Allergen labelling
Hi Everyone,
Strictly speaking, this is not a declarable allergen under regulation (EU) 1169/2011 - see appendix II:
Sulphur dioxide and sulphites at concentrations of more than 10 mg/kg or 10 mg/litre in terms of the total SO2 which are to be calculated for products as proposed ready for consumption or as reconstituted according to the instructions of the manufacturers
Since your instructions for the product "as proposed ready for consumption or as reconstituted according to the instructions of the manufacturers" does not contain SO2 above the 10mg threshold, this wouldn't be considered an allergen.
Nonetheless you might want to check local regulations/interpretation/preferences around any additional warning statements.
I can't imagine anyone eating powdered pudding mix without reconstituting it, so the chance of actually consuming sulphites at a level >10mg/kg would seem to be low, and indeed it's not a "true" allergen in the same sense as those for which very small traces of proteins could trigger a reaction.
You mention CO2 and SO2 in this question. For arguments' sake I am going to assume you are talking about SO2 since it is the allergen.
That depends on if the product can be considered ready-to-eat, as is. If it is then yes it needs to be labeled. If no, and the product needs to be reconstituted, then you would be looking at the final form of the product and you would not need to label it. Here is the EU guidance:
Sulphur dioxide and/ or sulphites at concentrations of more than 10 mg/kg or 10 mg/ (litre) in terms of the total SO2 which are to be calculated for products as proposed ready for consumption or as reconstituted according to the instructions of the manufacturers.
Full guidance is here:
Guidance template (food.gov.uk)
Bullet 51.
51. References to sulphur dioxide and/ or sulphites, which are used and found present in the finished product (ready for consumption or reconstituted according to manufacturers’ instructions) at less than 10 mg/Kg or 10 mg/litre is not required.
Hope this helps.
Cheers!
Strictly speaking, this is not a declarable allergen under regulation (EU) 1169/2011 - see appendix II:
Sulphur dioxide and sulphites at concentrations of more than 10 mg/kg or 10 mg/litre in terms of the total SO2 which are to be calculated for products as proposed ready for consumption or as reconstituted according to the instructions of the manufacturers
Since your instructions for the product "as proposed ready for consumption or as reconstituted according to the instructions of the manufacturers" does not contain SO2 above the 10mg threshold, this wouldn't be considered an allergen.
Nonetheless you might want to check local regulations/interpretation/preferences around any additional warning statements.
I can't imagine anyone eating powdered pudding mix without reconstituting it, so the chance of actually consuming sulphites at a level >10mg/kg would seem to be low, and indeed it's not a "true" allergen in the same sense as those for which very small traces of proteins could trigger a reaction.
Beat me out on the response while I was typing lol