indias amended standards for food additives in october 2015 the european union raised its concerns on indias draft food safety and standard amendment regulation as detailed in g sps n ind 108. the european union welcomed the user-friendly and simple approach to the listing of food additives in food products as well as the hierarchical listing of food additives. however the european union observed that the regulation needed further clarification and improvement in several areas. the draft regulation recommended maximum levels of additives only where codex had set such levels in the general standard for food additives gsfa . the european union noted that the gsfa had expressly stated that a lack of reference to a particular additive or to a particular use of an additive in a food in gsfa did not imply that the non-listed additive was unsafe or unsuitable for use. the european union further noted that the gsfa was neither complete nor exhaustive and that many members had implemented maximum levels of additives on a scientific basis where no codex standard existed. in addition for wines and spirits in the european unions view india had not taken into consideration the adoption of standards by other international standard-setting bodies such as the international organization for vine and wine oiv . in this regard the european union outlined several steps that india could take to avoid unnecessarily disrupting trade such as setting standards that took into account the safety of products and benefits for consumers which were proportionate necessary as well as scientifically and technologically justified. the european union requested india to take into account all of its comments including any additional comments submitted after the 4 october deadline and welcomed a written response from india at the earliest convenience. the european union further urged india to notify the measure to the wto committee on technical barriers to trade. the united states supported the concern and highlighted that although it supported aligning food standards to codex the codex standard was not designed to be a comprehensive standard for all additives commonly used in the production of wine and distilled spirits. the standard did not include some main additives commonly used in the production of these beverages. the united states indicated that it had submitted comments and urged india to take these comments into account in finalizing the measure. chile also supported the concern and noted that it would submit comments to india. india responded that it had notified the measure in august 2015 and had provided time for comments until 4 october 2015. india hoped that the concerned members had submitted their comments in writing so that the concerns could be addressed appropriately by the authorities. in march 2016 the european union reiterated its concerns on indias draft food safety and standard amendment regulation notified in g sps n ind 108. the european union again welcomed the user-friendly and simple approach to the listing of food additives in food products as well as the hierarchical listing of food additives. however the european union observed that the regulation if maintained as notified risked disrupting both national indian production and imports to india. the draft regulation recommended maximum levels of additives only where codex had set such levels in the general standard for food additives gsfa . the european union noted that the gsfa had expressly stated that a lack of reference to a particular additive or use of an additive in a food product did not imply that the non-listed additive was unsafe or unsuitable for use. the european union further noted that the gsfa was neither complete nor exhaustive and that many members had implemented maximum levels of additives on a scientific basis where no codex standard existed. in addition for wines and spirits in the european unions view india had not taken into consideration the adoption of standards by ot