Adding Ingredients Not Written in the Packaging

Hi.

Just wondering if we have printed all of our packaging and suddenly we want to add an ingredient that is not written in the packaging into the product, are we allowed to do that according to FSANZ? In this case, the ingredient is invert syrup, quantity is 1.5%.

If yes, when will we have to change the packaging (e.g. 3 months after introducing the ingredient? 6 months? 1 year?).

Thanks.

Are you adding or replacing?  If you're replacing one type of sugar with the invert syrup and the overall amount of added sugar doesn't change you could probably use existing inventory, but do not order more

if you are adding, you need to replace your packaging as you are no longer making a true statement AND your NFT will also change

I've heard of invert sugar syrup being used as a processing aid to facilitate shelf life (the use case was cookie dough, where the fat and sugar interactions would turn white in frozen storage, in the absence of invert syrup). In the EU, there are labelling provisions that allow for food ingredients to be omitted from the ingredients list if they are used as processing aids, so it's possible that you would legitimately use your printed packaging - depending on whether the invert syrup is performing a technological function in your finished product.

EUR-Lex - 02011R1169-20180101 - EN - EUR-Lex (europa.eu)

I've heard of invert sugar syrup being used as a processing aid to facilitate shelf life (the use case was cookie dough, where the fat and sugar interactions would turn white in frozen storage, in the absence of invert syrup). In the EU, there are labelling provisions that allow for food ingredients to be omitted from the ingredients list if they are used as processing aids, so it's possible that you would legitimately use your printed packaging - depending on whether the invert syrup is performing a technological function in your finished product.

 

EUR-Lex - 02011R1169-20180101 - EN - EUR-Lex (europa.eu)

Note that the OP referred to FSANZ.

It depends on whether you are replacing it with existing ingredient of the same type or you are adding entirely new ingredient to the product. If it is replacing with existing ingredient of the same type at the same amount, you may not need to change the package for up to 3 months. But if it is entirely new ingredient, then you may have to change the food package as this may be treated as deceit. You will see more useful information here https://www.pwrpack.com/