Do we need to declare Processing Aid (citric acid) in our ingredient statement?

We will be using a minute amount of citric acid as processing aid in our production, do we need to declare it in the ingredient statement if it is less than 2% but has functional effect in food?

(ii) Processing aids, which are as follows:

(a) Substances that are added to a food during the processing of such food but are removed in some manner from the food before it is packaged in its finished form.

(b) Substances that are added to a food during processing, are converted into constituents normally present in the food, and do not significantly increase the amount of the constituents naturally found in the food.

© Substances that are added to a food for their technical or functional effect in the processing but are present in the finished food at insignificant levels and do not have any technical or functional effect in that food.

Thank you.

Considering that sourcing (what it actually is made from) of Citric Acid can be very interesting to say the least and the potential for people being sensitive to it, it needs to go on the label.

In Canada the regulation state processing aids must be declared- CFIA regulates the amounts of ingredients that are additives, preservatives and processing aids and your program needs to indicate if you are within compliance for the amounts - this includes synthetic colors as well... see link

https://www.canada.c...-aids-2008.html

In Canada the regulation state processing aids must be declared- CFIA regulates the amounts of ingredients that are additives, preservatives and processing aids and your program needs to indicate if you are within compliance for the amounts - this includes synthetic colors as well... see link

https://www.canada.c...-aids-2008.html

Hi El Molino,

Are US Labelling Regulations identical to Canada ? Just curious.

We will be using a minute amount of citric acid as processing aid in our production, do we need to declare it in the ingredient statement if it is less than 2% but has functional effect in food?

 

(ii) Processing aids, which are as follows:

(a) Substances that are added to a food during the processing of such food but are removed in some manner from the food before it is packaged in its finished form.

(b) Substances that are added to a food during processing, are converted into constituents normally present in the food, and do not significantly increase the amount of the constituents naturally found in the food.

© Substances that are added to a food for their technical or functional effect in the processing but are present in the finished food at insignificant levels and do not have any technical or functional effect in that food.

 

Thank you.

US regs aren't particularly my area of expertise, but my reading of 21CFR101.100 is that you would need to label it - highlighted parts in the quote of primary relevance here.

Exemption (a) doesn't apply as the citric acid isn't removed, exemption (b) presumably doesn't apply as you haven't mentioned it as being a salient point, and exemption © seems to be ruled out on the basis that you're saying the citric acid does have a functional effect in the final product.

Nonetheless it's potentially still worth considering both points (b) and © in more detail if you feel there is a specific need to try to omit the citric acid from the label, but to provide any input on this we'd need to know significantly more about the composition of the product and potentially the processing, the packaging format etc., so appreciate that is a level of detail you may not wish to share here!

as long as they have functional effect on the food  , they need to be labelled.

If their functionality ends at processing  then its up to you to  determine how much may be in the product and decide

In Canada the regulation state processing aids must be declared- CFIA regulates the amounts of ingredients that are additives, preservatives and processing aids and your program needs to indicate if you are within compliance for the amounts - this includes synthetic colors as well... see link

https://www.canada.c...-aids-2008.html

Wrong, processing aids are not required to be declared on the label of prepackage foods in Canada - Processing aids differ from food additives and food ingredients in that they are not present in the finished food, or are present in a negligible amount.

read from your link.

Very similar guidelines with US:

PART 101 -- FOOD LABELING
Subpart G--Exemptions From Food Labeling Requirements
Sec. 101.100 Food; exemptions from labeling.

(3) Incidental additives that are present in a food at insignificant levels and do not have any technical or functional effect in that food. For the purposes of this paragraph (a)(3), incidental additives are:

(i) Substances that have no technical or functional effect but are present in a food by reason of having been incorporated into the food as an ingredient of another food, in which the substance did have a functional or technical effect.

(ii) Processing aids, which are as follows:

(a ) Substances that are added to a food during the processing of such food but are removed in some manner from the food before it is packaged in its finished form.

(b ) Substances that are added to a food during processing, are converted into constituents normally present in the food, and do not significantly increase the amount of the constitutents naturally found in the food.

(c ) Substances that are added to a food for their technical or functional effect in the processing but are present in the finished food at insignificant levels and do not have any technical or functional effect in that food.

(iii) Substances migrating to food from equipment or packaging or otherwise affecting food that are not food additives as defined in section 201(s) of the act; or if they are food additives as so defined, they are used in conformity with regulations established pursuant to section 409 of the act.

https://www.accessda....cfm?fr=101.100

I am not an expert on labeling but I would say yes.  It sounds like you are adding it into the product itself and you are doing so for a reason so that means it has a function and therefore should be declared.  It might depend on what product you make and which regulatory agency you fall under.  As we do not know what product you are making or why you are adding it is hard to really say.  You might contact one of the universities in your state that have a school for meat science or manufacturing of foods.  They usually have someone that can help with questions such as this, especially if you are a small company.

Well, if you don't remove it of the product and it has a functional effect in food, it seems to me that you have to declare.

Unless it's case b, where citric acid is part of natural component of the product

Since it's not a particularly "contentious" ingredient in the eyes of the public, I wouldn't worry too much if it really is minute.

2% by weight isn't a magic number, if you give me a glass of water that is 2% by weight in salt I'm going to take issue with you not declaring it. :)

That said, if it is an FDA regulated product...at the end of the day there's almost no enforcement on this. So make the a decision based on your best judgement and ethics, but don't lose sleep over it, you are likely the only one who will ever care. It's not a common sensitivity so you are unlikely to harm anyone by not including it on the statement, and you are unlikely to incur customer ire because it's not a hated ingredient.