5 replies to this topic

[AmberB]

Our company is in the process of updating all our retail packaging as we have gone milk free.

 

My question is.. We don’t have any intentionally added sulphites. All our approved supplier documents state less than 10ppm for sulphites, would we still have to declare sulphites in the allergy contains statement?

[Scampi]

The short answer is yes

There are details at this link on your query

https://inspection.c...-allergens#s8c2

 

Order of added sulphites declaration

Sulphites, like any other food additive, are required to be declared in the list of ingredients of food labels when they are added directly to a prepackaged product as an ingredient or a component of an ingredient that is not exempt from component declaration. If added sulphites are present in a prepackaged product in the first generation (that is to say, an ingredient) or second generation (a component), and are not exempt from declaration, they must be declared in the list of ingredients regardless of their quantity. Refer to Generations for more information on the generations of ingredients.

In the following examples, sulphites are a component of the dried apricots. Dried apricots are not exempt from component declaration, therefore sulphites must be declared along with all the other components of the dried apricots, regardless of their quantities.

[GMO]

Our company is in the process of updating all our retail packaging as we have gone milk free.

 

My question is.. We don’t have any intentionally added sulphites. All our approved supplier documents state less than 10ppm for sulphites, would we still have to declare sulphites in the allergy contains statement?

 

Not in the US so apologies if this is the wrong question to ask but you can get naturally occurring sulphites.  So your suppliers may be reluctant to say that an ingredient is sulphite free, but there may be no added sulphites.

 

I'd ask them if they add sulphites, if not then I would have thought that labelling is not required in that situation.  Just as you wouldn't have an apple labelled as "contains sulphites" but it probably will.  But if they're adding them and it's below 10ppm then that's different to my mind.

[nwilson]

Have you tested your product to make sure you are below the 10ppm requirement?  I would start there and if determined to be over 10ppm via product testing then sulfites should be listed in the ingredient statement.  Sulfites are not considered an allergen in the US only a sensitizing agent due to intolerance, and do not need to be listed in an allergen contains statement, unless you are shipping internationally which you should be referencing country of origin.  If sulfites are not intentionally added then there is an exemption from labeling due to being deemed naturally occurring.  

[AmberB]

My apologies, yes we are shipping our product to Canada so we need to also follow those labeling guidelines. 

[nwilson]

My apologies, yes we are shipping our product to Canada so we need to also follow those labeling guidelines. 

Should have been able to pull that one together given the tag (guess I need more coffee).  @scampi provided the Canada regs, the sulfites are not intentionally added so you should be in the clear, I am still a proponent of having test records to prove out the levels are below 10ppm.