003 (NSW), mirror these provisions and provide for enforcement by local food safety authorities.

In practice, enforcement actions are typically civil or administrative. Food regulators can issue improvement notices, prohibition orders, or suspend licences. They can also seize and destroy non‑compliant food, require recall of products, and seek civil pecuniary penalties. For example, if a food processor uses a substance as a processing aid that is not listed in any Schedule, or uses a listed substance in a food for which it is not permitted (e.g. using an S18‑7 bleaching agent on a non‑listed food), the resulting food is non‑standard and cannot be sold. The processor may face a prosecution or a recall order costing substantially more than any penalty.

The Standard creates several specific conditions that, if breached, also lead to non‑compliance. Using carbon monoxide on fish that changes the flesh colour (section 1.3.3‑4(3)) is an offence even if the carbon monoxide is listed as a processing aid. Having dimethyl dicarbonate present in the final food (section 1.3.3‑12(2)) is also a breach, regardless of whether it was used during manufacture. The shiitake fermentation aid conditions (section 1.3.3‑14(4)) impose precise limits on arsenic (10 µg/kg), cadmium (5 µg/kg), lead (5 µg/kg), and mercury (5 µg/kg), and an aerobic plate count of no more than 10 cfu/g. A processor who uses a fermentation aid sourced from mycelia that do not meet these specifications is in breach regardless of the final food’s safety.

Businesses should note that the Standard does not provide defences based on GMP or technological necessity alone. Even if a substance is used at a level far below any safety concern, it is unlawful if it is not permitted for that food. This creates an incentive for conservative recipe formulation and for engaging technical consultants who can interpret the Schedules correctly. The cost of non‑compliance includes not only fines but also loss of market access, brand damage, and the expense of reformulation.

Standard 1.3.3 is part of the Australia New Zealand Food Standards Code, a legislative instrument made under the Food Standards Australia New Zealand Act 1991 (Cth). The Code is a single set of standards applying in both Australia and New Zealand, but each jurisdiction incorporates it into domestic law. In New Zealand, the Code is adopted under the Food Act 2014 (see Note 2 to the Standard). In Australia, the Code is given force by the FSANZ Act and by state and territory food acts.

The Standard interacts directly with other Code provisions. Most notably, paragraph 1.1.1‑10(6)(c) prohibits a food for sale from containing a substance used as a processing aid unless the Code expressly permits it; Standard 1.3.3 is that permission. Section 1.1.2‑13 defines “used as a processing aid” and is reproduced in the Note to section 1.3.3‑2. Standard 1.2.4 (Labelling) and Standard 1.2.8 (Nutrition information) contain requirements relevant to processing aids: paragraphs 1.2.4‑3(2)(d) and (e) exempt processing aids from ingredient labelling, but only if they are used as processing aids (i.e. not excess amounts). If the excess amount is not exempt, it must be declared as an ingredient. Similarly, subparagraph 1.2.8‑5(a)(vii) deals with declaration of certain processing aids in nutrition information. Standard 2.6.2 (Packaged water) contains a specific permission for adding fluoride to water presented in packaged form, and section 1.3.3‑8 notes that it does not cover that use; rather, its permission is for fluoride to be added to water used as an ingredient in other foods.

Standard 1.3.3 also intersects with Standard 1.3.1 (Food Additives). Some substances permitted as processing aids under Standard 1.3.3 are also food additives under Standard 1.3.1. The Note to section 1.3.3‑2(3)(b) clarifies that “additive permitted at GMP” is a defined term under section 1.1.2‑11. A substance may be both an additive and a processing aid, but the use as a processing aid is governed by Standard 1.3.3, not Standard 1.3.1. If the same substance is added to perform a function in the final food, Standard 1.3.1 applies. This distinction is critical for compliance: the technological purpose of the addition determines which standard applies.

Import control laws also interact. The Imported Food Control Act 1992 (Cth) and the Imported Food Control Order 2018 require imported food to comply with the Code. The Australian Border Force and the Department of Agriculture, Fisheries and Forestry inspect imported food for compliance with Standard 1.3.3. If an importer cannot demonstrate that processing aids in foreign‑processed foods comply, the food may be detained or refused entry.

