Percentage of characterizing ingredients?
Hi guys!
Everyone here has been incredibly helpful in the past, so I'm hoping someone could perhaps give me some pointers once again. We are now on our way to moving towards ISO 22000 accreditation (!!) and the pressure is on for all our ducks to be in a row. We had a third party auditor here just to give us an idea of how ready we are, and she sat and discussed labeling with me. I've stated this before, but I'm really not an authority on food labeling. I just get told to do it since I'm in IT and know the software. Anyway... :P
She explained the procedure that when we have a "characterizing" ingredient, usually an ingredient appearing in the name of the product, we need to declare a percentage for that ingredient in the ingredient declaration. I.e. for a product called Raspberry Jam we would need to specify the percentage of raspberry in the product.
Now, I've chatted to my boss, and his major concern with this is that he feels such a declaration might be problematic in terms of trade secrets. We manufacture, for instance, a bread mix (premix) that customers of ours can use to make a Cheese & Onion bread. It is a dry mix, they add their wet ingredients and bake. Based on information from the auditor, I would need to then declare something such as Cheese (15%)* and onion (17%)* on the label. I have no problem, but as stated above my boss is worried that competitors would then be able to determine a rough copy of our recipe since they would then know our percentages of cheese and onion. Are there any ways around this, or is this something that we just have to bite the bullet on? Suggestions would be HIGHLY appreciated!
Curiously, would it also be better (or required) to identify the onion as "onion flakes" and the cheese as "cheese powder"?
*made these up! xD
Thanks a ton, guys and gals.
Not so much a food safety issue, but a requirement in the EU and probably elsewhere. If it's declared in the name of the product then the % of the ingredient must be shown. You can get round it by not naming the ingredient in the product name e.g. Jam, but it won't help the sales. I'm not sure if you are required to state the form of the ingredient (powdered cheese), but it seems likely to me.
If your boss believes that the recipes are easily copied and that the competition will take the market, maybe he doesn't believe that there is any unique sales proposition (USP) to the product. Surely you select the suppliers and ingredients carefully? If you are using fresh fruits, you would ensure that the amount of damaged or rotten fruit is kept to a minimum and so on? There must be something you can offer over the competition?
Hi Jeronkey,
As indicated by previous post, this is very likely a regulatory issue dependant on specifically the location where the product is to be utilised and potentially also it's status, eg intermediate /retail product.
You are going to have to investigate the (local?) labelling rules and particularly the degree of flexibility permitted.
For example I have experienced the situation where one country accepted "white fish" on the label, another location required the Latin species name.
Hello,
yes within the EU these regulations have to be followed. Please have also in mind, that in the EU mixed ingredients have also to show their list of ingredients.
E.g. your cheese shouled be "cheese (milk, spices, rennet, chemical agents ...)".