rning additive usage and the laws governing food labelling. Overall, your label must not mislead the consumer to the extent that they buy your product in preference to similar products. Finally you must be able to provide all necessary evidence demanded by the competent authorities who are charged with ensuring compliance with the food law.
Can I use ingredients that are also sources of nitrite/nitrate to replace sodium or potassium nitrite/nitrate?
You cannot use ingredients that are also a source of nitrite/nitrate if used for the intended technological purpose of preservation or colouring in the final food. Such use would be considered a deliberate use of a food additive.
The use of nitrates and nitrites must comply with the food additives legislation, including the conditions of use laid down in Annex III part C to Directive 95/2/EC as amended as well as the purity criteria in Annex I to Commission Directive 2008/84/EC. The use of ingredients that are also sources of nitrite/nitrate, such as vegetable extracts or fermented vegetable broths, has been discussed on a number of occasions at the Commission working party on food additives and also at the EU Standing Committee on the Food Chain and Animal Health. On these occasions it was agreed by the Commission and all Member States, that such a practice would be a deliberate use of a food additive if used for the intended technological purpose of preservation or colouring in the final food.
Nitrites added to food for preservation or colouring purposes, via other ingredients like vegetable extracts/fermented broths would not currently be permitted by Directive 95/2/EC as these extracts have not been approved as preservatives and their use would also not comply with the current purity criteria laid down in Directive 2008/84/EC.
Further information on these two standing committee decisions can be found at the following links:
http://ec.europa.eu/food/committees/regulatory/scfcah/toxic/summary23_en.pdf agenda item 4
http://ec.europa.eu/food/committees/regulatory/scfcah/toxic/summary19052010_en.pdf agenda item 5
What are the restrictions on the use of the word ‘natural’ on the food label of a meat product where nitrite has been removed?
The word “natural” is often used as a marketing term by food businesses and is currently not defined in legislation governing foodstuffs. However, general food legislation places on obligation on food businesses to ensure that the labelling, advertising and presentation of food, and the information made available about it through whatever medium, should not mislead consumers.
More specifically, the legislation requires that the labelling and methods used must not be such as could mislead the consumer to a material degree by suggesting that the foodstuff possesses special characteristics when in fact all similar foodstuffs possess such characteristics. A food business operator must be able to substantiate any claim made by them in relation to their product.
Therefore, in order not to mislead the consumer and thereby breach the labelling legislation the use of the word ‘natural’ would have to be in keeping with a general understanding of the meaning of that word in the context of food by the majority of consumers and cannot be used to imply that the food is different if all similar foods possess the same characteristics.
Can I use the word ‘natural’ in my ingredients declaration?
Legislation on flavourings sets out the requirements for use of the word ‘natural’ in relation to flavourings used in foodstuffs. For general ingredients, there is no definition of the word natural as discussed above. However, the general rules regarding the labelling, presentation and advertising of foods requires that the labelling and methods used must not be such as could mislead the consumer to a material degree by suggesting that the foodstuff possesses special characteristics when in fact all similar foodstuffs possess such characteristics. Where ingredients do not possess special characteristics when compared with similar ingredients in other foodstuffs, then th