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Dough Conditioners - Labeling and Substitutions

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svmwing

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Posted 07 October 2022 - 04:32 PM

Hi everyone, looking for some insight and thoughts on this scenario. I'm looking at potentially harmonizing 2 dough formulas within the company's 2 facilities so we can dual source the same product. Each facility uses different types of dough conditioners with differing ingredients as their subcomponents. 

 

I came across this in the FDA's CFR Section 101.4 (b) (18) Dough conditioners not present in the product may be listed if they are sometimes used in the product. Such ingredients shall be identified by words indicating that they may not be present, such as ‘‘or’’, ‘‘and/or’’, or ‘‘contains one or more of the following:’’

 

I'm trying to understand how that might look on an ingredient statement if we tried to harmonize the 2 formulas given the only differences are the dough conditioners (bolded ingredients). 

 

For example: 

Formula A is Bread: Enriched wheat flour (flour, ascorbic acid added as a dough conditioner, niacin, reduced iron, thiamine mononitrate, riboflavin, folic acid), water, soybean oil, yeast, sugar, salt, microbial enzymes.

 

Formula B is Bread: Enriched wheat flour(wheat flour, niacin, reduced iron, thiamin mononitrate, riboflavin, folic acid), water, contains 2% or less of: soybean oil, yeast, salt, sugar, malted barley flour, wheat gluten, dextrose, ascorbic acid added as a dough conditioner, microbial enzymes, vegetable protein, cornmeal.

 

Would the combined ingredient statement below make sense then? 

Bread: Enriched wheat flour (flour, ascorbic acid added as a dough conditioner, niacin, reduced iron, thiamine mononitrate, riboflavin, folic acid), water, contains 2% or less of: soybean oil, yeast, sugar, salt, malted barley flour, wheat gluten, dextrose, ascorbic acid added as a dough conditioner, microbial enzymes, vegetable protein, cornmeal. 

 

I feel like the contains 2% or less of: could cover the dough conditioners bolded but not sure about the ascorbic acid found within the enriched wheat flour? Any thoughts/advice? Or is "contains 2% or less" perceived differently from "contains one or more of"?

 

Also would the cornmeal be technically over declaring and therefore 'misleading' even though it's 2% or less?

 

 

Thanks! 

 





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