10 replies to this topic

[JR Ball]

Good day. We are to use 50ppm sulphite level of desiccated coconut (DCN) as ingredient in our food product. We don’t want to declare allergens beyond 10 ppm. The DCN shall be added <2% as an ingredient. Since it will be diluted by a different product, is it safe that we may be able to dilute it w/ 98% unsulfured raw material and we declare it <10ppm? Thank you.

[Charles.C]

Good day. 

 

we are to use 50ppm sulfite level of desiccated coconut (DCN) as ingredient in our food product. we dont want to declare allergens beyond 10 ppm. the DCN shall be added <2% as an ingredient. since it will be diluted by a different product, is it safe that we may be able to dilute it w/ 98% unsulfited raw material and we declare it <10ppm?

 

Thank you

Hi JR Ball,

 

i think there is a recent parallel thread to this one discussing an analogous situation/query.

 

IIRC, the consensus was that such a Dilution Procedure is typically regarded as not appropriate to implement.

[pHruit]

Good day. 

 

we are to use 50ppm sulfite level of desiccated coconut (DCN) as ingredient in our food product. we dont want to declare allergens beyond 10 ppm. the DCN shall be added <2% as an ingredient. since it will be diluted by a different product, is it safe that we may be able to dilute it w/ 98% unsulfited raw material and we declare it <10ppm?

 

Thank you

Where are you planning to sell the product?
For the EU I don't see a problem with this - there are a reasonable number of products that use one or more raw materials contains SO₂ above 10ppm, but the concentration is below 10ppm in the final product, and it is thus exempt from labelling.

Whilst the result seems mathematically self-evident, it's probably not a bad idea to test the final product for some verification. You may also want to consider the mixing process and the type of product, as for example the potential to have inhomogeneity in a finished product would make things more difficult - e.g. if some parts of the batch have the potential to come out higher than others.

 

Hi JR Ball,

 

i think there is a recent parallel thread to this one discussing an analogous situation/query.

 

IIRC, the consensus was that such a Dilution Procedure is typically regarded as not appropriate to implement.

Is this the thread you were thinking of, Charles?

https://www.ifsqn.co...make-safe-food/

 

The context is somewhat different in that SO2 isn't a "contaminant" in the same sense, at least for EU purposes.

That the level falls below the declared threshold in the OP's recipe is simply a matter of the mathematics of combining in the proportions desired, so is perfectly permissible provided that the raw material and the finished product are both themselves fully compliant with all relevant regulations.

 

For example, let's assume that I'm the sort of monster who wants to take a lovely batch of chianti at 75ppm total SO2, and defile it by making a wine cooler using 10% chianti and 90% juice/water/sugar/flavourings (to make sure that we've properly destroyed any semblance of the love that went into making the wine in the first place). The resulting product will have a total SO2 content of 7.5ppm (at most), so would be below the declarable threshold. I may therefore need to sit in a corner and think about the decisions I've taken in life that have taken me to this point, but my product won't need allergen labelling for sulphites, and will be compliant with EU regs.

[Charles.C]

Where are you planning to sell the product?
For the EU I don't see a problem with this - there are a reasonable number of products that use one or more raw materials contains SO₂ above 10ppm, but the concentration is below 10ppm in the final product, and it is thus exempt from labelling.

Whilst the result seems mathematically self-evident, it's probably not a bad idea to test the final product for some verification. You may also want to consider the mixing process and the type of product, as for example the potential to have inhomogeneity in a finished product would make things more difficult - e.g. if some parts of the batch have the potential to come out higher than others.

 

Is this the thread you were thinking of, Charles?

https://www.ifsqn.co...make-safe-food/

 

The context is somewhat different in that SO2 isn't a "contaminant" in the same sense, at least for EU purposes.

That the level falls below the declared threshold in the OP's recipe is simply a matter of the mathematics of combining in the proportions desired, so is perfectly permissible provided that the raw material and the finished product are both themselves fully compliant with all relevant regulations.

 

For example, let's assume that I'm the sort of monster who wants to take a lovely batch of chianti at 75ppm total SO2, and defile it by making a wine cooler using 10% chianti and 90% juice/water/sugar/flavourings (to make sure that we've properly destroyed any semblance of the love that went into making the wine in the first place). The resulting product will have a total SO2 content of 7.5ppm (at most), so would be below the declarable threshold. I may therefore need to sit in a corner and think about the decisions I've taken in life that have taken me to this point, but my product won't need allergen labelling for sulphites, and will be compliant with EU regs.

Hi pHruit,

 

Well spotted. Yes, Yr link was the one I remembered.

