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Sulfur Dioxide declaration on packaging

Allergen labelling

Best Answer Ryan M., 15 June 2019 - 03:46 PM

If you are not adding the SO2 and the PPM is below 10 in your finished product you do not need to declare it.  If you are putting "NATURAL" on your label be vary wary in any SO2 you have in the product, even if you declare it.  The natural claim has been coming under fire the past 10 years or so in the US even though there is no regulatory definition beyond natural flavors, and chicken (thanks USDA).

 

You can declare it by two options:

 

1.  As the last ingredient on your ingredient declaration.

2.  Separate statement, similar to allergens, such as "Contains Sulfites".

 

"Treated with Sulfites" or something of the like is not appropriate as it is not clear if sulfites levels are below or above 10 PPM...consumer confusion, which you could get called out for.  However, I see this all the time on labels so not really sure how much enforcement there is on it.

 

If I were you I'd fix the issue with your suppliers and reject any raisins incoming that have sulfites at 10 PPM or above.

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#1 ailin

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Posted 13 May 2019 - 01:31 AM

Hi All. 

 

I would like to seek some advice on packaging labeling. 

 

I have a natural raisin product, where it origin process do not added any permitted preservative (SO2), it is a natural sun dry process. 

But, we had done the incoming checking on a few batch, the preservative SO2 was detected more than 10ppm. Sometime it is within the specification below 10ppm, the result was inconsistent. 

 

According to regulation, product with added SO2 or with SO2 level more than 10ppm would need to be delcared. 

 

If i declare as "Contains Sulfur Dioxide." , can i not to include the contained of preservative in the ingredient list. As the origin was not added with preservative. 

 

Or any other method to put on labeling....  :helpplease:  :helpplease:

 



#2 poppysnoss

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Posted 13 May 2019 - 12:19 PM

Sulphur dioxide is an almighty pain. It is exceptionally volatile and many methods of analysis are almost at their limit of detection down at that level. One drop in a titration can literally make a difference between a result of above or below 10ppm.

 

Is your product always sent for analysis packed as it would be purchased by the consumer? Exposure to the air quickly affects SO2 readings which can cause inconsistencies and this can include sample preparation time is the lab.



#3 ailin

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Posted 13 May 2019 - 02:55 PM

Sulphur dioxide is an almighty pain. It is exceptionally volatile and many methods of analysis are almost at their limit of detection down at that level. One drop in a titration can literally make a difference between a result of above or below 10ppm.

 

Is your product always sent for analysis packed as it would be purchased by the consumer? Exposure to the air quickly affects SO2 readings which can cause inconsistencies and this can include sample preparation time is the lab.

 

Hi poppysnoss..

 

We take the sampling during incoming quality check from the bulk pack, means during receiving from the supplier.

After quality checked, we will proceed for repacking into smaller package. 

 

Isn't mean the SO2 might be evaporate with time..., when it was undergoes process (eg. repacking/ exposure to air)? 

 

I'm am dilemma either to update my labeling or not.... hope to seek more advice. 



#4 FoodSafetyPlanet

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Posted 13 May 2019 - 06:28 PM

Hi A,

 

Check your specifications and supplier agreement. 

 

If you are receiving, testing, and accepting product that does not meet labeling requirements, it could get messy. 

 

How long has this been occurring? Have you checked other alternatives (calibrating device, employee training, etc.)?



#5 Hank Major

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Posted 13 May 2019 - 09:28 PM

Correct me if I'm wrong, but doesn't treating raisins with sulfur dioxide prevent them from browning? So if the raisins stay yellow (golden) then they have been treated?



#6 ailin

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Posted 16 May 2019 - 01:39 PM

Hi A,

 

Check your specifications and supplier agreement. 

 

If you are receiving, testing, and accepting product that does not meet labeling requirements, it could get messy. 

 

How long has this been occurring? Have you checked other alternatives (calibrating device, employee training, etc.)?

 

Yup... specification do not state any preservative added.    :unsure:

So we didn't test for SO2 cause it is not added.

We realize it during the random sampling for yearly analysis test (send out for external accredited lab).  

 

From there we started the checking on every batch of receiving. Then the story become like tat..... 

 

Just get the some feedback from supplier, this might be happen for fresh crop......  :yeahrite:



#7 ailin

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Posted 16 May 2019 - 01:53 PM

Correct me if I'm wrong, but doesn't treating raisins with sulfur dioxide prevent them from browning? So if the raisins stay yellow (golden) then they have been treated?

 

mmm... from what i understand. 

Natural sun dried (untreated)... the end product will be in dark brown/ brown/ dark colour. 

For those yellow (golden) raisins are normally treated..... ya.. 

SO2 somehow act as a preservative, antioxidant... prevent the caramelisation effect... 



#8 GMO

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Posted 15 June 2019 - 04:36 AM

Is it possible to include in your ingredients listing...

Ingredients: [specific dried fruit], contains naturally occurring sulphites.

(Putting sulphites in bold, I'm on my tablet.)


Edited by GMO, 15 June 2019 - 04:37 AM.


#9 Ryan M.

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Posted 15 June 2019 - 03:46 PM   Best Answer

If you are not adding the SO2 and the PPM is below 10 in your finished product you do not need to declare it.  If you are putting "NATURAL" on your label be vary wary in any SO2 you have in the product, even if you declare it.  The natural claim has been coming under fire the past 10 years or so in the US even though there is no regulatory definition beyond natural flavors, and chicken (thanks USDA).

 

You can declare it by two options:

 

1.  As the last ingredient on your ingredient declaration.

2.  Separate statement, similar to allergens, such as "Contains Sulfites".

 

"Treated with Sulfites" or something of the like is not appropriate as it is not clear if sulfites levels are below or above 10 PPM...consumer confusion, which you could get called out for.  However, I see this all the time on labels so not really sure how much enforcement there is on it.

 

If I were you I'd fix the issue with your suppliers and reject any raisins incoming that have sulfites at 10 PPM or above.







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