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Listing component ingredients in component ingredients.

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Kelly S

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Posted 21 August 2014 - 11:40 PM

I'm having trouble finding any literature about this so any help is appreciated.


We make ready to eat salads and most of our dressings are made in-house. Consequently we have quite a few ingredient statements that look like this- Dressing (French Dressing, Tomato Pesto, Seeded Mustard, Dijon Mustard, Sugar, Water). 


My question is, should I be listing the ingredients of the French dressing and Tomato Pesto as they are both component ingredients of a component ingredient. I know the 5% rule but as I said earlier, I having trouble finding anything that covers this scenario.

Edited by Charles.C, 25 August 2014 - 02:54 AM.
Unless Aust.language, COMPONENT should prob. be written COMPOUND ??

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Posted 25 August 2014 - 01:30 AM

Hi WyldIce,



Refer below


6             Declaration of compound ingredients


(1)           A compound ingredient must be declared in the statement of ingredients either –


(a)          by declaring the compound ingredient by name in its appropriate place in the statement of ingredients, and listing its ingredients in brackets after the name of the compound ingredient, in descending order of ingoing weight in the compound ingredient, as specified in the Table to this clause; or

(b)          by declaring all of the ingredients of the compound ingredient separately as if they were individual ingredients of the final food.


(2)           However, paragraph 6(1)(a) does not apply to food standardised in Standard 2.9.2.


(3)           The ingredients in an alcoholic beverage, standardised in Standards 2.7.2 to 2.7.5 of this Code, do not need to be declared in a statement of ingredients if the alcoholic beverage has been declared as an ingredient in the food.




Table to clause 6


Amount of compound ingredient in the food

Ingredients of the compound ingredient to be included in the statement of ingredients

5% or more

All ingredients

less than 5%

1.  If applicable, any substance listed in the Table to clause 4 of Standard 1.2.3; and

2.  all food additives in the compound ingredient that perform a technological function in the final food



The link to the Food Standards Code AU/NZ for this specific is issue - http://www.comlaw.go...ils/F2013C00983


Also a helpful link for labelling http://www.foodsafet...redients-v5.pdf

(I know this is an NZ document, but the only difference in labelling law between NZ and AU is that country of origin labelling is not required here in NZ.


As far as my understanding/interpretation goes. You'd need to follow the "Table to clause 6" even if it is a compound ingredient of a compound ingredient.


I did a 1 year stint in NPD and developed a bacon and lentil soup. I found to comply with compound labelling law that the ingredients for the bacon, increased the ingredient list substantially.


Ingredients: Water, Lentils (13%), Vegetables 
(13%) (Carrot, Spinach Onion), Bacon (7%) 
(Pork, Water, Salt, Sugar, Mineral Salts, [451, 
452, 450], Dextrose, Vegetable Fibre [Potato], 
Antioxidant [316], Preservative [250], Honey, 
Smoke Flavour), Tomato Paste, Wheat Flour, 
Vegetable Stock (Hydrolysed Vegetable Protein 
[Soy]), Olive Oil, Dijon Mustard, Flavours (Milk), 
Garlic, Salt, Lemon Juice Concentrate, Emulsifier 
(Soya Lecithin), Spices, Herbs.

Edited by Ragga, 25 August 2014 - 01:33 AM.

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Posted 25 August 2014 - 03:46 AM

Dear Wyldice,


I presume component should have been written as compound unless Australian dictionary not = NZ.


Assuming that the document kindly linked by Ragga applies (its title looks promising), and that the  5% rule (or others) is triggered, the basic answer to yr OP as noted by Ragga appears to be YES, assuming option (a).( but also taking note of a few exceptions sprinkled here and there).


The diffficulty partly arises from yr “convenient”  Process notation, ie yr (completed) “Dressing” which then requires some re-interpretation  from a  labelling POV


eg (If I understand correctly)(definitely not Guaranteed) -


In Process notation,  completed “Dressing” =

Dressing (French Dressing, Tomato Pesto, Seeded Mustard, Dijon Mustard, Sugar, Water)


The labelling requires –

French Dressing ( a,b,c,d,e ) where a,b,c etc in order of weight +  due notice of 5% rule (++)

Tomato Pesto (f,g,h,i,j) ditto

Ad infinitum, eg next 4 items


Option (b) looks of some interest but necessitates further calculations / cross-comparisons, increases chance of error. Rock and Hard Place?. :smile:


The flowchart in Ragga’s pdf looks more like the fabrication details of a motor car. The text is relatively helpful.


Hard to believe that anyone will ever check the labelling minutiae unless there is a specific “MOChaos” for this purpose. Or an incident occurs.


Rgds / Charles.C


PS - Logically, there could seemingly also be 3rd,4th,etc layers. This might require "nesting" as in mathematical / PC statements. or perhaps there's an exception for this somewhere. :smile:

Kind Regards,



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