Saudi Arabia has proposed two regulations limiting the amount of salt and sugar in food that could completely block exports of certain U.S. dairy products from entering the Saudi market. USDEC is seeking member feedback on the expected impact of these regulations on their business by May 16, 2019 (sugar upper limits) and June 15, 2019 (salt upper limits).

Sugar Upper Limits

Through World Trade Organization (WTO) notification G/TBT/N/SAU/1108, Saudi Arabia is proposing upper limits on added sugar to food products. If implemented, this regulation will have a significant impact on U.S. dairy exports to Saudi Arabia. As it relates to dairy products, the proposed regulation states:

1. Article 4.6: "It is not permitted to use any added sugar in milk products (fresh, pasteurized and long term milk) and flavored (fresh, pasteurized and long term) milk."
2. Article 4.7: The quantity of added sugar in any of the food products not stipulated in article (4.8) shall not exceed 10% of total energy per person, based on World Health Organization (WHO) recommendations (average energy intake doesn't exceed 2000 calories.)
3. Article 4.8: Ice cream (includes all types of ice cream (milk and non-milk products, chocolates...etc.): Maximum limit of added sugar per 100 mL/100 gm: 10.23g per 100 g

USDEC will be commenting on the proposed measures and encourages exporters to provide feedback to be included in its formal comments to USDA Foreign Agricultural Service (FAS) for incorporation into the U.S. government's comments. The comment deadline for USDEC members to provide feedback on this draft notification is May 16, 2019.

The proposed legislation may be accessed through the links below:

• G/TBT/N/SAU/1108
• Saudi Drug Authority, Draft Standard, Sugar Upper Limits Added in Some Food Products

Salt Upper Limits

In addition to upper limits on added sugar in foods, Saudi Arabia seeks to establish maximum salt limits in food products, which will also be detrimental to U.S. exports to this region if implemented.

As it relates to dairy products, Section 4/6 in the draft states:

The values of the maximum limit for sodium in the products should be used in accordance with the following table:

While this proposed regulation has not yet been notified to the WTO, USDEC continues to monitor the latest developments pertaining to this issue. We welcome your comments. The deadline to provide comments to USDEC is June 15, 2019.

The proposed legislation may be accessed at the following link:

• SFDA.FD 59:2018 Salt Limits Guidelines in Food Products

Please contact Sandra Benson at sbenson@usdec.org or Dacia Whitsett-Morrow dwhitsett@usdec.org with any questions.