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Do we need to state E330 in ingredients on back of energy balls pack?


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#1 Fijiball

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Posted 19 November 2019 - 03:04 PM

Hello Team,

 

We make energy balls .We use egg powder which contains E330 as a thickening agent. Do we need to state this in ingredients on back of pack.

 

Regards



#2 pHruit

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Posted 19 November 2019 - 03:10 PM

Where are you selling the energy balls?

Rules and requirements on additives and carryover vary between regions.



#3 The Food Scientist

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Posted 19 November 2019 - 03:49 PM

I believe E330 is Citric Acid and it is not considered a thickening agent. Are you sure of the E number?


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


#4 Fijiball

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Posted 20 November 2019 - 01:38 PM

we sell in europe and uk.Yes it is E330 Citric acid



#5 pHruit

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Posted 20 November 2019 - 01:55 PM

In that case, the answer is "maybe".
You're using the egg powder as a thickening agent, and this contains citric acid as an additive (or processing aid?), so the citric acid would thus be considered as a "carryover" additive in your finished product.

In accordance with Article 20(b)(1) of Regulation (EU) 1169/2011 this might be exempt from a requirement to declare on the label:

 

Without prejudice to Article 21, the following constituents of a food shall not be required to be included in the list of ingredients:...

(b) food additives and food enzymes:
(i) whose presence in a given food is solely due to the fact that they were contained in one or more ingredients in that food, in accordance with the carry-over principle referred to in points (a) and (b) of Article 18(1) of Regulation (EC) 1333/2008, provided that they serve no technological function in the finished product.

 

The underlined part I've emphasised is going to be the key factor that you will need to determine, as for example if the citric acid is achieving some degree of useful pH/acidity control (for example), then it would be performing a technological function and would thus need to be declared as "Acid: Citric Acid" or similar.






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