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Adding Ingredients Not Written in the Packaging

ingredients packaging fsanz

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prwib

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Posted 13 October 2021 - 01:51 AM

Hi.

 

Just wondering if we have printed all of our packaging and suddenly we want to add an ingredient that is not written in the packaging into the product, are we allowed to do that according to FSANZ? In this case, the ingredient is invert syrup, quantity is 1.5%.

 

If yes, when will we have to change the packaging (e.g. 3 months after introducing the ingredient? 6 months? 1 year?).

 

Thanks.

 



Scampi

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Posted 13 October 2021 - 11:59 AM

Are you adding or replacing?  If you're replacing one type of sugar with the invert syrup and the overall amount of added sugar doesn't change you could probably use existing inventory, but do not order more

 

if you are adding, you need to replace your packaging as you are no longer making a true statement AND your NFT will also change


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Duncan

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Posted 14 October 2021 - 09:11 AM

I've heard of invert sugar syrup being used as a processing aid to facilitate shelf life (the use case was cookie dough, where the fat and sugar interactions would turn white in frozen storage, in the absence of invert syrup). In the EU, there are labelling provisions that allow for food ingredients to be omitted from the ingredients list if they are used as processing aids, so it's possible that you would legitimately use your printed packaging - depending on whether the invert syrup is performing a technological function in your finished product.

 

EUR-Lex - 02011R1169-20180101 - EN - EUR-Lex (europa.eu)


FOOD PORTAL - The web portal dedicated to the food industry - Home (food-portal.co.uk)

 

Food Portal provides a range of systems and tools for food manufacturers.


Charles.C

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Posted 14 October 2021 - 03:35 PM

I've heard of invert sugar syrup being used as a processing aid to facilitate shelf life (the use case was cookie dough, where the fat and sugar interactions would turn white in frozen storage, in the absence of invert syrup). In the EU, there are labelling provisions that allow for food ingredients to be omitted from the ingredients list if they are used as processing aids, so it's possible that you would legitimately use your printed packaging - depending on whether the invert syrup is performing a technological function in your finished product.

 

EUR-Lex - 02011R1169-20180101 - EN - EUR-Lex (europa.eu)

Note that the OP referred to FSANZ.


Kind Regards,

 

Charles.C


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