Flavourings, Colourings and Additives Labelling Issues

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1 Flavourings, Colourings and Additives Labelling Issues JOY HARDINGE AJH CONSULTING

2 Flavourings Ingredient listing Front of pack depiction Claims Additives Carryover What does it mean? Colourings Natural Colouring? Colouring Foodstuffs

3 Ingredient Listing of Flavourings Currently covered by the Flavouring Regulations 1334/ Art 29 which applied from Jan In the Food Information to Consumers it is covered by 1169/2011 Art 18 and Part D of Annex VII which refers back to 1334/2008 requirements.

4 Ingredient Listing of Flavourings Flavouring(s) or a more specific name or description. Smoke Flavouring(s) or Smoke flavouring produced from x. If the flavouring doesn t impart a smoky flavour it can be covered under the word Flavouring.

5 Natural Flavouring The term Natural for the description of Flavourings shall be used in accordance with Art 16 of the Flavourings Regulation 1334/2008. The flavouring part of Natural flavourings can only be composed of natural flavouring substances and/or flavouring preparations. Smoke Flavourings and Processed flavourings are therefore not natural.

6 Use of Natural The solvent /Carrier and other non flavouring parts do not need to be natural Natural X Flavouring The flavouring part has to be at least 95% from X. Natural X Flavouring with other Natural Flavourings The flavouring part has to be partially derived from X and must be easily recognisable. Natural Flavouring The flavouring part is derived from different sources and a reference to them would not reflect the flavour or taste.

7 Claims e.g. No Artificial Flavourings Not covered by EU Regulations specifically but must not be misleading. Situation varies between Member States In some the back of pack declaration must match the front of pack. There are different views on the use of Artificial Flavouring since this is not defined in the legislation.

8 Guidance on Pictorials FDF have produced a document to help UK industry decide when a picture is appropriate. It builds on the requirements of the current UK Labeling regulation. Shared with UK FA and other stakeholders including DEFRA and FSA. Guidance covering all of the EU is very difficult due to the existing national requirements which are so disparate.

9 EU Guidance Due to the number of interpretation questions from Member States the EU Commission has been working on a Labeling Q&A document for flavourings. Despite a number of meetings during the last 12 months this is still not agreed but it is hoped to finalise it shortly. It will be placed on the Commission website for guidance only.

10 EU Labelling Guidance - Examples Clarifies both the use of Negative claims such as No Artificial flavourings and positive claims such as Only Natural Flavourings. Considers the use of terms such as Strawberry flavouring to describe a non natural flavouring which imparts a strawberry flavour to the food.

11

12 Carry over of Additives Explained in Article 18 of the Additive Regulations 1333/2008. This does not apply to infant formulae etc unless specifically provided for. The additive must not perform a technological function in the final food.. If it performs a technological function in the final food it is an additive. Additional requirements for sweetener carry over

13 Article 18 Carry Over. The presence of a food additive shall be permitted: (a) in a compound food other than as referred to in Annex II, where the food additive is permitted in one of the ingredients of the compound food;

14 Carry Over (cont) (b) in a food to which a food additive, food enzyme or food flavouring has been added, where the food additive: (i) is permitted in the food additive, food enzyme or food flavouring in accordance with this Regulation; and (ii) has been carried over to the food via the food additive, food enzyme or food flavouring; and (iii) has no technological function in the final food;

15 Carry over (cont) 1. The presence of a food additive shall be permitted: (c) in a food which is to be used solely in the preparation of a compound food and provided that the compound food complies with this Regulation. Sometimes referred to as reverse carry over

16

17 Colourings Unlike flavourings there is no definition of a Natural Colour although this is frequently seen on labels and in front of pack claims Ingredient List declaration is Colour : name or E number

18 Colouring foodstuffs or When is a colouring not a colouring? Increased use of Ingredients such as concentrated elderberry juice and spinach juice, due in part by the desire for clean label products, has caused the Commission and Member States to work on guidance documents to decide when a material is a colour and when it s a colouring foodstuff.

19 Colouring Foodstuffs - Guidance Work started in 2008 and the current draft is revision 10 Document is nearing completion and will hopefully be agreed at Standing Committee later this month It will be published on the Commission Website 2 year transitional period

20 Colours definition 1333/ preparations obtained from foods and other edible natural source materials obtained by physical and/or chemical extraction resulting in a selective extraction of the pigments relative to the nutritive or aromatic constituents are colours within the meaning of this regulation

21 Enrichment Factor Cp Cp Np Ap Fn = or Ff = Cs Cs Ns As Cp- colour, Np - nutritive value, Ap Aromatic substance in examined material Cs colour, Ns - nutritive value, As aromatic substance in source Fn enrichment factor on nutritive basis, Ff on aromatic basis AJH CONSULTING

22 Additional Sources of Information FoodDrinkEurope Guidance on the Flavouring Regulations rings-guidelines/ EFFA Guidance on Flavouring Regulations and Also on Natural Flavourings Commission Q&A on Flavour Labelling and Colouring Foodstuffs/Colours Guidance UK Guidance on Depiction

23 Thank You for Your Attention AJH CONSULTING

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