Food Products Containing Undeclared Added Sulfiting Agents

Why FDA issued it

Note: The revision of this Import Alert (IA) dated 07/28/2023 updates the guidance section including agency contacts. Changes to the import alert are bracketed by asterisks (***). There is a continuing problem of undeclared added sulfiting agents e.g. sulfur dioxide, sodium sulfite, sodium bisulfite, potassium bisulfite, sodium metabisulfite and potassium metabisulfite) in a wide variety of imported foods. This is a misbranding issue which can be corrected by relabeling to alert sensitive individuals to the presence of added sulfiting agents. Under 21 CFR 101.100(a)(3), if an ingredient is present at an incidental level (present at less than 10 ppm (21 CFR 101.100(a)(4)) and has no functional or technical effect in the finished product, then it need not be declared on the label. Furthermore, sulfiting agents that remain in a food in a significant amount but no longer have a technical or

Quoted from the “Reason for Alert” section of the FDA page for 99-21, mirrored 30 August 2026. The quotation is truncated at the length this copy carries.