7 replies to this topic

[arlenegormley]

Hi there-

I am hoping to get some help- I have developed a product named “The Iron Egg’ and I need some advice on categorisation and regulation requirements.

Using cast iron cookware has been proven to release iron into food / liquids during cooking- link to study

A factory in China that manufactures cast iron cookware, produced a cast iron piece in the shape of an egg, that is placed in food / liquids to release iron.

Testing was conducted at the University of Ulster that showed the egg was effective in releasing 6.23mg of iron following the instructions for use. The report from University of Ulster is attached.

I had originally listed the product as 46150 - Agents involved in the sale of furniture, household goods, hardware and ironmongery (link to Companies House listing) as I thought the product would be listed in the “kitchen utensils” category.

I reached out to Intertek for a consultation about additional testing I may need to conduct before taking the product to market. They were unsure if the egg was a ‘food contact material’, a supplement or, an ingredient. They suggested that I reach out to the Northern Ireland Food Standards Agency for advice on this. I have did this an I am awaiting their response for a introductory call. Does anyone have any advice or insight into this? 

Under the EU food contact materials framework, the product must not alter the food/liquid (which the Egg does, by design!) But I am wondering if there are any ways round this as a similar product is available in Japan (link to Japanese Iron Egg).

Please help!

 

Attached Files

•  Primary Clinical Research.pdf   840.8KB   2 downloads

[pHruit]

Article 2 of Regulation (EC) 178/2002:
 

Definition of 'food'

For the purposes of this Regulation, 'food; (or 'foodstuff') means any substance or product, whether processed, partially processed or unprocessed, intended to be, or reasonably expected to be ingested by humans.

'Food' includes drink, chewing gum and any substance, including water, intentionally incorporated into the food during its manufacture, preparation or treatment. It includes water after the point of compliance as defined in Article 6 of Directive 98/83/EC and without prejudice to the requirements of Directives 80/778/EEC and 98/83/EC.

 

Since it is your specific intent that the egg is "consumed" (albeit at a rather slow rate), I'd infer that it is effectively a food within the meaning of current EU and UK regulations, and should therefore be regulated as a food. Obviously this is somewhat speculative, and if you're able to update once you have a verdict from NI FSA then I'd be fascinated to know what their view is.

 

If this assumption is correct, then the purpose of the device is effectively to act as a fortifier, so you potentially want to have a look at Regulation (EC) 1925/2006 and subsequent amendments, available as a single consolidated document here: https://eur-lex.euro...6R1925-20221221

 

N.B. Some of the amendments included in this are after the Brexit transition, so this linked version applies in NI but not in England/Scotland/Wales. If you're planning to market across the whole of the UK then you might need to dig back through the individual post-Brexit amendments (linked at the side of the page I linked above) to see if any of them have any specific implications for your product.

[SHQuality]

I'm assuming you're using the egg with the purpose of adding iron to your food as a nutritional mineral.

That would be an ingredient unless it is added in a form that is recognized as an additive by your local legislation.

[kfromNE]

There are similar items like this but added to a pot - the ones I've seen are in the shape of a fish. Maybe see what they do for regulatory.

[G M]

There are similar items like this but added to a pot - the ones I've seen are in the shape of a fish. Maybe see what they do for regulatory.

 

I think that's why they're here asking.

[arlenegormley]

Hi all- thank you so much for taking the time to respond- especially pHruit- that was super helpful.

 

So yes about the Lucky Iron Fish (https://luckyironfish.com) When they started out, the fish was made from cast iron, same material as cast-iron cookware. But recently, and I'm not sure when the change happened, but they now cite on the website that the material is-

"Food-grade electrolytic iron powder that is FDA certified and approved for food fortification worldwide."

The material of my egg is cast-iron (the factory that produced them in China manufacture cast-iron cookware for the global market. However, getting information about the exact composition of the material used is proving very tricky and I think part of it is due to my 'ask' being lost in translation. 

 

It makes sense to me about the egg being a food - but I am getting so many conflicting opinions (fascinating has been used to describe my quandary more than once!)

 

So, the egg that was made in Japan and is listed as a kitchen utensil, I see that it can actually be bought in the UK. How are they getting around this I wonder? Apologies for raising more questions here! The minimum order of the eggs from the factory in China was 1000, so I have literally boxes of these taking over my mum's house and we are all beginning to lose faith a little.

 

Does anyone know of an organisation/ company/ person who could get to the bottom of this for me?

Thanks again for all your help

Arlene

[pHruit]

Being on sale in the UK isn't necessarily equivalent to being legally on sale in the UK

There are plenty of products, including foods, that can be purchased in the UK that do not comply with one or more regulations - it's simply a case of there being so many products and sales routes that the tiny resource we have left for regulatory enforcement is absolutely swamped.

 

Big names for regulatory/food science consultancy in the UK are people like Campden BRI, Leatherhead, RSSL. It won't be cheap, and their opinions necessarily err on the conservative side, but it is an option.

As a cheaper route some Trading Standards services offer what is known as "assured advice", where you effectively pay them a consultancy fee (far less expensive than the likes of the above) to give you their formal opinion, and this has the added benefit of carrying a lot of weight if you get any challenges/queries from Trading Standards in other regions. I don't know if this is offered in NI, but if they're already looking at your query then it might be worth asking about it.

If they can't do this then you might well be able to get it via a different local authority's Trading Standards service, by signing up with them for what is known as Primary Authority status. More info here: https://www.gov.uk/g...imary-authority

 

[arlenegormley]

Hi PHruit,

Thank you so much for your input- it has proved more valuable that you know! I am still going round in circles 'from pillar to post' but I will keep you posted. 

 

Thanks again,

Arlene