2 replies to this topic

[CarolineE]

Hi All, 

 

I'm hoping you lovely collection of techie folk can help me.

I'm trying to establish whether a food colour (which EU legislation permits) is permitted or banned in individual EU member states.

e.g. E133 Brilliant Blue FCF - permitted at EU regs level but allegedly banned by Austria, Belgium, Denmark, France, Greece, Italy, Spain, Switzerland, Norway, Sweden and Germany.

 

My issue is that i need to give sound guidance to my company for EU exports, but i can only find permitted colours at an EU level. The 'oracle of google' shows me results from slightly dubious websites advocating additive bans on all sorts, so i'm a bit dubious to quote them. 

 

I can't afford a subscription to one of the food research bodies like Campden or Leatherhead.... any locals from the above list of countries that can guide me?

 

thanks in advance

 

Caroline

 

 

 

 

 

 

 

[Lesley.Roberts]

Hi there CarolineE

 

– this link may be of use:

 

https://ec.europa.eu...ves/eu_rules_en

 

My advice to your employer would be that access to Campden or Leatherhead is advised because  the list of additives that is permitted, can & does change, so – unless you have the time to check the legislation on a regular basis – ie. weekly or more often, there is the chance that something may be banned, and you wouldn’t know about it?.

 

 

If you are BRC accredited (ver 8) you will need to comply with section 1.1.8 which advises:

The company’s senior management shall have a system in place to ensure that the site is kept informed of and reviews:

 • scientific and technical developments

• industry codes of practice

• new risks to authenticity of raw materials

• all relevant legislation in the country where the product will be sold (where known).

 

 Interpretation Technical knowledge and information Food safety issues and legislative requirements are constantly changing. The objective of this clause is to ensure that sites remain up to date, are able to meet legislation and can adapt their food safety systems to protect against new threats. The company must be able to demonstrate that it maintains up-to-date knowledge of relevant legislation, scientific and technical developments, potential risks to raw materials (e.g. to the authenticity of the raw material) and industry codes of practice, such as Codex Alimentarius. Activities to achieve this may include:

• membership of a trade association that provides this service

• subscription to a service provider supplying legal updates

• help from government officials or local enforcement offices

• regular review of identified websites covering legislation and standards.

 In addition to information relating to food safety, the site must also have a system to obtain and review information relating to the authenticity of raw materials and the potential for substitution or dilution of the ingredients. This information will be required to demonstrate compliance with clause 5.4.1.

The company needs to demonstrate that it can readily access, either directly or through a third party, legislation relating to the product in the country, state or territory where:

• the product is manufactured

• the product is sold to the ultimate consumer (if known).

The auditor will therefore look for evidence of systematic checking and of the process for ensuring the information is transferred into action as necessary.

Sites must understand and comply both with relevant food safety and labelling legislation in the country of manufacture and with any applicable legislation where the product can reasonably be expected to be sold.

 

[Gerard H.]

Dear Caroline,

 

In the link below you find extra information about the use of E133. It's neighbouring the document in the links above from Lesley Roberts. As it was not so easy to find, I preferred to add it, hoping it helps you further.

 

https://eur-lex.euro...11R1129&from=EN

 

As far as I can see, the use of E133 is not forbidden in Europe (there has been a ban in the past in some countries, before its inclusion in the EU Regulations).

 

Please, note that Switzerland (as it isn't a Member State of the Union) may have its own legal criteria.

 

The use of the colour E133 is allowed, however:

• There are consumers or organisations with strong opinions about the use of food colours, specially for the ones that are artificially made, like E133
• The colour bleu in food may be perceived as "chemical" by consumers
• E133 doesn't fall under the additional labelling requirement about hyperactivity of children
• E133 is allowed in the European Union, however not in any situation neither in any food
• There may be dosage limits and restrictions of dosages when E133 is used in combination with other colours

So, you have to look to your product and to verify whether it complies to the legislation in the document in the link.

 

Kind regards,

 

Gerard Heerkens