Prepacked Product labelling - additives vs additives for nutritional purposes
Our latest HSE audit highlighted an error on back of pack whereby the guar gum, contained in coconut milk, was not listed as an additive on back of pack - which I understand.
However, the auditor also highlighted the calcium carbonate which is an additive in the fortified wheat flour. According to EC 1333/2008 (Article 2, Scope) , if a substance is added to foods as a nutrient, it is not considered an additive. Can anyone please clarify whether the added vitamins / minerals in fortified wheat flour need to have the word 'additive' or anything else in front of the names of the substances? I've never seen any back of pack listing to this effect - unless everyone just copies everyone else's back of packaging....
- A nutrient is not necessarily a fortifier of an ingredient.
- E170 is the calcium carbonate which is an additive according to EU and it is used as a fortifier of wheat-flour .
- It does not need to be there and it does not need to have 'additive' or fortifier or nutrient before its name.
- If the inspection authorities insist, then add one of the functions (See below) before its name for avoiding hassle.
- Various functions incl. acid regulator, raising agent, and nutrient - Added to white flour as a calcium supplement to replace the loss due to refining process- Frequently an ingredient in bread and baked products.
- UK retailers used the words Wheat Flour (with added Calcium, Iron, Niacin (B3), Thiamine (B1)).
Thanks for your input, much appreciated. I don't doubt your feedback, but do you have any document reference that I could use to substantiate your point " It does not need to be there and it does not need to have 'additive' or fortifier or nutrient before its name." I would like to be able to revert to the auditor with "proof".
My labelling training is a bit out of date but I do recall a few years ago that the law changed to start to include flour fortification under EU law which is still adopted in the UK. To my understanding you don't need to list "additive" but you do need to list what the additives are.
So for example, as online data should match pack, this is from a UK retailer website and it's just for white bread flour:
INGREDIENTS: Wheat Flour [Wheat Flour, Calcium Carbonate, Iron, Niacin, Thiamin].
Tesco Strong White Flour 1.5Kg - Tesco Groceries
I remember it coming up in conversation when the law changed because we used to just have to have "wheat flour" that consumers may suddenly think something has changed. But of course nobody batted an eyelid because it's only nerds like us and allergenic consumers who read BoP.