3 replies to this topic

[Sushan_G]

Hi everyone!

 

Currently our company is currently actively communicating with a Chinese supplier to purchase a premix flour-intended for making Bapao. This premix flour is primarily based on wheat flour but also contains sugar, baking powder (E170, E450(i), E500(ii), and E341(i)), and some fats. I consider it to fall under Food Category 6.2 – Flours and starches. However, if I understand correctly, E170 and E500(ii) would not be permitted in this category. At the same time, I know that E170 and E500(ii) are very common additives, so I am wondering if my categorization of this product is incorrect and perhaps it should belong to a different food category. I am quite confused and am seeking your guidance.

[SHQuality]

I came to the exact same conclusion as you did.

The problem here is that the supplier is from China and not necessarily aware of the restrictions imposed by EU legislation.

 

If I had to categorize this product, I would go with 06.2.1 Flours (under category 06.2: Flours and other milled products and starches) as well.

 

This supplier is not in line with EU legislation as "Flour and other milled products and starches" is one of the categories in which presence of a food colour may not be permitted by virtue of the carry-over principle. In other words, the E170 which appears to be present in the baking powder is not allowed to be present in the flour.

 

Source (latest consolidated version): https://eur-lex.euro...d=1767563427098

 

According to the guidance document, your final product (bapao) falls under category 7.1 Breads and rolls. Steamed breads are specifically mentioned in the guidance document (https://food.ec.euro...008_annex-2.pdf)

 

E170 and E500(ii) are also not allowed in your final product, so this particular premix is simply not suitable for your use regardless of how it would be classified on its own. I suggest you make sure Procurement is aware of this issue before they buy a tonne of material you can't legally use.

Edited by SHQuality, 04 January 2026 - 10:10 PM.

[Sushan_G]

I came to the exact same conclusion as you did.

The problem here is that the supplier is from China and not necessarily aware of the restrictions imposed by EU legislation.

 

If I had to categorize this product, I would go with 06.2.1 Flours (under category 06.2: Flours and other milled products and starches) as well.

 

This supplier is not in line with EU legislation as "Flour and other milled products and starches" is one of the categories in which presence of a food colour may not be permitted by virtue of the carry-over principle. In other words, the E170 which appears to be present in the baking powder is not allowed to be present in the flour.

 

Source (latest consolidated version): https://eur-lex.euro...d=1767563427098

 

According to the guidance document, your final product (bapao) falls under category 7.1 Breads and rolls. Steamed breads are specifically mentioned in the guidance document (https://food.ec.euro...008_annex-2.pdf)

 

E170 and E500(ii) are also not allowed in your final product, so this particular premix is simply not suitable for your use regardless of how it would be classified on its own. I suggest you make sure Procurement is aware of this issue before they buy a tonne of material you can't legally use.

Thank you!! Fortunately, this product is still in the discussion stage, and I reported that this pre mix flour cannot be imported. And I must thank you because we seem to be using E500(ii) now...

[SHQuality]

Is that E500(ii) used directly as an additive in your recipe or is it carry-over from some other ingredient that is ending up in your product?