Chlorine dioxide as additive in Japanese products
I have a question regarding Japanese food safety requirements. Oddly as per Japanese regulations any substances used in or on food in the process of manufacturing food is considered an additive. There is a standards of use list recently updated in feb 2021 substances used in or on food in the process of manufacturing food. As per this list chlorine dioxide only appears to be allowed for the use on wheat as a flour treating agent. Is this an accurate interpretation, does this mean that if you want to use a product it must be on this list and for the food product listed only and not for other targeted foods or as another major use category? If I wanted to use chlorine dioxide as a sanitizer on a food and was assured there were no residuals would it be allowed or not? I cannot determine that using any chemicals in a different manner and in a different food group is allowed or not?
From the limited experience I have with exporting foods to Japan they are very specific in the additives and targeted foods. Therefore, the additive must be approved for the targeted food. There isn't much flex in this.
However, it has been 8 years since I've had experience with Japan food import regulations.