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#1 shea quay

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Posted 19 April 2013 - 12:17 PM

Hi Everyone. Once again, Shea Quay is about to expose his shocking ignorance of labelling legislation!

We are looking at a new supplier of flour who adds extra ingredients during the milling stage such as wheat gluten, bean flour, malted wheat flour etc etc to achieve a consistant final product. These ingredients are present at less than 1% of the flour, and may, or may not actually be present in the flour depending on the raw material being milled.

I've asked the miller for a risk assessment regarding the presence of these minor ingredients. He asked me what a risk assessment was. I congratulated him on his honesty, and bid him a good day.

So the question is, to label or not to label. Should I have these possible occasional ingredients listed as ingredients on retail packs? I appreciate the simple answer would be "if in doubt, label," but obviously this would have a cost impact for retail packaging. Any feedback would be appreciated.



#2 Simon

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Posted 24 April 2013 - 02:14 PM

Surely someone wants to talk with Shea Quay, I'm sure it will brighten your day. Posted Image

Regards,
Simon


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#3 Charles.C

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Posted 24 April 2013 - 03:10 PM

Hi Everyone. Once again, Shea Quay is about to expose his shocking ignorance of labelling legislation!

We are looking at a new supplier of flour who adds extra ingredients during the milling stage such as wheat gluten, bean flour, malted wheat flour etc etc to achieve a consistant final product. These ingredients are present at less than 1% of the flour, and may, or may not actually be present in the flour depending on the raw material being milled.

I've asked the miller for a risk assessment regarding the presence of these minor ingredients. He asked me what a risk assessment was. I congratulated him on his honesty, and bid him a good day.

So the question is, to label or not to label. Should I have these possible occasional ingredients listed as ingredients on retail packs? I appreciate the simple answer would be "if in doubt, label," but obviously this would have a cost impact for retail packaging. Any feedback would be appreciated.


Dear shea quay,

An obvious comment I fear but are you able to state the "minor ingredients" here ? Perhaps some other flour expert here may know if they do constitute a risk, eg yet another allergen. :smile:
(Although if the risk was this simple, i must aver high confidence in yr capabilities to have spotted it already).

Rgds / Charles.C

Kind Regards,

 

Charles.C


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#4 moskito

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Posted 27 April 2013 - 02:23 PM

Hi shea quay,

what is your final product? For use in biscuits: even if these are minor ingredients, these ingredients are still ingredients to be declared. There is an intentional use and not something like "carry over of an additive" or the use of additives with no further effect in the final product (ascorbic acid in flour). This "raw material" is in my view a mixure of several ingredients which has to be listed in the ingredient list. I would do for biscuits.

Rgds

moskito


Hi Everyone. Once again, Shea Quay is about to expose his shocking ignorance of labelling legislation!

We are looking at a new supplier of flour who adds extra ingredients during the milling stage such as wheat gluten, bean flour, malted wheat flour etc etc to achieve a consistant final product. These ingredients are present at less than 1% of the flour, and may, or may not actually be present in the flour depending on the raw material being milled.

I've asked the miller for a risk assessment regarding the presence of these minor ingredients. He asked me what a risk assessment was. I congratulated him on his honesty, and bid him a good day.

So the question is, to label or not to label. Should I have these possible occasional ingredients listed as ingredients on retail packs? I appreciate the simple answer would be "if in doubt, label," but obviously this would have a cost impact for retail packaging. Any feedback would be appreciated.



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#5 shea quay

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Posted 28 April 2013 - 09:46 PM

"confidence in my capabilities"?!?!?!? Have you EVER read any on my posts, Charles!!!!
I must admit, I posted this in the hope someone would pull something from the darkest realms of European legislation that would get me out of jail, but have to agree with moskito's comments. As mentioned, the possible ingredients are wheat based, so don't have an allergen risk, but do have a functional reason, no matter how occasional they are (e.g. if the protein is low).
And thanks for the bump, Simon. Looking forward to informing purchasing in the morning!



#6 Charles.C

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Posted 29 April 2013 - 12:30 AM

"confidence in my capabilities"?!?!?!? Have you EVER read any on my posts, Charles!!!!
I must admit, I posted this in the hope someone would pull something from the darkest realms of European legislation that would get me out of jail, but have to agree with moskito's comments. As mentioned, the possible ingredients are wheat based, so don't have an allergen risk, but do have a functional reason, no matter how occasional they are (e.g. if the protein is low).
And thanks for the bump, Simon. Looking forward to informing purchasing in the morning!


