28 replies to this topic

[chowell]

What is your take on claiming food additives that are in raw materials? As in, say you have sugar that has an added anti-clumping agent *from the supplier*. You aren't adding the anti-clumping agent, but this sugar is then added to your final product. You aren't adding the anti-clumping agent and this agent doesn't have anything to do with your final product. I haven't been able to track down specific legislation that explicitly says whether or not you have to declare it. 

[SQFconsultant]

What is the anti-clumping agent make up?

[The Food Scientist]

Check out this thread:

 

https://www.ifsqn.co...processing-aid/

[chowell]

What is the anti-clumping agent make up?

It's a silicon dioxide which is a food additive according to Canadian legislation, that much I've found. In regards to the thread posted above, looked through that, and what I'm seeing is if it has relation to the functional property of the finished product it has to be declared, if it doesn't then it doesn't have to be declared. This additive only serves to make it not clump in storage, it has nothing to do with the finished good. 

[Scampi]

This should help you out 

 

 

http://www.inspectio...48488947?chap=9

 

"defined a processing aid as a substance that:

• is used for a technical effect in food processing or manufacture;
• when used, does not affect the intrinsic characteristics of the food; and
• when used, results in no or negligible residues of the substance or its by-products in or on the finished food"

So if you have test results that agree with bullet 3, then you do not have to declare it on the label

[chowell]

This should help you out 

 

 

http://www.inspectio...48488947?chap=9

 

"defined a processing aid as a substance that:

• is used for a technical effect in food processing or manufacture;
• when used, does not affect the intrinsic characteristics of the food; and
• when used, results in no or negligible residues of the substance or its by-products in or on the finished food"

So if you have test results that agree with bullet 3, then you do not have to declare it on the label

 

That's where I run into the issue of my research though. It's not a processing aid, it's a food additive, but not a food additive that we add. I can't seem to find a specific clause relevant to food additives in raw materials. 

[Scampi]

I'm going to email my inspector and ask on your behalf!  Because we MAY be in the exact same situation.....

 

 

Have you seen this?

https://www.canada.c...ing-agents.html

Edited by Scampi, 14 March 2019 - 05:35 PM.

[The Food Scientist]

But do you mention "sugar" on your finished product ingredient statement? From my experience in Nutrition facts & ingredient statements on finished product you should include sub ingredients of each ingredient you add in your recipe (finished product). But its probably in very little amounts that you dont need to include it.  You can contact Dept of Agriculture/FDA to make sure so you know the legality of it, my advice!

Edited by The Food Scientist, 14 March 2019 - 05:40 PM.

[Scampi]

Once I hear back from my inspector I will post the response.  We currently use salt without an anti-caking, so have not had to worry about it, but it's good for me to know as well moving forward

[chowell]

But do you mention "sugar" on your finished product ingredient statement? From my experience in Nutrition facts & ingredient statements on finished product you should include sub ingredients of each ingredient you add in your recipe (finished product). But its probably in very little amounts that you dont need to include it.  You can contact Dept of Agriculture/FDA to make sure so you know the legality of it, my advice!

 

We do, and agreed for the sub ingredients part, but it's my understanding that food additives need to be declared regardless of amount (as opposed to processing aids). 

 

I did find this on the CFIA site. 

 

"Sulphites, like any other food additive, are required to be declared in the list of ingredients of food labels when they are added directly to a prepackaged product as an ingredient or a component of an ingredient that is not exempt from component declaration."

 

That leads me to believe yes..

[Mariam Y.]

I don't know if this might help or not.. but try checking it out..

 

http://www.inspectio...12932341?chap=2

 

Our labelling specialist says if the supplier provided the info. that they add any additives to their products, then we have to add that on our labels as well..

Edited by MariamY, 14 March 2019 - 07:33 PM.

[chowell]

I don't know if this might help or not.. but try checking it out..

 

http://www.inspectio...12932341?chap=2

Definitely did, that's where I found the quote from my last post. Thanks for posting the link so others can interpret. 

[Mariam Y.]

Definitely did, that's where I found the quote from my last post. Thanks for posting the link so others can interpret. 

 

There are a lot of details to catch up in that link, but I think it is worth reading..
 

Let's see how others will interpret it.

 

Good luck !

[The Food Scientist]

We do, and agreed for the sub ingredients part, but it's my understanding that food additives need to be declared regardless of amount (as opposed to processing aids). 

 

I did find this on the CFIA site. 

 

"Sulphites, like any other food additive, are required to be declared in the list of ingredients of food labels when they are added directly to a prepackaged product as an ingredient or a component of an ingredient that is not exempt from component declaration."

 

That leads me to believe yes..

 

 

I would say add it to the ingredients list as sub-ingredient for sugar, since it is an additive (to be on the safe side). I would still contact any federal agency to double check. I do believe sulfites are required to be declared because they are considered allergens. 

[Scampi]

Ok, whoa before you go any further, that addendum for sulphites is because they are an allergen..........so you're not really comparing apples to apples on that one

 

If the additive to your sugar =s less than a 10th of a % of the finished good you probably needn't include it................my inspectors out til Monday, but is usually really quick at responding.