The Standard does not create any private rights of action. Only regulatory authorities can enforce it. However, breach of the Standard can be used as evidence of a breach of consumer law (e.g. the Australian Consumer Law prohibition on misleading conduct, if a product claims to be “natural” but contains a listed processing aid). Competitors may also lodge complaints with regulators.

Standard 1.3.3 was originally published in the Food Standards Gazette No. FSC96 on 10 April 2015 as part of Amendment 154 (F2015L00402, registered 31 March 2015). It commenced on 1 March 2016. The compilation in force at 2 September 2025 is Compilation No. 5, having been amended five times:

1. Amendment 157 (F2015L01374, registered 1 September 2015, Gazetted FSC99 3 September 2015, commenced 1 March 2016): corrected a typographical error in section 1.3.3‑3. No description of the nature of the error is provided beyond “correction of typographical error.”

2. Amendment 211 (F2022L01125, registered 26 August 2022, Gazetted FSC151 1 September 2022, commenced 1 September 2022): added section 1.3.3‑13, which permits cetylpyridinium chloride to be used as an “anti‑microbial” agent during processing of foods listed in S18‑11, subject to maximum permitted levels and conditions. This was a significant expansion of the Standard to allow a specific quaternary ammonium compound as a processing aid for antimicrobial purposes.

3. Amendment 220 (F2023L01004, registered 11 July 2023, Gazetted FSC160 19 July 2023, commenced 19 July 2023): amended section 1.3.3‑13 to replace “anti‑microbial” wherever occurring with “antimicrobial”. This is purely editorial, aligning the term with current nomenclature.

4. Amendment 240 (F2025L00856, registered 21 July 2025, Gazetted FSC180 22 July 2025, commenced 22 July 2025): added section 1.3.3‑14, permitting a fermented preparation of Lentinula edodes (shiitake mushroom) mycelia as a fermentation aid for pea protein, rice protein, or pea‑and‑rice protein, subject to the conditions in subsections (3) and (4) regarding GMP and compositional specifications for heavy metals and aerobic plate count.

5. Amendment 243 (F2025L00988, registered 26 August 2025, Gazetted FSC183 2 September 2025, commenced 2 September 2025): repealed Note 2 to section 1.3.3‑6 (enzymes). The content of the repealed Note is not provided in the source, but it presumably contained cross‑referencing information that was no longer current.

No uncommenced amendments or provisions ceasing to have effect are noted in the compilation as at 2 September 2025. The Standard has been amended at a rate of roughly one substantive change per two years since commencement. The addition of cetylpyridinium chloride and the shiitake fermentation aid are the only new permission categories introduced; the other amendments are housekeeping. This relatively sparse amendment history suggests that the processing aid permissions are stable and that FSANZ has not seen a high volume of applications for new processing aids, likely due to the cost and time of preparing a safety assessment. The lengthy period between commencement (2016) and the first substantive amendment (2022) may indicate that industry adjusted to the new Standard without needing immediate changes, or that applications for new processing aids take several years to progress through FSANZ’s assessment process.

The source text does not record any court or tribunal decisions interpreting or applying Standard 1.3.3. The Standard is a technical food regulatory instrument with a narrow scope, and disputes are more likely to be resolved administratively through FSANZ variation applications or compliance actions by food regulators rather than through litigation. Enforcement proceedings under state food acts may reference the Standard, but such cases are typically heard in local magistrates or district courts and are not systematically reported. The absence of litigation history in the compilation is consistent with the Standard’s role as a permission schedule: its terms are prescriptive, leaving little room for interpretive dispute. If a substance is not listed, it is not permitted; there is no ambiguity to litigate. The only potential area for legal challenge might be FSANZ’s decision to refuse an application to add a new processing aid, but such challenges would be brought under administrative law (e.g. Judicial review under the Administrative Decisions (Judicial Review) Act 1977) rather than through direct litigation of the Standard itself. No such challenges are mentioned in the amendment history or otherwise known from the source. Similarly, the carbon monoxide prohibition in section 1.3.3‑4(3) has not generated any reported case on whether a specific processing technique “changes or fixes the colour of the flesh” of fish; this would be a factual determination likely made by a food analyst rather than a court. The highest profile enforcement action involving processing aids in Australia has concerned iodine as a processing aid in bread (Standard 1.3.2), not Standard 1.3.3. For practical purposes, readers should treat litigation risk as negligible, but should be aware that regulatory action (e.g. seizure, recall) is the more likely consequence of non‑compliance. Any legal advice on the Standard should focus on correct interpretation of the Schedules and GMP conditions rather than on case law, as none exists.

