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Ingredient and allergen declaration

Started by , Sep 03 2019 11:41 AM
12 Replies

Hello everyone, Id like to ask about ingredient and allergen declaration when it comes to this:

 

This is a newly quoted ground cinnamon we will be buying and the following ingredients are in it on the spec sheet:

 

Corn fiber, grounded cinammon, soy oil, cinnamic aldehyde, fd&c yellow #5 lake, fd&c red #40 lake, fd&c blue #1 lake

 

They said this product is non allergenic but I see soy oil, so I asked them about it. But what about the rest of the ingredients? How will I be including them on the final labeled product? I have to admit I have never seen this much ingredients listed on a bottle of ground cinnamon before... is this right? 

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In the EU there is an exemption for highly refined oils from allergens, and it looks like the FDA has the same approach - see e.g. point 15 in the attached: https://www.fda.gov/...ons-and-answers

 

As for the other ingredients, you'll need input from someone more familiar with labelling on your side of the Atlantic, but at face value it sounds as though the spec is more of a "cinnamon-like product" than actual ground cinnamon?

Relative proportions are not clear from the list given, but the corn fibre is presumably basically a filler to bulk it out, that is coloured to match actual cinnamon using the various FD&C lakes, and then flavoured using (possibly artificial/synthetic) cinnamic aldehyde.

If you want "actual" ground cinnamon then I'd be inclined to ask if they have an alternative spec/product, or looking elsewhere.

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In the EU there is an exemption for highly refined oils from allergens, and it looks like the FDA has the same approach - see e.g. point 15 in the attached: https://www.fda.gov/...ons-and-answers

 

As for the other ingredients, you'll need input from someone more familiar with labelling on your side of the Atlantic, but at face value it sounds as though the spec is more of a "cinnamon-like product" than actual ground cinnamon?

Relative proportions are not clear from the list given, but the corn fibre is presumably basically a filler to bulk it out, that is coloured to match actual cinnamon using the various FD&C lakes, and then flavoured using (possibly artificial/synthetic) cinnamic aldehyde.

If you want "actual" ground cinnamon then I'd be inclined to ask if they have an alternative spec/product, or looking elsewhere.

 

Now the thing is they do have actual cinnamon, but you know its way more costy. "Ceylon Cinnamon" aka real cinnamon is quite expensive and not really easy to import. which is why there are cheaper alternatives, which is this one.  But yes I guess I must ask for relative proportions. and I asked about the soy oil. 

Now the thing is they do have actual cinnamon, but you know its way more costy. "Ceylon Cinnamon" aka real cinnamon is quite expensive and not really easy to import. which is why there are cheaper alternatives, which is this one.  But yes I guess I must ask for relative proportions. and I asked about the soy oil. 

Ah ok, understood - you'd mentioned ground cinnamon, and the ingredient list included many things that aren't that :ejut:

It does look like a lot of ingredients, but you may be able to get them to supply a "cleaner" version of the same material. The various colours are really just about making it look like cinnamon, so if you're using it for the taste alone then these are largely going to be superfluous.

Depending on finished product labelling requirements you could also ask about the source of the Cinnemaldehyde component, but I'd be quite surprised if this wasn't artificial - not really a problem as long as you're not dealing with any "no artificial flavours" type requirements.

Indeed if you only want the flavour of cinnamon then you could potentially just buy Cinnemaldehyde and avoid all of the other ingredients completely, but then you'd have no "actual" cinnamon component.

Ah ok, understood - you'd mentioned ground cinnamon, and the ingredient list included many things that aren't that :ejut:

It does look like a lot of ingredients, but you may be able to get them to supply a "cleaner" version of the same material. The various colours are really just about making it look like cinnamon, so if you're using it for the taste alone then these are largely going to be superfluous.

Depending on finished product labelling requirements you could also ask about the source of the Cinnemaldehyde component, but I'd be quite surprised if this wasn't artificial - not really a problem as long as you're not dealing with any "no artificial flavours" type requirements.

Indeed if you only want the flavour of cinnamon then you could potentially just buy Cinnemaldehyde and avoid all of the other ingredients completely, but then you'd have no "actual" cinnamon component.

