prohibition of certain food additives in october 2010 india expressed concerns over japans proposed withdrawal of 80 food additives in may 2011 which had been notified to the wto in july g sps n jpn 255 . the decision to prohibit the use of these additives was apparently based on a survey and the analysis of public comments. the survey considered the sale manufacturing import processing use storage and display of such substances in japans market. india was concerned that the requirements of article 2 of the sps agreement had not been fully considered as the survey did not provide any indications that the additives were hazardous to human health nor had a risk assessment been undertaken by the japanese authorities and international standards had not been followed. of the 80 food additives to be withdrawn at least 33 substances were allowed in other countries including korea and the united states in line with codex or country specific standards. india urged japan to follow the provisions of the sps agreement before deciding to prohibit the use of the food additives and suggested that codex could be requested to examine the risks associated with those food additives. japan recalled that according to the revision of the japanese food sanitation law in 1995 natural additives became subject to prior approval by the ministry of health labour and welfare. therefore whether natural or synthetic no additive could be used unless it was approved by the ministry. the concept of existing food additives was established in 1995 and referred to substances that were derived from natural origin and that had been used before 1995 without prior approval. however their safety had not been verified or examined based on a safety assessment and japan would be systematically verifying the safety of existing food additives. japan considered that it was justifiable to eliminate those substances for which there was no actual use or distribution in japan and hence would not result in any restriction of trade. japan had previously directly contacted embassies and trade groups in response to requests received on this issue. in 2009 japan had carried out a survey on 125 substances and based on the survey results had prohibited these 80 additives since they were no longer in use in the domestic market. should members nevertheless have further comments on this notification these should be submitted by 17 november 2010 at the latest. in march 2011 india recalled its concerns about 31 of the 80 food additives that japan had notified as no longer being distributed in japan. in march 2011 the original list had been reduced to 50 however india still had concerns regarding 18 food additives to be withdrawn from the japanese market on 18 may 2011. the european union also requested clarification on a number of food additives planned to be withdrawn and which according to the webpage of the japanese ministry of health still remained on the list. the european union would continue its bilateral discussions with japan to address its outstanding concerns. japan reiterated that it was carrying out a safety verification of existing food additives as some were being used without a risk assessment. japan had notified the wto in july 2010 g sps n jpn 255 and had received several comments. at the october 2010 meeting japan had asked india to submit evidence that certain substances were in use in japan so as to change the status of those food additives. however indias comments had been received after the comment period had lapsed. japan would publish a list of 55 substances for withdrawal from the japanese market in the official gazette in may 2011. in june 2011 india remained concerned that food additives were being prohibited on the basis that they were not in use in japan without a risk assessment. some of the food additives that were restricted in japan were in use in other countries and such a measure to prohibit these additives without any scientific basis violated t