Allergen Declaration

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.

 

Thanks,

 

Lelou

Refer to below articles.

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".

Can see this is an old post. Have I understood right: I have a fruit juice with sulphites. I add the fruit juice to a recipe, and then I have <10ppm sulphites. 

Can I leave it off the list entirely? Or I am simply exempt from 'allergen labelling' (making it bold). 

An Allergen declaration is necessary in the EC if:

 

 

12 Sulphur dioxide and sulphites at concentrations of more than 10 mg/kg or 10 mg/litre in terms of the total SO2 which are to be calculated for products as proposed ready for consumption or as reconstituted according to the instructions of the manufacturers;

 

See annex

 

https://eur-lex.euro...4096854&from=EN

 

See:

Annex II

 

I guess the added juice is grape juice since the fruit juice guideline states that:

 

“For grape juice, where sulphitation with sulphur dioxide of the grapes has been used, desulphitation by physical means is authorised, provided that the total quantity of SO2 present in the final product does not exceed 10 mg/l;”

 

 

http://https://eur-l...4581513&from=EN

 

See:

Annex 1

II  AUTHORISED INGREDIENTS, TREATMENTS AND SUBSTANCES

 

For other juices as grape juice SO2 is a not authorized ingredient that has to be questioned.

Ok but what about the carry over rule? Doesn't that mean it is exempt, right?

Ok but what about the carry over rule? Doesn't that mean it is exempt, right?

If you are the person adding the sulphite as a preservative, there is no carry over rule.

The carry over rule applies to an additive in an ingredient that no longer has a function in the final product.

That's correct. I am not adding the sulphites. They are in a raw material. And no function in final product. Thus the carry over applies, correct?

That's correct. I am not adding the sulphites. They are in a raw material. And no function in final product. Thus the carry over applies, correct?

You still have to declare it as an allergen if more than 10 ppm remains in the product.

We are not over 10ppm in the final product. We are way under 10ppm.
So I am looking for confirmation that it isn't necessary to include in the ingredients list.
Thanks ☺️