Several provisions in Standard 1.3.3 are easily misunderstood or create traps for the unwary.

Excess food used as processing aid becomes an ingredient. Note 2 to section 1.3.3‑2 warns that if a food is used as a processing aid in another food and the amount used exceeds what is necessary to perform the technological purpose, the excess is not exempt from ingredient declaration. This means a manufacturer who adds, say, a milk protein concentrate as a processing aid to bind ingredients but adds more than necessary will have to declare that excess as an ingredient, which could trigger allergen labelling or add to the ingredient list. The burden of proof as to what is “necessary” lies with the manufacturer.

Additive permitted at GMP is not a free pass. Section 1.3.3‑4(2)(a) allows an additive permitted at GMP to be used as a processing aid in any food. However, “additive permitted at GMP” is a defined term that refers only to additives that are permitted in that food under Standard 1.3.1 without a maximum level. A processor might incorrectly assume that all food additives are GMP‑permitted; in reality, many additives have maximum levels under Standard 1.3.1 and cannot be used as processing aids under this provision if their technological function is as a processing aid. The correct approach is to check Standard 1.3.1’s table to see if the additive is listed as permitted at GMP in that food.

Carbon monoxide prohibition only applies to colour change. Section 1.3.3‑4(3) prohibits carbon monoxide in fish processing only if “its use results in a change to or fixes the colour of the flesh”. This means carbon monoxide used as a processing aid for a non‑colour‑related purpose (e.g. as a reducing agent) might be permissible, but the processor would need to demonstrate that no colour change occurs. This is a factual risk: a regulator may argue that any use of carbon monoxide in fish necessarily affects colour, even if the processor intended otherwise. Moreover, smoke‑derived carbon monoxide is exempt, but processors must prove the carbon monoxide is naturally occurring in smoke, not separately added.

Dimethyl dicarbonate must not be present at all. Section 1.3.3‑12(2) is absolute: the substance must not be present in the food for sale. This is stricter than a maximum residue limit. A manufacturer using dimethyl dicarbonate must ensure complete reaction or removal. Testing for residues is essential; even trace amounts that would be harmless could lead to a breach.

Cetylpyridinium chloride has use conditions. Section 1.3.3‑13(2) requires that any conditions for use specified in S18‑11 be complied with. The Standard does not reproduce those conditions in the main text, so a reader must check the Schedule. The conditions may include application methods, rinsing requirements, or temperature restrictions.

Shiitake fermentation aid specifications are mandatory. Section 1.3.3‑14(4) sets out six specifications for the glycerol stock of Lentinula edodes mycelia. These are not optional; the mycelia must meet all of them. A processor who relies on a supplier without certified test results for heavy metals and plate count risks using a non‑compliant substance, even if the final food is safe. The specifications apply to the mycelia stock, not the final food, so testing of incoming materials is necessary.

Misreading the food scope in Schedules. S18‑6 through S18‑11 contain tables that list permitted foods. If a food is not listed, the processing aid cannot be used, even if the technological purpose matches. For example, S18‑8 restricts extraction solvents to specific foods (e.g. decaffeinated coffee, cocoa butter). A manufacturer wishing to use hexane to extract an ingredient from a non‑listed food cannot do so under this Standard.

No transitional provisions. The Standard as compiled does not include any transitional or savings provisions for processing aids that were used prior to commencement. Businesses must assume that any processing aid not listed was always unlawful, even if historically used.

Reliance on GMP is not a defence to exceeding a maximum permitted level. The Standard distinguishes between the GMP “necessary” level and a numeric maximum permitted level in a Schedule. Where a Schedule sets a number, that number is a cap, not a safe harbour. Using a level below the numeric cap but still above the GMP necessary level would be a breach of section 1.3.3‑3(b). Conversely, using a level below the GMP necessary level but above the numeric cap is a breach of the Schedule. Compliance requires satisfying both limits.

Cross‑checking with other Standards. The Standard notes that permissions for water processing aids (S18‑6) do not extend to fluoride in packaged water, which is covered by Standard 2.6.2. A processor assuming that all S18‑6 substances are authorised for any water product would be wrong if they add fluoride to bottled water under S18‑6.

