Annex 1 – Quick Guide to Using the Register of Food Additive Authorisations
| Identify Additive Name and/or E Number |
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| Identify food category for product in question |
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| Access register |
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| Search by additive name or E number |
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| Open ‘Conditions of Use in Foods’ |
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| Scroll to Part E: Authorised Food Additives and Conditions of Use |
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| Identify Conditions of Use for Additive/Food combination |
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Annex 2 – Examples of LA sample failures for additives
| Name of Additive and inclusion in any additive group(s) | Product Category, including examples | Maximum level permitted (mg/l) or (mg/kg) | Examples of Non-compliance |
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E 220 Group(s): E 220–228: Sulphur dioxide — sulphites | 08.1 Fresh meat, excluding meat preparations as defined by Regulation (EC) No 853/2004 | Not permitted Assimilated Regulation (EC) No. 1333/2008 – Annex II Rows 1501-1750 |
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08.2 Meat preparations as defined by Regulation (EC) No 853/2004 | 450mg/kg Only permitted in burger meat with ≥4% vegetable or cereal content, breakfast sausages and some traditional Spanish/Portuguese meat preparations Assimilated Regulation (EC) No. 1333/2008 – Annex II Rows 1501-1750 |
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E 280 Group(s):
| 07.1 Bread and rolls | 1000-3000mg/kg Different levels apply to different types of bread product, as specified in the authorisation. Assimilated Regulation (EC) No. 1333/2008 – Annex II Rows 1251-1500 |
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E200 Group(s): Multiple Groups – see authorisation for detail | 01.4 Flavoured fermented milk products including heat-treated products | 300 mg/kg Only non-heat-treated dairy-based desserts Assimilated Regulation (EC) No. 1333/2008 – Annex II Rows 1 - 250 |
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E251 Group(s): E 251–252: Nitrates | 08.2 Meat preparations as defined by Regulation (EC) No 853/2004 | Not permitted
Assimilated Regulation (EC) No. 1333/2008 – Annex II Rows 1501-1750
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Note that cured chorizo would fall into a separate food category (08.3.1 - non-heat-treated meat products) which permits nitrates to be added up to 150 mg/kg during manufacturing |
08.3.4.2 Traditional dry cured products | 250 mg/kg Maximum residual amount, residue level at the end of the production process, expressed as NaNO 2 or NaNO 3 Assimilated Regulation (EC) No. 1333/2008 – Annex II Rows 1501-1750 |
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E124 | 12.6 Sauces | Not permitted Assimilated Regulation (EC) No. 1333/2008 – Annex II Rows 2251-2500 |
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E129 Group(s) Group III: Colours with combined maximum limit | 08.3.1 Non-heat-treated meat products | Not permitted Assimilated Regulation (EC) No. 1333/2008 – Annex II Rows 1501-1750
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Similar failures noted for carmoisine (E 122) and tartrazine (E 102) |
E621 Group(s): Group I and E 620–625: Glutamic acid — glutamates | 12.6 Sauces | E620-E625 Permitted at up to 10g/kg, expressed as glutamic acid.
Assimilated Regulation (EC) No. 1333/2008 – Annex II Rows 2251-2500 |
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Annex 3 – Worked Examples
Example A:
A butcher produces beef burgers using a seasoning blend as part of the recipe. The packaging for the seasoning shows that this contains sulphur dioxide (E 220). The inspecting officer wants to verify that the use of the additive is in accordance with the authorisation.
- Determine the food category
The beef burgers are sold raw. The appropriate food category would therefore be:
Category 08.2 Meat preparations as defined by Regulation (EC) No 853/2004
- Determine whether the additive in question is permitted
Additive: Sulphur Dioxide E 220
Groups: Sulphur Dioxide – Sulphites E220 – E228
E220-E228 sulphur dioxide – sulphites are permitted up to 450mg/kg in burger meat with a minimum vegetable and/or cereal content of 4% mixed within the meat.
