Labelling of fruit concentrate

Dear IFSQN community, 

I am Heidi, nice to meet you and I hope one of you can help out with the following. 

We are making breakfast cereals and one of our ingredients is 'fruit concentrate' the concentrate is made from different ingredients e.g. apple, pear, strawberry, mint.... However we ingredients of the concentrate are varying per production. 

To get the ingredient list on the label right I was hoping you can advise on the best way to label the concentrate. Would just 'fruit concentrate' be sufficient? Or would 'fruit concentrate (in varying composition) be oke?

Thanks in advance!

Best, 

Heidi

I'd suggest having a read of Article 1(3)(a) of Directive 2012/12/EU as a starting point, as it sounds like at least some of the components may fit within the "several fruit" option given here. As this is a directive, there will be a local regulation in the Netherlands (and/or other markets in which you're selling the product) that implements this into law, so I'd also suggest reading whichever of those are applicable.

For the fruit parts you'll want to check with the supplied whether these are Concentrated Fruit Juices in accordance with Annex I(I)(1)(b) of Directive 2012/12/EU, as if so you'd probably be obliged to use this as the legal name, and separate out any non-fruit components such as the mint.

In any case, mint isn't a fruit so you would not be able to group this within "fruit concentrates".