5 replies to this topic

[JensV]

Hi all!

 

I have a question concerning "novel foods" and "vegetable fibers" (european legislation is applicable).

 

a) Are vegetable fibers novel foods? For example pea fiber, bamboo fiber?

 

b) If these are novel foods, what are the consequences? 

 

c) If these are not novel foods, can we use them freely as an ingredient? 

 

Thank you!

 

Kind regards,

Jens

 

 

[SarahIFS]

Hi all!

 

I have a question concerning "novel foods" and "vegetable fibers" (european legislation is applicable).

 

a) Are vegetable fibers novel foods? For example pea fiber, bamboo fiber?

 

b) If these are novel foods, what are the consequences? 

 

c) If these are not novel foods, can we use them freely as an ingredient? 

 

Thank you!

 

Kind regards,

Jens

Hi Jens,

 

I am not sure, but trying to help with what I know, so please anyone correct me if I am wrong.

 

a) I do not find these in REGULATION (EU) 2018/1023 for novel foods

 

b) - 

 

c) They need to comply to EU legislation for max limits contaminants in REGULATION (EC) No 1881/2006, when the product is not specified in the annex by name, I look for the one most applicable. Will they be labeled as food supplements?

[pHruit]

This isn't necessarily an easy question to answer, due to the complexity around determining what is / isn't novel.

There are some examples in Regulation 2018/1023 that might fall into the group you're thinking about - for example sugar cane fibre, or phosphated maize starch used for it's relatively high (>70%) fibre content.

 

The "novel" status may relate to the process to which the material has been subjected, rather than simply the source from which it is derived - obviously both sugar cane and maize have an extensive history of consumption, but processing them in ways that changes the nutrient balance and/or chemical composition potentially renders them novel.

 

There is a defined process to check whether something is or isn't novel, via your member states' competent authority. Although it sounds like you're looking at using ingredients in finished products, in which case it would be a question to put to your raw material suppliers.

There is also an online novel food catalogue operated by the Commission: https://webgate.ec.e...food_catalogue/

Understandably this isn't exhaustive, as it would be impossible to catalogue everything, so it's most useful probably as an initial quick reference point.

 

If the products are novel, they need to go through the formal assessment process defined in regulation - placing them on the market prior to this would not be legal. There is a bit of an overview of the processing on this EFSA page: https://www.efsa.eur...raditional-food

 

Assuming the products aren't novel, you can use them subject to meeting any other regulatory obligations that apply for the product. As mentioned in post #2 this would include contaminants limits, along with pesticide residue limits etc.
Additionally if the source of fibre is also considered to potentially be an additive then there may be maximum usage limits and/or category restrictions. The only potential fibre source I can think of that would fall into this category is polydextrose (E1200), which probably is outside the scope of the vegetable-based ones you're considering, and in any case IIRC it also has a quantum satis limit in most categories, so isn't really restricted in that sense anyway.

[Marloes]

Hi Jens,

 

Novel foods are any foods that do not have a history of ''significant'' consumption in the EU before 1997.
Bamboo fiber is most like not eaten significantly before 1997, pea fiber... idk? Pea's are eating a lot here, but perhaps not in their refined fiber form.

The suggestion of checking with your supplier is smart. If they already sell in the EU without issue, it also shouldn't be an issue for you.
If they are approved novel foods they might be limits on how (much) you can use, but that should be in their approval.

If it is not consumed yet in the EU and you do want to sell/use these plant fibers you would have to put in a request through your competent authority to submit for review. But these processes are long, tedious and expensive. 

[JensV]

Hi all,

 

Thank you for the input.

 

Tricky and complex it is indeed.

 

@pHruit @SarahIFS

 

 

 

There is also an online novel food catalogue operated by the Commission: https://webgate.ec.e...food_catalogue/

 

If I search for "Bambusa vulgaris", then it is stated that the leaf , shoot and stem of Bambusa Vulgaris (common bamboo) are not considered novel in food supplement.

 

So it isn't novel when used as a food supplement? In our case, we indeed use it as an ingredient in our end product, to increase the fibre content. However our end product isn't a food supplement. So what in our situation - can I motivate it this way it is ok for our end product?

 

--

 

@Marloes @pHruit

 

 

 

The suggestion of checking with your supplier is smart.

 

Yes, I checked this with the supplier. They claim it is no novel food for our application without really clear explanations. So I am looking for substantiation.

[pHruit]

It looks like you've found one of the limitations of the relatively small and sparse novel foods catalogue

Certainly I don't believe that whole bamboo shoots would be considered novel, due to the history of consumption prior to 1997. Even in England with our famously dull food back in the 1980s and early 1990s I recall eating these in Chinese restaurants.

The novel food catalogue has taken a slightly broader grouping though, including the stem and leaf. If you look at the other entry for the broader Bambusa sp. grouping you'll see that this includes specific reference to the leaf having no known history of consumption before the 1997 cutoff date, so in this case I suspect that the Bambusa vulgaris entry has been compromised by including several parts of the plant.

 

If you know what bits of the bamboo your ingredient is made from, then I'd give your local regulator a call/email. In the UK this would be trading standards, but I'm not sure who the equivalent would be for you in Belgium. As it's a relatively simple case, they should readily be able to advise whether they consider that part novel or not, without needing to instigate the full determination process defined in the regulation.

 

In some cases the database does do a good job of highlighting that the processing element can be an important part in determining novel status. For example if you look at the entry for Vaccinium myrtillus, you'll see that this doesn't have the nice green tick mark despite blueberries/bilberries have a long established history of safe consumption. However you'll also note that there is text indicating the entry refers specifically to certain extracts.

 

In terms of your position with your supplier, I think you would be on reasonably good footing to use the product if they can (a) confirm which bit(s) of the plant they're using, as you can cross-check this with your local regulator, and (b) if they can give you a formal declaration that it is not manufactured using processes that would render it novel in accordance with Article 3(2)(a) of Regulation (EU) 2015/2283.