7 replies to this topic

[Sugar and Spice]

Hi everyone, we are packing fruit products (canning) and use calcium chloride as a firming agent in some of our products.  We've got a big discussion going on internally on processing aids and ingredients.  What will calcium chloride be classified as?

[FurFarmandFork]

FDA on processing aids: https://www.accessda....cfm?fr=101.100

 

(ii) Processing aids, which are as follows:

(a ) Substances that are added to a food during the processing of such food but are removed in some manner from the food before it is packaged in its finished form.

(b ) Substances that are added to a food during processing, are converted into constituents normally present in the food, and do not significantly increase the amount of the constitutents naturally found in the food.

(c ) Substances that are added to a food for their technical or functional effect in the processing but are present in the finished food at insignificant levels and do not have any technical or functional effect in that food.

(iii) Substances migrating to food from equipment or packaging or otherwise affecting food that are not food additives as defined in section 201(s) of the act; or if they are food additives as so defined, they are used in conformity with regulations established pursuant to section 409 of the act.

 

 

 

Use this as a flowchart to make the final call. Common problems I had were "what is insignificant", since FDA has no definition. I typically read that as "could not somehow be further reduced under the processing method used and is at a level that does not cause a change in composition/sensory characteristics, safety, or nutrition".

 

In your product, it sounds like CaCl is used to change the characteristics of the final product, and your product would be different if you were not using it. To me that sounds like an additive/ingredient and not a processing aid. To help clarify point C in the fda reg above, I always clarify that the intended interpretation is: "...and do not have any final or sustained technical or functional effect in that food.

 

Further downstream as a customer of yours, if I made a fruit salad with your products, I would continue to list CaCl as a processing aid, since it has an ongoing effect of keeping some of my fruits firm. However, if I were to blend it into a smoothie where it is now in an "insignificant" amount and the firmness of the fruit is no longer a function of the composition of my product, I would potentially consider it a processing aid from upstream.

 

As always, don't let anyone at your company bring a competitor label in as proof that you should or shouldn't do anything. This is your decision, not your competitors', and there are a million examples out there of why "someone else did it" isn't good enough for label compliance.

[Sugar and Spice]

Thank you so much!  This is really helpful!!!

[Charles.C]

The previous post made sense to me from a processing aids POV.  It's not my area of expertise but i wonder if answer to this query might also depend on  local Regulations ?.

 

Calcium chloride has many applications in the food industry where it is used either as food additive or as food processing agent. It is listed as a permitted food additive in the European Union for use as a sequestrant and firming agent, and considered as “generally recognized as safe” (GRAS) by the U.S. Food and Drug Administration. The main applications for calcium chloride in the food industry are:

 

 Food Additives.pdf   2.46MB   65 downloads

 

I understand from the (highly) complex attachment below (but am only too happy to be proved incorrect) that chemicals which are regarded as GRAS for a defined (generally?) application(s) are not classified as food additives in USA ?

 

 US Food Additive Regulatory Program,2011.pdf   728.17KB   48 downloads

 

But South Africa ?

 

PS - JFI, one consumer's viewpoint -

 

http://www.consumeth...-it-in-my-food/

[Ryan M.]

Additive =/ processing aid.  It largely depends on the technical function and it's lasting effects, if any on the product.

 

For what it is worth...the FDA's definition between an ingredient or material that is GRAS versus additive is simply the route it takes to ensure the safety of the material.  A GRAS material can be claimed as such by the manufacturer or company producing it with some literature they have or they develop, or obtain from someone.  An additive is more of a "certification" process that is filed with the FDA for the specific material/ingredient to be determined if it is safe to use.

 

Many ingredients are considered GRAS through historical usage in certain products and applications.  Some materials cannot be GRAS, and have to go through the additive process such as artificial food colors and dyes.

 

The previous post made sense to me from a processing aids POV.  It's not my area of expertise but i wonder if answer to this query might also depend on  local Regulations ?.

 

Food Additives.pdf

 

I understand from the (highly) complex attachment below (but am only too happy to be proved incorrect) that chemicals which are regarded as GRAS for a defined (generally?) application(s) are not classified as food additives in USA ?

 

US Food Additive Regulatory Program,2011.pdf

 

But South Africa ?

 

PS - JFI, one consumer's viewpoint -

 

http://www.consumeth...-it-in-my-food/

[Charles.C]

Hi everyone, we are packing fruit products (canning) and use calcium chloride as a firming agent in some of our products.  We've got a big discussion going on internally on processing aids and ingredients.  What will calcium chloride be classified as?

