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Updated by SFA Regulation 15(3) of the Food Regulations provides for "carryover" of food additives into the final food product.
To paraphrase the regulation, a food product may contain added ingredients which may, in turn, contain permitted food additives. The quantities of the food additives present in the added ingredients must be within the levels specified under the Food Regulations. Under such circumstances, the food additives are deemed to be carried over into the food product.
Regulation 15(3):
Notwithstanding paragraph (1), any food containing as an added ingredient any specified food may contain any such permitted food additive of the description for and of an amount appropriate to the quantity of such specified food in accordance with these Regulations.
In terms of labelling, Regulation 5(4)(b) of the Food Regulations requires that all ingredients (including additives) used in prepacked food must be declared in descending order of the proportion by weight in which they are present. Where the food contains ingredients that are made of two or more constituents (i.e. compound ingredients), the constituents, including carried over food additives, of the compound ingredient must be declared accordingly under the statement of ingredients. For processing aids, SFA is agreeable with the recommendations of Codex on the declaration of processing aids in the statement of ingredients, as laid out in the following standards.
Codex General Standard for Labelling of Food Additives When Sold as Such (CODEX STAN 107-1981) and
Codex General Standard for the Labelling of Prepackaged Food (CODEX STAN 1-1985)
In the absence of a definition for "processing aids" under the Food Regulations, the current definition for "processing aids" as stipulated in the Codex Procedural Manual may be taken as a reference –
"Processing aid means any substance or material, not including apparatus or utensils, and not consumed as a food ingredient by itself, intentionally used in the processing of raw materials, foods or its ingredients to fulfil a certain technological purpose during treatment or processing and which may result in the non-intentional but unavoidable presence of residues or derivatives in the final product."
Your company must be able to justify for the presence of undeclared processing aids in the final food product, as and when necessary. Please see Labelling Requirements for Foodfor more information on labelling requirements for prepacked food.
Can food additives be carried over to the final food product?
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