Do you also want a clean label? Here's what you need to know

Article updated May 2023

Manufacturers are increasingly replacing E numbers with ingredients without E numbers, so-called clean label ingredients. The NVWA intervenes because this circumvents the additives legislation. This article tells you everything you need to know about this clean label trend.

There is no established definition for the term "clean label. In general, a clean label contains few additives or artificial ingredients. Additives are added to foods because of their technological function, for example as preservatives or antioxidants. Annex II of Regulation (EC) No 1333/2008 contains the list of approved additives. Clean label ingredients are ingredients with the same technological function as additives. However, these ingredients are not on the list of approved additives. The NVWA therefore views the use of these ingredients as unapproved additive use. Their use is also misleading to consumers because the technological function of these ingredients is often not mentioned either.

What is clean label?

The term "clean label" came about in response to the needs of discerning consumers. An important goal of using a clean label is therefore to portray the food as a healthy and natural product. However, there is no established definition for the term "clean label. Each producer and consumer can therefore provide their own interpretation.
Some examples of a clean label are:

No E numbers
Only natural ingredients
Simple and brief ingredient declaration
Transparent composition
No GMO
No hydrogenated fats
Processed as little as possible
Use of claims such as 'natural' or 'free of'

Clean label ingredients

Clean label ingredients are often natural ingredients. Plant extracts have certain properties to function as preservatives, antioxidants or dyes. Bamboo fiber can bind water well and is therefore suitable as a thickening agent. In certain cases, the unpurified version of an additive is used instead of the approved additive. You can think of citrus extract instead of citric acid (E330) and buffered vinegar instead of acetic acid (E260). An approved additive with an E number must meet certain purity requirements. Thus, it is not allowed to use the unpurified variety. Another specific example is when a celery or beet extract with a high nitrate content is added to certain products, especially meat preparations. The nitrate is converted into nitrite in these products, which is the same substance as the additive nitrite (E249 or E250), but in an unpurified form. However, the addition of nitrite is not permitted in these products.

Enforcement NVWA

The use of clean label ingredients is thus seen as unauthorized additive use. The Ministry of Health, Welfare and Sport does welcome innovation, provided the legislation is observed. The ministry therefore announced on June 16, 2021, that the NVWA will take enforcement action. Clean label ingredients for which a file is already pending with the European Commission for approval as an additive are the exception. The NVWA will not take enforcement action in these cases, provided 4 conditions are met:

This temporary exception applies only to clean label ingredients on the Dutch market. The ingredients must be placed on the market before June 16, 2021.

Current applications

Currently, dossiers have been initiated for approval as additives for some ingredients, including buffered vinegar and fruit and herb extract. Once a dossier is approved, an E-number and function will be assigned to the ingredient. Until then, according to the terms of the NVWA, the technological function of these ingredients must be declared.

Buffered vinegar is used for preservation of meat or fish, for example. The ingredient is often declared as flavoring or buffered vinegar (powder). From now on, the preservative function will have to be stated, for example: buffered vinegar (preservative ingredient). Fruit and herbal extract has antioxidant properties. For now, this ingredient will have to be labeled as fruit and herbal extract (antioxidant).

Buffered vinegar

The EU Commission Working Group on Additives provided an update on pending applications for buffered vinegar in December 2022. Three different applications had been submitted for buffered vinegar. The European Food Safety Authority (EFSA) has now evaluated one of these applications and found it to be safe. More information is still needed for the other two applications.

However, there are still questions about the technological need for some of the intended applications. Also still under discussion are the heavy metal limits and authorization as a Group I additive. The Commission, in consultation with the applicant and member states, will finalize the last questions and incorporate the proposed changes into the specifications. Buffered vinegar will be given the E number E267.

For now, we are waiting for the publication of the approved application and the inclusion of buffered vinegar as E267 in Annex II of Regulation 1333/2008. We will keep you informed