6 replies to this topic

[Mr Risk]

I have recently moved to my current site, and this is my first role as a technical manager. The site produces frozen fish, coated fish and fishcakes etc.

What I am asking is, apart from the initial development of a product, is there a legal minimum for frequency of nutritional testing we need to carry out on our products? If there is no legal minimum, can someone recommend best practise? At the moment we test each product category once per year (previous tech manager's policy).

I am asking because I have noticed our lab bills are spiraling (the most expensive test being nutritional analysis) and the CEO is starting to question!!

[Charles.C]

Dear Mr Risk,

Welcome to the forum

Presumably these are retail products. Not in UK myself so can’t comment about any legal requirements however IMEX in related businesses outside Europe, the common tendency, rightly or wrongly, seems to be to use (acquired / calculated database) values for times well over a year. Any validity may obviously depend on the levels / exact items you are referring to and uniformity of ingredients like “white” fish etc but you are quite correct that private labs make a good living from this business.

My guess is that (any) legalities for this will vary across industries so hopefully someone in UK knows more ?? (once per year looks like a "default" choice; perhaps yr predecessor found very small historical variations [?], though this can be a pretty empirical measurement area IMEX).

Rgds / Charles.C

[Marco]

Dear Mr Risk,

It seems after doing some researches it seems to me that there is not a legal requirement for the periodic nutritional analysis.

I have attached three documents for your reference.

1. Codex Guideline point 5 says that the review should be done "periodically".

2. COUNCIL DIRECTIVE on nutrition labelling for foodstuffs (90/496/EEC) Art. 6(8)

3. Schedule 7 (of the Food Labelling Regulation) point 4© - Giving similar information as EU Directive.

I was not able to find good practice with regards to periodic nutritional analysis but IMEX I have seen it done annually.

I suppose if you have enough hystorical data you could analyse how the nutritional profile of the raw material varies (I believe this can depend if the fish is farmed or wild, specie, age when it is caught and area etc.) and get an average.

If no hystorical data are available you can refer to documents 2 and 3.

I hope the reply helps.


Regards,
Marco

Attached Files

•  CODEX_GUIDELINES_ON_NUTRITION_LABELLING.pdf   24.34KB   67 downloads
•  Nutrition_Labelling_for_foodstuffs__90_496_EEC_.pdf   45.39KB   47 downloads
•  SCHEDULE_7___NUTRITION_LABELLING.pdf   86.64KB   62 downloads

[Techy]

Hi

We have always carried out annual testing on all stanadrd products and quarterly for any where we are making a claim e.g low fat, or lower fat than std etc.

We recently asked our TSO about reducing testing and he said that we would have to increase testing on raw materials and then we would still need to demonstarte that the process was not causing any deviations.

We have decided to keep it to annual testing.

Regards

Techy

[Charles.C]

Dear Techy,

Sounds like a classic lose-lose conversation

What does TSO mean, something like EHSO I guess (had to query that one last month !) (or was it ESHO ?)

@ Marco, thks for yr digging. Im not too surprised at lack of info, in fact Codex often chooses the even more escapist "periodically as appropriate" which sounds more scientific I guess.

Rgds / Charles.C

[cazyncymru]

Dear Techy,

Sounds like a classic lose-lose conversation

What does TSO mean, something like EHSO I guess (had to query that one last month !) (or was it ESHO ?)

@ Marco, thks for yr digging. Im not too surprised at lack of info, in fact Codex often chooses the even more escapist "periodically as appropriate" which sounds more scientific I guess.

Rgds / Charles.C

TSO is Trading Standards

I can emphasise with the spiralling lab costs. what i have done is looked at the results for the past two years, and risk assessed to see what we are over testing on. i've cut our bill down to a quarter what it was!

we also do our nutritional on an annual basis, but rather that do each flavour (we make yogurts) we test our base product.

All i will say is that be careful which lab you use, and make sure that the methodology they use is relevant to your product!

c x

[Charles.C]

Dear Cazx,

TSO is Trading Standards

Many thks. So there really is a Trading Standards Officer, amazing. Looks like the UK hv a special department to make up hierarchical acronyms. I bet you've even got an ERBO.

Rgds / Charles.C

PS - apologiesto Mr Risk for off-topic.