 

Sadly no, not for flavoring purposes! We'll just be taking this ground cinnamon and repacking it into our bottles with our own labels. There is ground cinnamon in there, but they probably used low amounts due to its price and added all those additives to cover up. My issue will fall into what and what no to include on the final product label and I know for a fact many consumers won't like whats listed on there... :/

Hmm, yes, I see your predicament - the classic case of the consumer wanting pure handpicked organic ingredients, but not wanting to actually pay for it...

Definitely worth asking the supplier about the function of the various components, as there may be a carryover exemption for one or two of them. I can't see the colours being exempted though, nor the cinnamaldehyde. 

Highly refined oil does not contain protein which causes allergenic reaction, so maybe that's why they're saying that there is no allergen in the products. Just make sure there is no cross-contact in their manufacturing facility for other allergens, as you need that information to decide what you will put on your label.

 

The colors have to be declared by their certified name as per fda requirements..

The FDA requires food manufacturers to list all ingredients on the label, with the ingredients used in the greatest amount first, followed in descending order by those in smaller amounts. The label must list the names of any FDA-certified color additive (e.g., FD&C Blue No. 1 or the abbreviated name, Blue 1).  With the exception of carmine/cochineal extract, color additives exempt from certification can be listed collectively as “artificial colors,” “artificial color added,” “color added,” or equally informative terms, without naming each one. Because of potential allergic reactions in some people, carmine/cochineal extract are required to be identified by name on food labels.

 

https://www.fda.gov/...swers-consumers

I sort of vaguely get the impression that this thread is describing a potential  example of Food Fraud ??!

I sort of vaguely get the impression that this thread is describing a potential  example of Food Fraud ??!

 

It certainly could be!

Description/labelling will be critical, as certainly "ground cinnamon" could easily lead people to make the same inference I did, i.e. that it's supposed to actually be ground cinnamon... ;)

I sort of vaguely get the impression that this thread is describing a potential  example of Food Fraud ??!

 

hmm I am not sure that this could be considered a fraudulent material because the supplier gave us two options: The real "ceylon" real ground cinnamon, which is way more costly and this one. The supplier is also approved and hold a GFSI certificate. Also I did a quick google search and some companies in fact do not use real, pure cinnamon. And in here we are actually using real cinnamon along with it's "Cinnamic Aldehyde" , but with other additions to make it less expensive which of course I need to check if its entirely legal (hence not fraudulent). But from our standpoint, the label is not going to look very nice and I know I can't NOT include all those ingredients on there. 

Hmmm...I don't know if you can really call it "ground cinnamon".  The first ingredient is corn fiber.  You need to find a labeling expert who has legal experience because depending on the product name it could be considered mislabeling.

 

As far as the ingredients you have to list them as your supplier lists them, there is no way around this.  I'm afraid you might be having to choose pure ground cinnamon because customers won't like to see all that stuff on the label....unless you price it far below pure ground cinnamon.

 

Good luck, definitely a challenge!

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hmm I am not sure that this could be considered a fraudulent material because the supplier gave us two options: The real "ceylon" real ground cinnamon, which is way more costly and this one. The supplier is also approved and hold a GFSI certificate. Also I did a quick google search and some companies in fact do not use real, pure cinnamon. And in here we are actually using real cinnamon along with it's "Cinnamic Aldehyde" , but with other additions to make it less expensive which of course I need to check if its entirely legal (hence not fraudulent). But from our standpoint, the label is not going to look very nice and I know I can't NOT include all those ingredients on there. 

 

The FF question relates to aspects such as "blending" + Post 9 with the intention of Economic Gain.

Wow, that ground cinnamon ingredient statement is quite a mess. I agree with Ryan, I'm not sure how this qualifies as ground cinnamon. The only way I could see this being labeled is as a "ground cinnamon blend" or something similar. I tried scouring the FDA site to see if there were any specific standards of identity for ground cinnamon; but I don't see anything that really dives deeply into standards of identity. There is a section on labeling of spices and flavorings (CFR 21 101.22), which is somewhat helpful, but doesn't work to establish whether or not ground cinnamon can have all those ingredients.

 

As far as the soy oil, as long as it is highly refined, it isn't an allergen. You should get an allergen statement from your supplier for this "cinnamon" showing it isn't an allergen concern.

 

It also sounds like your goal is to have a clean label, and you definitely won't reach that goal with this "ground cinnamon". I'd definitely suggest you go for the real cinnamon.


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