 

Hi MvanEeden,

 

I assume this is basically a labelling question.

 

The answer must ultimately depend on yr local regulatory laws. I hope you have access to the current version.

 

SA food regulations seem to not use the GRAS system and are more oriented to EC style. I suspect every country's Regulations have (some of) their own characteristics, eg see this comparitive review (not including SA) -

 

https://www.ncbi.nlm...les/PMC3725665/

 

The latest relevant SA related document (2014) I could find is attached below. [Stated to be "proposed".]  It's stated definitions of "food additive" and "processing aid" are respectively -

 

"processing aid" means any substance consumed as a food ingredient by itself, intentionally used in the processing of raw materials, foods or its ingredients, to fulfill a certain technological purpose during treatment or processing and which may result in the non-intentional but unavoidable presence of residues or derivatives in the final product;

 

"food additive" means any substance, regardless of its nutritive value, that is not normally consumed as a food by itself and not normally used as a typical ingredient of the food, which is added  intentionally to   a    food   for   technological   (including   organoleptic) purposes   in    the manufacture, processing, preparation, treatment, packing, packaging, transport or storage of the food, and results, or may reasonably be expected to result (directly or indirectly) in such a substance, or its by-products, becoming a component of, or otherwise affecting the characteristics of such foods and excludes any substance added to foods for maintaining or improving nutritional qualities or any contaminants and sodium chloride, but exclude processing aids;

 

So first Question - is CaCl₂ a "substance consumed as a food ingredient by itself" [the presence of the word "ingredient" is confusing IMO, I ignored it]? afaik, the answer is NO(??). If NO is correct, presumably not a processing aid.

 

The decision clearly has labelling  importance due to this -

 

Processing aids and carry-over of food additives
42.         Subject to the conditions of regulations 38 to 41,-
(a)         a food additive carried over into a food in an amount sufficient to perform a technological function  in that food as a result of the use of raw materials or other ingredients in which the additive was used, shall be indicated in the list of ingredients; and (b)  a food additive, except a preservative, carried over into foods at a level less than what is required to achieve a technological function, as well as processing aids, are exempted from declaration in the list of ingredients.

 

As a further comment, if CaCl₂ is regarded as an additive, the Regulation's Annex 1 (= CATEGORIES OF ADDITIVES THAT MAY BE IDENTIFIED BY THEIR CATEGORY NAME IN A LIST OF INGREDIENTS) includes "*Firming agent" (meaning of "*" undefined) which as I understand is the operational intention.

 

 R.429, 29 May,2014 - FOODSTUFFS, COSMETICS AND DISINFECTANTS ACT, 1972 (ACT No.54 OF 1972).pdf   3.67MB   22 downloads

[Charles.C]

addendum

 

Just found  a later (2015) (but still draft) short section which would modify the above post. No specific definition of "food additive" (unchanged?) but has added a new term of miscellaneous additives and expanded the definition of processing aid.
 

 

"miscellaneous additives" means any food additive which is used or intended to be
used primarily as an acidity  regulator, anti-caking agent, antifoaming agent,
bleaching agent, bulking agent, carbonating agent, carrier, colour retention agent,
emulsifier, emulsifying salt, firming agent, flavour enhancer, flour treatment agent,
foaming agent, gelling agent, glazing agent, humectants, packaging gas, propellant,
raising agent, sequestrant, stabiliser, thickener, but does not include any processing
aid; and

 

"processing aid" " means any substance consumed as a food ingredient by itself,
intentionally used in the processing of raw materials, foods or its ingredients, to fulfill
a certain technological purpose during treatment or processing and which may result
in the non-intentional but unavoidable presence of residues or derivatives in the final
product, but does not perform technological effect in the final product.

 

This change looks to support Earth's interpretation in Post 2 assuming that the "firming" assumptions are in fact valid.

 

I wonder if any of these drafts are ever approved.

 

 S.Africa, Act54-1972 - draft regulations relating to misc additives.pdf   279.13KB   9 downloads

[Tresa]

Hi everyone,

 

we have an ingredient in our recipe that according to the supplier used Calcium Chloride as a processing aid. 

 

Do we need to declare the Calcium Chloride as sub ingredient of ingredient in our ingredient list on the label or not?

 

Thanks,