[chowell]

Ok, whoa before you go any further, that addendum for sulphites is because they are an allergen..........so you're not really comparing apples to apples on that one

 

If the additive to your sugar =s less than a 10th of a % of the finished good you probably needn't include it................my inspectors out til Monday, but is usually really quick at responding.

Yeah trying not to jump the gun on that one, the words "like any other food additive" seem to make that an inclusive sentence to all of them. 

 

That's sort of what I'm trying to research more now is the level at which you must claim. I think for our particular product it's slightly more than 0.1% of the finished product. 

[Scampi]

I think I may have found the answer for you!

 

http://www.inspectio...12932341?chap=2

 

Food preparations that generally do not have to declare their components

The following table lists food preparations and mixtures which, when used as ingredients in other foods, are exemptfrom declaring their components (except for the components listed in tables C and D below) [B.01.009(2), FDR]. Refer to Food allergen, gluten and added sulphites declarations for additional exceptions.

Table B: Preparations exempt from a component declaration Item Preparation/Mixture 1. food colour preparations 2. flavouring preparations 3. artificial flavouring preparations 4. spice (definition) mixtures 5. seasoning or herb (definition) mixtures 6. vitamin preparations 7. mineral preparations 8. food additive (definition) preparations 9. rennet preparations 10. food flavour-enhancer preparations 11. compressed, dry, active or instant yeast preparations

[Mariam Y.]

 

I think I may have found the answer for you!

 

http://www.inspectio...12932341?chap=2

 

Food preparations that generally do not have to declare their components

The following table lists food preparations and mixtures which, when used as ingredients in other foods, are exemptfrom declaring their components (except for the components listed in tables C and D below) [B.01.009(2), FDR]. Refer to Food allergen, gluten and added sulphites declarations for additional exceptions.

Table B: Preparations exempt from a component declaration Item Preparation/Mixture 1. food colour preparations 2. flavouring preparations 3. artificial flavouring preparations 4. spice (definition) mixtures 5. seasoning or herb (definition) mixtures 6. vitamin preparations 7. mineral preparations 8. food additive (definition) preparations 9. rennet preparations 10. food flavour-enhancer preparations 11. compressed, dry, active or instant yeast preparations

 

 

Yes, in the link we found above, it means that he doesn't have to declare food additives in sugar (Table B), even though sugar is not mentioned in table A as an exempt component.

 

Right?

[The Food Scientist]

Yes, in the link we found above, it means that he doesn't have to declare food additives in sugar (Table B), even though sugar is not mentioned in table A as an exempt component.

 

Right?

 

I dont see sugar in Table A. And I think what they mean here (Table B) is that you should not declare "ingredients" of the Food additive.... like what the additive is made of. Because many additives are made of several components. And I am thinking this is Canadian regulation and the original poster is in the U.S, perhaps it differs.

[Scampi]

No, it's actually Table B that applies, silicone dioxide is on the list of approved FOOD ADDITIVES, but in this case, since it's an ingredient IN an ingredient it looks like it does NOT have to be declared

 

And quite frankly, I've never seen it on an ingredient list on products in Canada.....

 

I will still be posting my inspectors response for absolute clarity

[Mariam Y.]

No, it's actually Table B that applies, silicone dioxide is on the list of approved FOOD ADDITIVES, but in this case, since it's an ingredient IN an ingredient it looks like it does NOT have to be declared

 

And quite frankly, I've never seen it on an ingredient list on products in Canada.....

 

I will still be posting my inspectors response for absolute clarity

 

I haven't seen it either.. It only states the "main" ingredient. 
The confusing part was that our label specialist said she would declare it, I didn't get to know her reference though... (I work & live in Canada)

[Scampi]

out of curiosity, who does your specialist work for???  Some are all about CYA 

 

We shouldn't be putting anything on the label we don't have to-----this would fall under the new "market fairness" requirement     It's not "fair" if you list it and the competitor doesn't!

[Mariam Y.]

out of curiosity, who does your specialist work for???  Some are all about CYA 

 

We shouldn't be putting anything on the label we don't have to-----this would fall under the new "market fairness" requirement     It's not "fair" if you list it and the competitor doesn't!

I don't know really... I always like to challenge one's references but I didn't get to do that this time...
 

Edited by MariamY, 15 March 2019 - 01:05 PM.

[chowell]

I dont see sugar in Table A. And I think what they mean here (Table B) is that you should not declare "ingredients" of the Food additive.... like what the additive is made of. Because many additives are made of several components. And I am thinking this is Canadian regulation and the original poster is in the U.S, perhaps it differs.

 

That's what I interpreted it as. And yes, looking for Canadian regulations on it since it's a Canadian product. Interested in the "market fairness" requirement though, as I haven't seen it on any Canadian labels either (although it sure does seem like it should be). 

[Scampi]

I think the market fairness has been seriously overlooked by lots of companies.........if this kind of food additive really ought to be on the label, then it's only fair that everyone start

 

But the fact that none of us have seen it on the label makes me think it really falls under Table B