Dear Shea quay,

Reading is one thing, U..g is sometimes something else. It’s a bit like Politics, or Boxing. :smile:

It appears to me that you are posing 2 questions, partially related to knowledge on flour and equally to knowledge on labeling and safety risk –

(a) the legal requirements for labeling ingredients with respect to % concentration. (QUID?)
(b) the legal requirements in the case of a product which may, or may not, contain certain added ingredients and whose consumer risk is unknown other than likely to be allergenic due possession of wheat allergenic factors.
(c) (Possible) selling location(s) unknown.

I suggest the answers are –

(a) It depends on the relevant legislation and the latter depends on (c). Some EC requirements have been discussed here on other threads.
(b) The apparent absence of knowledge on any risk factors relating to the “added ingredients” (other than the possibility of wheat allergens) surely makes the safety aspect essentially unknown (eg Food Grade?). This would appear to preclude meaningful safety-related labeling and anyway render the commercialization of such a product highly questionable without further data.

One word which (rightly or wrongly) occurs frequently in the legalistic context of (acceptable) allergenic manufacturing protection via “may contain” statements for US products is “unintentional”. How far this convenient concept can be extrapolated to other factors I have no idea.

I have assumed in the above that you are not referring to items classified as processing aids (if otherwise see 1st link below).

Sorry if any failure to correctly understand yr posts in this thread has caused any interpretive errors above.

Rgds / Charles.C

PS – I don’t know if relevant or not but the Ireland website does have some quite impressive looking stuff on labelling –

eg http://www.fsai.ie/f...html#processing
http://www.fsai.ie/l...ng_of_food.html
http://www.fsai.ie/faq/allergens.html
Attached File  labelling of food in Ireland 2007.pdf   1.13MB   5 downloads

PPS - If you are satisfied that the ”occasional ingredients" are ”Food Grade” other than exhibiting wheat allergen characteristics which you have already taken (labelling) care of , I guess some of the text in above upload may define whether labelling is mandatory or not, eg –

Substances not regarded as ingredients
additives serving no technological function in the final food where their presence in food is only because they were contained in one or more of the ingredients of that foodstuff. For example, sulphur dioxide used as a preservative in dried fruit such as raisins (to prevent them browning) will have no function when the dried fruit is added to a cake mix* (see also sub section (b) on additives)

(Pg13)

Additives carried over from other ingredients
Some additives may be present in a food because they were contained in one of the ingredients. They need only be indicated in the list of ingredients if they perform a significant technological function in the final food (see previous sub-section on substances not regarded as ingredients). Whether or not the additive performs a technological function in the final product will depend both on the ingredient containing the additive and the food to which it is added. For example, preservatives used in fruit puree will not necessarily be performing the same function when the fruit is added to a heat-treated yoghurt.
However, carry-over additives that are derived from allergenic ingredients (i.e. those listed in Appendix IV but excluding those listed in Appendix V) are considered as ingredients and must always be declared in the list of ingredients (see also sub-section (e) on allergens).

(Pg 17)

However, if a declaration is apparently required by the above or similar pronuciations, the best handling of the "occasional" factor remains unclear to me. The notorious "may contain" or the more elegant "manufactured in an environment or using equipment where ..." are both contenders except that the latter seems to require 5-10 line blockbusters in some US examples. In context of OP, Revision cost vs Cost of discovery of an omitted / legally required declaration ?.

3PS – Further illustrations of the European complexity for requirement / non-requirement–
http://www.reading.a...w/label/a-3.htm

In the case of ingredients which -
(a) are similar or mutually substitutable;
(b) are likely to be used in the preparation of a food without altering its nature or its perceived value;
(c) are not additives, specified allergenic ingredients or ingredients originating from a specified allergenic ingredient; and
(d) constitute less than 2 per cent of the finished product,
such ingredients may be referred to in the list of ingredients by means of the phrase "contains … and/or …", where at least one of no more than two such ingredients is present in the finished product.


Ingredients not needing to be named
The following exemptions are made to the general requirement to label ingredients:
• Constituents which are temporarily separated and later re-introduced (in the original proportions) - an example would be egg white and egg yolk.
• Additives which were in an ingredient (and are 'carried over' into the final product) and which serve no significant technological function in the finished product.
• Any additive used solely as a 'processing aid' (as defined in the Regulations, see Definition). If any residues of the processing aid still act in the final product, they have to be listed as additives.
• Any substance (other than water) used as a solvent or carrier of an additive (and used only at level which is strictly necessary).
• Any substance which is not an additive but which is used in the same way and for the same purpose as a processing aid.


4PS - Of course, if the final product is a petfood, the terminology "Variable formulation" seems to get you off the hook :smile: -
http://www.extension...-pet-food-types

Kind Regards,

 

Charles.C





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