 

I noticed (Wiki) these somewhat similar comments for US/EU although the US text appears potentially in disagreement with Post 6 of the above-mentioned link. (but depending on the list of "defects"). -
 

In 1986, the U.S. Food and Drug Administration banned the use of sulfites as preservatives on foods intended to be eaten fresh (such as salad ingredients).^[16] This has contributed to the increased use of erythorbic acid and its salts as preservatives.^[29]

Generally, U.S. labeling regulations do not require products to indicate the presence of sulfites in foods unless it is added specifically as a preservative;^[16] still, many companies voluntarily label sulfite-containing foods.^[30] Sulfites used in food processing (but not as a preservative) are required to be listed if they are not incidental additives (21 CFR 101.100(a)(3)), and if there are more than 10 ppm in the finished product (21 CFR 101.100(a)(4))

In the European Union, "EU law requires food labels to indicate “contains sulfites” (when exceeding 10 milligrams per kilogram or per litre) without specifying the amount".^[32]
 

 

 

Regarding homogeneity It is unclear whether the OP's  intended mixing process is solid/liquid or solid/solid. (a non-viscous liquid/liquid system is presumably the ideal situation). Either way I hope the OP has a valid method to determine whether his final result is adequately homogeneous.  Or a liking for Russian Roulette.

 

I attach the FDA's seafood haccp viewpoint on sulphites -

 

 sulphites.png   95.23KB   0 downloads

[JR Ball]

Where are you planning to sell the product?
For the EU I don't see a problem with this - there are a reasonable number of products that use one or more raw materials contains SO₂ above 10ppm, but the concentration is below 10ppm in the final product, and it is thus exempt from labelling.

Whilst the result seems mathematically self-evident, it's probably not a bad idea to test the final product for some verification. You may also want to consider the mixing process and the type of product, as for example the potential to have inhomogeneity in a finished product would make things more difficult - e.g. if some parts of the batch have the potential to come out higher than others.

 

Is this the thread you were thinking of, Charles?

https://www.ifsqn.co...make-safe-food/

 

The context is somewhat different in that SO2 isn't a "contaminant" in the same sense, at least for EU purposes.

That the level falls below the declared threshold in the OP's recipe is simply a matter of the mathematics of combining in the proportions desired, so is perfectly permissible provided that the raw material and the finished product are both themselves fully compliant with all relevant regulations.

 

For example, let's assume that I'm the sort of monster who wants to take a lovely batch of chianti at 75ppm total SO2, and defile it by making a wine cooler using 10% chianti and 90% juice/water/sugar/flavourings (to make sure that we've properly destroyed any semblance of the love that went into making the wine in the first place). The resulting product will have a total SO2 content of 7.5ppm (at most), so would be below the declarable threshold. I may therefore need to sit in a corner and think about the decisions I've taken in life that have taken me to this point, but my product won't need allergen labelling for sulphites, and will be compliant with EU regs.

Hi pHruit, 

plan to sell the product to north america, EU, AU. 

 

procedure shall be to mix desiccated coconut w/ mashed raw material. a heterogenous mixture. 

maybe "dilution" might not be the best term it.

 

as i see, it looks like 50ppm sulfite would be detectable even added at <2%.

 

thanks for pinning the thread and thanks for your insights    

[JR Ball]

hi Charles C, 

 

it is solid/solid.

 

it is now becoming clear, understanding the consensus.

control method shall be at raw materials - COAs, to know sulfite levels. 

 

appreciate your responses. Thanks!

[Ryan M.]

Also get confirmation of sulfite levels in the other ingredients.  At a previous company we blended fruit bases and some of them contained coconut with sulfites added.  Some of the other ingredients contained sulfites, but less than 10PPM so it was not required to be labeled.  We had to get the information from our suppliers on sulfite levels that are naturally occurring or were added in the process, even when less than 10PPM to account for total possible sulfites in the coconut blended products.  In some cases we had to get the ingredients tested ourselves.  It was a long process, but worth it to have certainty.

[moskito]

Hi,

 

perhaps this example from bakery helps:

dough mixed with ingredients which sum up to 50-100 ppm sulphite

-> after baking (heat reduces sulphite) the content in the finished product is < 10 ppm -> no risk for sensitive consumers -> no declaration required

 

Rgds

moskito

[JR Ball]

Also get confirmation of sulfite levels in the other ingredients.  At a previous company we blended fruit bases and some of them contained coconut with sulfites added.  Some of the other ingredients contained sulfites, but less than 10PPM so it was not required to be labeled.  We had to get the information from our suppliers on sulfite levels that are naturally occurring or were added in the process, even when less than 10PPM to account for total possible sulfites in the coconut blended products.  In some cases we had to get the ingredients tested ourselves.  It was a long process, but worth it to have certainty.

we use raw fruits and fortunately, other ingredients used are not sulfited in nature, and are verified on COAs.

I would agree w/ the external testing. this maybe tedious - but the assurance that the product is at safe sulfite levels will make confident label declarations.

 

appreciate the feedback. Thanks!      

[JR Ball]

Hi,

 

perhaps this example from bakery helps:

dough mixed with ingredients which sum up to 50-100 ppm sulphite

-> after baking (heat reduces sulphite) the content in the finished product is < 10 ppm -> no risk for sensitive consumers -> no declaration required

 

Rgds

moskito

hopefully freezing also reduces sulfite levels. our main raw material is cooked then DCN shall be mixed then frozen. we would have to do sulfite testing of our finished product for validation.

 

thanks for the input!       

[moskito]

hopefully freezing also reduces sulfite levels. our main raw material is cooked then DCN shall be mixed then frozen. we would have to do sulfite testing of our finished product for validation.

 

thanks for the input!       

Heating (baking, cooking) will do the job to exhaust sulphite. I don't think freezing will have an effect.
In any case pH is important too.
Rgds
moskito