ah/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 the word “natural” should not be used except where it is specifically permitted by legislation e.g. ‘natural flavouring’.
Will my product be safe if I take out the nitrite?
Safety cannot be taken for granted unless a full validation of the new preservation system in the food is carried out. Nitrate has been traditionally used to prevent meat products from causing botulism caused by the harmful bacterium, Cl. botulinum. The removal of nitrite can be likened to the removal of a hurdle to the growth of Cl. botulinum. To maintain the safety of the food, another similar hurdle must be used to replace nitrite or otherwise the ‘height’ of the remaining hurdles has to be increased to prevent Cl. botulinum from growing. For example, to reinstate the safety of the food you may have to reduce the shelf life and/or increase the salt level (and therefore increase the water activity: Aw) and/or decrease the pH and/or add a different preservative. In effect you will have to reformulate the product, validate the shelf life and readjust the HACCP system to ensure the food can be manufactured safely on a consistent basis.
A useful document was produced by CCFRA in 2009 called “The manufacture of vacuum and modified atmosphere packaged chilled foods: a code of practice. 2nd edition”, which provides good guidance to manufacturers.
What is botulism?
Clostridium botulinum is a bacterium that exists in soils and is found throughout the environment. It produces spores which have great resistance to heat and chemical disinfectants. Cl. botulinum can be found in many raw foods including meat and is capable of producing a potent neurotoxin (poison that affects the functioning of brain and nerves) as it grows. The neurotoxin can kill at very low levels if victims are unable to seek immediate treatment. This condition is known as botulism.
For the purposes of this FAQ there are two main forms of Cl. botulinum called Type I and Type II. Type I Cl. botulinum spores are the most heat resistant but cannot grow below 10ºC. Type II Cl. botulinum spo