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Allergen Declaration

#allergen #sulphites #label

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Posted 16 February 2018 - 08:54 AM

Good day!!


Just need to clarify regarding the sulphite declaration in product label. Based on below article published by BRC, sulphite used as preservative regardless of concentration/amount shall be declared on label (according to sulphite decision tree; Page 8).


But according to published EU regulation (refer to attachment 2) "Under allergen labelling legislation, when sulphites are present at above 10 mg/kg/litre in the finished product, whether or not they have a technological function, a clear declaration of sulphites and/ or sulphur dioxide is always required."

Both guidelines are quite confusing.


On our current operation, we intentionally added sulphite during in-process of product as preservative but the level of sulphite on finished product is <10 ppm. Should we declare it or not?


Hoping someone can clarify this to me.






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Posted 16 February 2018 - 08:56 AM

Refer to below articles.

Attached Files

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Posted 16 February 2018 - 03:50 PM

Complex but not confusing. Similar standard here in US. Here's a flowchart that hopefully will help clarify.




Are you adding sulphites to the product for the functional use as a preservative?


>Yes  >  Sulphites need to be on the label regardless of final concentration


>No  >  Continue to next question



Is the final concentration of sulphites >10ppm?


>Yes  >Sulphites need to be declared on the label so folks with sensitivities can avoid.


>No   > Sulphites do not need to be declared, since they aren't added as a preservative and are at a concentration that does not pose a risk to those with sensitivities.



Does that make sense? It's a labeling transparency thing. If you're deliberately adding them then you have to declare them on the label since they're a functional component of your food. However if I happen to use a little bit of wine in my cheese sauce, but then retort it, the only reason they need to be declared is if the pose a potential health hazard, otherwise they're "incidental".

Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
Consulting for companies needing effective, lean food safety systems and solutions.

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