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Does anyone treat Naturally Occurring Sulphites as and allergen?

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Bigblue1878

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Posted 24 January 2020 - 03:42 PM

Hi all,

 

New to this so apologise if this has been covered - tried to search but no joy.

 

I've an issue onsite with a RM coming in, spec states the material contains naturally occurring Sulphites. I know these are not required to be declared as an allergen on back of pack (FIR), but just wanted to see if anyone else treats them as an allergen on site and what would be the stance from BRC audits?

 

Our allergen policy states Sulphites not on site above 10ppm, so was thinking of adding a statement excluding naturally occurring sulphites ??

 

Also believe Garlic and Onions fall into this category



Charles.C

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Posted 24 January 2020 - 04:01 PM

Hi all,

 

New to this so apologise if this has been covered - tried to search but no joy.

 

I've an issue onsite with a RM coming in, spec states the material contains naturally occurring Sulphites. I know these are not required to be declared as an allergen on back of pack (FIR), but just wanted to see if anyone else treats them as an allergen on site and what would be the stance from BRC audits?

 

Our allergen policy states Sulphites not on site above 10ppm, so was thinking of adding a statement excluding naturally occurring sulphites ??

 

Also believe Garlic and Onions fall into this category

 

Hi Bigblue,

 

The above seems to imply that  naturally occurring Sulphites have no "allergenic" consumer consequences ? Really ?.

 

I assume the 10ppm is a specific allergen kit  detection limit ? IIRC lower values are feasible for some allergens.  Validation of 10 ppm?

 

I think this has been discussed here previously but don't offhand remember where.

 

Relevance may relate to the specific RM.


Kind Regards,

 

Charles.C


Bigblue1878

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Posted 24 January 2020 - 04:26 PM

Hi Charles,

 

I tend to agree that naturally occurring allergens would still have the same consequences, however FSA have confirmed no requirement to declare ingredients with sulphites that naturally occur.

 

The 10ppm is the limit where declaration is required should these be non naturally occurring.

 

If you have any idea where there the thread is that would be great



pHruit

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Posted 24 January 2020 - 04:26 PM

Hi all,

 

New to this so apologise if this has been covered - tried to search but no joy.

 

I've an issue onsite with a RM coming in, spec states the material contains naturally occurring Sulphites. I know these are not required to be declared as an allergen on back of pack (FIR), but just wanted to see if anyone else treats them as an allergen on site and what would be the stance from BRC audits?

 

Our allergen policy states Sulphites not on site above 10ppm, so was thinking of adding a statement excluding naturally occurring sulphites ??

 

Also believe Garlic and Onions fall into this category

 

We treat sulphite products as an allergen on site if the content is, or may be, above 10ppm in the form we're using/handling, including those for which labelling dec wouldn't be required.

The labelling position is a separate question to whether there is a potential cross-contamination risk (albeit a low one given the actual figures) that you need to assess/control.



The Food Scientist

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Posted 24 January 2020 - 05:19 PM

In the US, even if it was naturally occurring, you shall still declare it on label if it is above 10ppm

 

My company had a recall on a product that had naturally occurring sulfites (>10ppm) for not declaring on label. 


Edited by The Food Scientist, 24 January 2020 - 05:20 PM.

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


joaopoeiras

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Posted 15 February 2020 - 09:55 PM

Hello,

 

Can someone please help me ?  Is there a statment / official position on this by the EFSA ?

 

Thank you very much



cdreineri

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Posted 06 April 2020 - 11:35 AM

Hi!

 

I have a similar problem: I work in only manufacturing site (labelling is not in our scope) and a very reputable supplier sent the following information for ginger powder:

- Allergen declaration: None

- Comments: contains naturally occurring sulphates at less than 150 mg/kg

 

This is more than 10ppm so we will treat as an allergen on site. 

 

For labelling purposes, I found this interesting FSA document. What I understand from it is that you can omit declaration for UK market, as it is naturally occurring, but have to declare for EU market:

https://www.food.gov...al-guidance.pdf (page 19)

 

I assume that's why the supplier declared allergen as none. Doesn't make a lot of sense to me, though.


Edited by cdreineri, 06 April 2020 - 11:36 AM.


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Ryan M.

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Posted 06 April 2020 - 02:05 PM

Why do people find this difficult?  Guess what...most allergens are NATURALLY occurring, do we label the others?  You bet.  What about gluten, akin to sulfites, is naturally occurring do we label it?  You bet.

 

FDA requires that processors declare the presence of sulfites when the concentration meets or exceeds 10 ppm. The usage and/or concentration of the sulfiting agent found in the food will determine whether it will be declared on the label as an ingredient (to be discussed later in the chapter.)

 

https://www.fda.gov/.../80337/download



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pHruit

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Posted 06 April 2020 - 02:26 PM

Hi!

 

I have a similar problem: I work in only manufacturing site (labelling is not in our scope) and a very reputable supplier sent the following information for ginger powder:

- Allergen declaration: None

- Comments: contains naturally occurring sulphates at less than 150 mg/kg

 

This is more than 10ppm so we will treat as an allergen on site. 

 

For labelling purposes, I found this interesting FSA document. What I understand from it is that you can omit declaration for UK market, as it is naturally occurring, but have to declare for EU market:

https://www.food.gov...al-guidance.pdf (page 19)

 

I assume that's why the supplier declared allergen as none. Doesn't make a lot of sense to me, though.

Is the bit I've marked in red a typo?
If it does indeed say sulphates then it isn't an allergen, so that makes life easier! Nonetheless it's probably worth checking with your supplier.

Equally if it's sulphites then unless the declaration make specific reference to the EU allergen list, it could simply be the case that it isn't considered an allergen in the country of manufacture.  

Otherwise yes, it appears to fall within the UK's technical guidance on the "naturally occurring" bit. Article 9(1)© of Regulation (EU) 1169/2011 does actually say "any ingredient or processing aid listed in Annex II or derived from a substance listed in Annex II...", and in a strict sense a natural sulphite content is neither an ingredient nor processing aid. Nonetheless I find the position a bit odd - if the purpose is to inform consumers of the presence of a substance that may harm them then this seems like a strange gap to me...



cdreineri

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Posted 06 April 2020 - 02:47 PM

Is the bit I've marked in red a typo?
If it does indeed say sulphates then it isn't an allergen, so that makes life easier! Nonetheless it's probably worth checking with your supplier.

Equally if it's sulphites then unless the declaration make specific reference to the EU allergen list, it could simply be the case that it isn't considered an allergen in the country of manufacture.  

Otherwise yes, it appears to fall within the UK's technical guidance on the "naturally occurring" bit. Article 9(1)© of Regulation (EU) 1169/2011 does actually say "any ingredient or processing aid listed in Annex II or derived from a substance listed in Annex II...", and in a strict sense a natural sulphite content is neither an ingredient nor processing aid. Nonetheless I find the position a bit odd - if the purpose is to inform consumers of the presence of a substance that may harm them then this seems like a strange gap to me...

 

Indeed... it's a typo  :doh:.

The list of allergens given by supplier is the one in Annex II of Regulation (EU) 1169/2011. Anyway, on our end, I will treat it as an allergen for manufacturing process purposes (colour-code utensils, cleaning protocol...). 

 

I think I unintentionally diverted the thread. Answering to the original post:

- We do treat them as allergen in my site. However, we are not a sulphite over 10ppm free site.

- I think you can add "excluding naturally occurring". I don't agree with how the law is written for this but, in terms of legal cover, if the law allows not to declare naturally occurring...why would you have to test for those or reject them from your site if they won't change your declaration to consumer?

- No idea about onion or garlic 

 






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