Jump to content

  • Quick Navigation
Photo

Do we need to list sulfites as ingredients for Canadian products?


  • You cannot start a new topic
  • Please log in to reply
4 replies to this topic

#1 3kdi

3kdi

    Grade - Active

  • IFSQN Associate
  • 10 posts
  • 1 thanks
0
Neutral

  • United States
    United States

Posted 29 April 2013 - 04:34 PM

Hi all,

I am trying to determine if we are required to list sulfites in our ingredients or if we are to mention the possibility of their presence. We have a product that uses a spice containing 0.04ppm sulfites. The spice is added to raw product at a ratio of 3:20, making the presence of the sulfites even less. If anyone has solid knowlegde in regards to this please let me know. Thanks



#2 SpursGirl

SpursGirl

    Grade - MIFSQN

  • IFSQN Member
  • 114 posts
  • 77 thanks
26
Excellent

  • United States
    United States
  • Gender:Female
  • Location:PA

Posted 29 April 2013 - 08:39 PM

Hi 3kdi


This is an extract from the Health Canada website regarding allergen labelling.....

"Sulphites will still have to be declared at any level of use when directly added to a food as a food additive or when indirectly added to a food as components of an ingredient that is not exempted from component declaration. In addition, the new regulations will require that sulphites added as components of an ingredient exempted from component declaration will have to be declared when the total amount of sulphites contained within the food is 10 parts per million or more in the finished product"


In your case as the spices are exempt from component declaration as long as the total sulphite concentration is less than 10 ppm in the finished product you do not need to label with an allergen declaration.


I hope that helps!



Sarah



Thanked by 1 Member:

#3 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 17,376 posts
  • 4836 thanks
943
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 30 April 2013 - 01:14 AM

Dear SpursGirl / 3kdi,

Sulphites will still have to be declared at any level of use when directly added to a food as a food additive or when indirectly added to a food as components of an ingredient that is not exempted from component declaration. In addition, the new regulations will require that sulphites added as components of an ingredient exempted from component declaration will have to be declared when the total amount of sulphites contained within the food is 10 parts per million or more in the finished product


Based on my experiences of potential complexities encountered while attempting to understand labelling rules in an Ireland related parallel thread I am rather nervous to enter this one but, out of the frying pan …..

It seems to me that one over-riding principle in labelling decisions for any country where allergens are (or may be) involved is – the topic is a minefield of opportunities to be “WRONG”. So just like SpursGirl, one can only hope that any advice helps rather than hinders. And expect emendations.

In present case, I am guessing that SpursGirl quote comes from Q1-A1 in this link –

http://www.hc-sc.gc....0_qa_qr-eng.php
(stated to be operative after Aug4,2012)

Please note that this article relates to prepackaged food. OP’s item is ?? Consequences are ??

Chronology-wise, whether this is the definitive / relevant / complete / current statement I do not know. Hopefully yes.

Other questions in the list given in this link may relate depending on, for example, what product is actually involved (?). Some specific exemptions are in Q16.

Assuming top quote is usable, are there still not 2 possibilities based on whether the ingredient itself is exempted from component declaration or not ?, ie the 10ppm tolerance does not over-ride the first sentence ?
So are spices invariably exempt from declaration ? Seems unlikely but maybe SpursGirl knew this to be the case in which case I agree with her opinion ? Maybe it also depends on the product, specific spices, spice levels, whatever. I have no idea unfortunately.

Also see Q28, 29.

Over to next contributor.

Rgds / Charles.C

PS - i also noticed this rather blunt comment in a feb.2011 article stated to have now been updated on Aug3,2012 -

For example, if a prepackaged food contains the ingredient "spices", that food will be required to list any allergens, gluten sources, or sulphites present in the spices.


http://www.hc-sc.gc....11_23bk-eng.php

(ADDED LATER, also see post #5): It appears that the above quoted (2011) comment was incompletely stated by HC, and similarly repeated in the later News Release of Aug,2012, eg -

1. Labelling of "hidden" priority allergens

Up until now, food labels did not have to declare when a priority allergen was used to make an ingredient like spices or flavours. Now, labels on products will have to let consumers know when these allergens are in the product, either in the ingredient list or in a "contains" statement.