Compliance with Standard 1.3.3 requires a systematic audit of all substances added during food processing that are intended to perform a technological purpose but are not intended to function in the final food. The following steps are recommended.

Step 1: Identify each processing aid. Prepare a complete list of all substances added during manufacturing, handling, or packaging that are not declared as ingredients on the final label. Include substances used for cleaning, peeling, bleaching, filtering, ion exchange, anti‑foaming, lubrication, extraction, microbial control, and fermentation. For each substance, record its chemical name, CAS number (if relevant), supplier, and the proposed technological purpose.

Step 2: Classify each substance. Determine whether the substance is a substance within the meaning of section 1.3.3‑2(3) (i.e. listed in Schedule 18 or an additive permitted at GMP). If it is a food (e.g. a food ingredient used as a carrier), it does not need a permission under this Standard, but the amount used must not exceed that necessary for the technological purpose, and excess amounts must be labelled as ingredients. For substances, proceed to Step 3.

Step 3: Check the Schedules. For each substance, check whether it is listed in:

• S18‑2 (generally permitted for all foods), including additives permitted at GMP (cross‑check with Standard 1.3.1).
• S18‑3 (permitted for specific purposes in all foods). Note the permitted technological purpose and maximum level.
• S18‑4 (enzymes). Check the permitted source (animal, plant, microbial).
• S18‑5 (microbial nutrients/adjuncts).
• S18‑6 (water processing aids). Only for packaged water or water used as an ingredient.
• S18‑7 (bleaching/washing/peeling agents). Only for listed foods.
• S18‑8 (extraction solvents). Only for listed foods.
• S18‑9 (substances performing various technological purposes). Check the food category (if specified) and purpose.
• S18‑10 (dimethyl dicarbonate foods).
• S18‑11 (cetylpyridinium chloride foods).

If a substance is not listed in any applicable Schedule, it cannot be used as a processing aid. An application to amend the Standard must be made to FSANZ, which can be a lengthy and costly process.

Step 4: Verify technological purpose and conditions. For each listed substance, confirm that the intended use matches the purpose stated in the Schedule. For example, a substance listed in S18‑3 for “decolouring, clarifying, filtering or adsorbing” cannot be used for anti‑foaming unless also listed for that purpose. Check any conditions, such as application methods for cetylpyridinium chloride.

Step 5: Establish GMP usage levels. For all processing aids, document the maximum level necessary to achieve the technological purpose under Good Manufacturing Practice. This requires process validation and quality control. For substances with a specified maximum permitted level in the Schedule, that level is the absolute cap; do not exceed it even if GMP would allow more. For substances without a specified level, the only limit is the GMP necessary level.

Step 6: Implement residue controls. For processing aids that must not be present in the final food (e.g. dimethyl dicarbonate), establish testing protocols to ensure absence. For substances with maximum permitted levels (e.g. residues of extraction solvents), include testing in the HACCP plan.

Step 7: Train staff. Ensure that purchasing, production, and quality assurance personnel understand the Standard. A purchasing officer who orders a cheaper supply of a processing aid not listed in the Schedules could render products non‑compliant. All incoming substances should be checked against the approved list.

Step 8: Maintain documentation. Keep records of each processing aid used, its supplier, the technological purpose, the level used, and the rationale for why that level is necessary under GMP. Such records are essential for demonstrating compliance during regulatory inspection.

Step 9: Monitor amendments. FSANZ occasionally amends the Standard (see Amendment History). Subscribe to FSANZ notification services or engage a regulatory affairs consultant. When a new processing aid is added, assess whether it offers a commercial advantage; when a substance is removed (none have been removed to date), reformulate immediately.

Step 10: For importers, collect supplier declarations. Obtain from overseas suppliers a certificate confirming that all processing aids used in the imported food comply with Standard 1.3.3. Ideally, have the supplier provide the specific Schedule reference for each processing aid. Consider testing of final products for residues of likely unlisted processing aids (e.g. certain solvents, antimicrobials) as part of a risk‑based verification program.

Compliance is ultimately a matter of accurate classification and strict adherence to the Schedules. The Standard does not permit any “self‑determination” of safety; if the substance is not listed, it is not allowed, regardless of toxicological data. The cost of compliance includes internal auditing, possible reduction in processing options, and the expense of applying for new permissions. The benefit is certainty of lawful sale and avoidance of regulatory action.