The documented recipe includes 500g rusks per 10kg batch. This equates to a cereal content of 5%, therefore, E220 is permitted in this product.
- Determine whether the product composition is compliant
E220-E228 is permitted up to 450 mg/kg. The notes indicate that this is the maximum level expressed as SO2 from all sources.
As the authorisation does not specify otherwise, in accordance with Article 11, the level applies to the limit in the food as marketed.
The technical data sheet for the seasoning confirms that it contains E220 at 1.5%. No other sulphites are present and there are no other sources of sulphites in the recipe.
The authorisation limit is in mg/kg. It is therefore necessary to calculate the volume of additive present in one kg of the burger meat being produced. This should be calculated as follows:
The recipe indicates that 250g of seasoning is added per 10kg batch of burger meat. Dividing both amounts by 10 shows that there is 25g of seasoning for every 1 kg of burger meat.
The concentration of SO2 in the seasoning is 1.5%.1.5% of 25 is 0.375, meaning there is 0.375g (equivalent to 375mg) of SO2 in 25g of seasoning and 1 kg of burger meat.
- Conclusion
If process controls are in place to ensure the recipe is adhered to, this would result in a finished product which contains 375 mg/kg SO2, which is within the level permitted by the authorisation.
Example B:
An officer is carrying out an inspection of a ready meal manufacturer. The business use monosodium glutamate (MSG) (E 621) as an ingredient and the inspecting officer wants to verify that it is being used in accordance with the authorisation. They select a sweet and sour chicken product to consider in detail as part of the verification process. The final product contains cooked chicken, sweet and sour sauce, onions, peppers and pineapple.
Determine the food category
There is no single product category which would cover the sweet and sour chicken, as a compound food.
Having reviewed the recipe and product specification, for the purposes of food additive authorisations, the officer considers the product is a compound food which comprises ingredients from different food categories:
Cooked chicken (40%) Category 8.3.2 Heat-treated meat product
Cooked vegetables (20%) Category 4.2.4.1 Fruit and vegetable preparations
Sauce (40%) Category 12.6 Sauces
Determine whether the additive in question in permitted
Additive: Monosodium glutamate (E 621)
Groups: Group I and group E 620–625: Glutamic acid — glutamates
From authorisation:
Part C(1) of Annex II in the authorisation details that E621 is a member of Group I, with a limit of 10g/kg either individually or combined with E620-E625, where that group is permitted in a food, expressed as glutamic acid.
| Ingredient | Group 1 |
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Chicken | Permitted as per group I criteria i.e. 10g/kg E620-E625, expressed as glutamic acid |
Vegetables | Permitted as per group I criteria i.e. 10g/kg E620-625, expressed as glutamic acid |
Sauce | Permitted as per group I criteria i.e. 10g/kg E620-E625, expressed as glutamic acid |
Determine whether the product composition is compliant
From the recipe and manufacturing instructions, the officer establishes that the MSG is added as an ingredient within the sauce and no other ingredients used contain the additives E620-E625
The recipe indicates that 200g MSG is added to each 10kg batch of sauce, which equates to 20g/kg of E621. The authorisation states a level, expressed as glutamic acid rather than monosodium glutamate.
The officer checks the data sheet for the MSG, which confirms it is entirely MSG with no other ingredients. From research they establish that MSG contains 87.72% glutamic acid, therefore, the 20g/kg equates to a glutamic acid content of 17.5g/kg in the sauce.
Conclusion
The average glutamic acid content across all components of the sweet and sour chicken would be 7g/kg (as the sauce makes up only 40% of the meal and there are no other sources of glutamic acid). However, each component of the compound food must comply with the conditions of use in the authorisation.
The presence of E621 at 20g/kg in the sauce, equivalent to 17.5g/kg glutamic acid, exceeds the permitted 10g/kg glutamic acid for that component of the food. The product is therefore non-compliant with the authorisation.
Annex 4 – Aide memoire
Considerations
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Identification of additives used
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Establishing Additive limits
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Adherence to limits
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Labelling
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Staff training
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Verification
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