Parents and consumers should look for the allergen in the ingredient list as usual (components of an ingredient like spices may be in brackets) or look for a "contains" statement after the ingredients, like "Contains: XXXXX".

( http://www.hc-sc.gc....2-130fs-eng.php )

Kind Regards,

 

Charles.C


#4 SpursGirl

SpursGirl

    Grade - MIFSQN

  • IFSQN Member
  • 114 posts
  • 77 thanks
26
Excellent

  • United States
    United States
  • Gender:Female
  • Location:PA

Posted 01 May 2013 - 01:19 PM

Hi



From my experience of working with labelling in Canada 'spices' are exempt from breakdown declarations however you do need to declare any allergens contained within that compound ingredient. For example I have a spice mix in one of my products that contains mustard seeds so i declare as "spices (contains mustard)".


However the OP was asking specifically about sulphites and the regulations state that with respect to sulphites if the ppm is less than 10ppm in the finished product there is no requirement to declare the sulphites with the compound ingredient, Looking at the information the OP gave regarding sulphite levels it looks most likely that the level is below 10ppm so he does not require to declare the sulphites.


Obviously this is just my view and I may be wrong however this is how I present my labels in Canada and I have not had any issues with the regulatory departments.



S



#5 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 17,376 posts
  • 4836 thanks
943
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 01 May 2013 - 01:42 PM

Hi

From my experience of working with labelling in Canada 'spices' are exempt from breakdown declarations however you do need to declare any allergens contained within that compound ingredient. For example I have a spice mix in one of my products that contains mustard seeds so i declare as "spices (contains mustard)".

However the OP was asking specifically about sulphites and the regulations state that with respect to sulphites if the ppm is less than 10ppm in the finished product there is no requirement to declare the sulphites with the compound ingredient, Looking at the information the OP gave regarding sulphite levels it looks most likely that the level is below 10ppm so he does not require to declare the sulphites.

Obviously this is just my view and I may be wrong however this is how I present my labels in Canada and I have not had any issues with the regulatory departments.

S


Dear SpursGirl,

Clearly we interpret the (HC) English Language differently. Maybe it's a Canadian variation. No problem.

Anyway, there's an easy way for the OP to find out. :smile:

Rgds / Charles.C

(ADDED LATER) PS -

After re-re-reading and backtracking through the Health Canada website, I have concluded your understanding of (HC) English and HC’s labelling intentions are superior to mine. :smile:

Just to reiterate some of previous comments -

(a) I deduce that Health Canada have decided that a level of 10 ppm sulphites in the finished product is a “critical” level for sulphites . (quote, A28, “Documented reactions to sulphites occurred at levels of 10 parts per million or above”, http://www.hc-sc.gc....0_qa_qr-eng.php )

(b) I deduce that where sulphites are directly added to a food, a declaration is required at any sulphite level, eg would be required at a level of 1ppm. (A1, A28, ibid).

© I infer that previously (eg ca 2010) spices were legally exempted from having all (??) their components declared on the label. ( quote “Previously, certain components of ingredients were exempted from declaration. For example, when spices or seasonings were used as ingredients in other food, their components were not required to be included in the list of ingredients.” A24, ibid)

(d) I deduce that, operationally, after August 2012, the situation for spices has changed with respect to occurrences of “mustard” and sulphites (and ??). The change for sulphites (assuming overall exemption status of spices unchanged from [c]) is defined by A1, A28, ibid. Specifically, for spices, no sulphite declaration is required if level below 10ppm in finished product

(e) The above implies that the statement I previously quoted in the PS of post #3, ie “For example, if a prepackaged food contains the ingredient "spices", that food will be required to list any allergens, gluten sources, or sulphites present in the spices” is incompletely stated on Health Canada website.

(f) paras (a-d) are not relevant if the (unknown) food is exempted from providing an ingredient declaration, see A16, ibid (and ??).

(g) the originating Feb.2011 document for above discussion (prior to various modifications) appears to be http://gazette.gc.ca...dors28-eng.html , the sulphite-relevant content looks mainly to be in sections B.01.010.2, B.01.010.3. It is neither brief nor simple. :smile:

(g) (the ??s) emphasise that the above comments are opinions only.

Kind Regards,

 

Charles.C





0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users

EV SSL Certificate