What do you need to know about additives?

The use of additives in foods has become almost indispensable. However, the labeling of additives can raise many questions. What additives may I use in my product? And how do I list them on the label? This article clearly lists everything you want to know about additives.

So what is an additive? The definition of an additive is as follows:

'Any substance, with or without nutritional value, not ordinarily consumed as a food by itself and not ordinarily used as a characteristic food ingredient, which for technological purposes in the manufacture, processing, preparation, handling, packaging, transportation or storage of food is intentionally added to such food, with the effect or reasonably foreseeable effect that the substance itself or its by-products become, directly or indirectly, a component of such food.'

This definition, together with the conditions of use and EU lists of approved food additives, is contained in Regulation (EU) No. 1333/2008 (hereinafter, the Additives Regulation).

EU list of approved additives

How do you know if an additive is allowed or not? A substance that meets the definition of additive may only be used if it has gone through an approval procedure and is included in the EU list. This procedure is established in Regulation (EU) No. 1331/2008. When an additive has gone through this procedure and is deemed safe for use in food, it is included in the EU list with an associated E number.

The EU list of approved additives for use in food can be found in Annex II of the Additives Regulation. The EU list lists for each food category which E numbers are allowed and whether maximum concentrations apply.

The EU Annex II list can also be accessed via a digital database. Using this database, you can conveniently search by E number or food category.

Specifications of additives

Once an additive is approved, the specifications of the additive are laid down in the annex of Regulation (EU) 231/2012. The specifications include requirements regarding chemical composition and purity, among other things. If an ingredient does not meet these specifications, it may not be used. It is also not allowed to use the name of an additive for another ingredient that does not meet the specifications of the additive in question. An example: The ingredient "extract of paprika" may not be declared as "paprika extract" if this ingredient does not meet the specifications of E160c/paprika extract.

Labeling of additives

Suppose you have determined that an additive may be used in your product. Now you need to declare it correctly on your label. But how? Additives must always be indicated on the label by the category (function of the additive) and the E-number or the specific designation.

Here the E-number or the specific name as listed in the EU list is always used. To indicate the function, one of the legally defined categories must be used. These categories are listed in Annex VII, Part C of Regulation (EU) No. 1169/2011:

Some comments are made on this listing of categories. First, when an additive belongs to more than one category, only the category appropriate to its main function in the food is listed. In addition, the category melting salt may only be used for processed cheese and processed cheese-based products. Furthermore, in the case of modified starch, the specific name or E number need not be given.

Additions to E numbers

Some E numbers are supplemented in the specifications in Regulation (EU) No. 231/2012 by an additive, for example E101(i) or E150a. The additions a, b, c, etc. always involve different additives. Therefore, this addition must always be declared.

In the case of the entry (i), (ii), (iii), etc., in most cases it is the same additive. Since these entries are also not included in the EU list, they may not be used on the label. So instead of E101(i), declare E101.
The only exception is E160b (annatto bixin or annatto norbixin). Instead, in the case of annatto, the E number must be specified to E160b(i) (annatto bixin) or E160b(ii) (annatto norbixin).

Label exceptions

There are some exceptions in the additives regulation that must be taken into account. First, there are certain ingredients that are not considered additives even though they may meet the definition of additive. These ingredients are listed in Article 3 of the Additives Regulation. Thus, these ingredients are not declared as additives.

In addition, additives need not be declared if their presence in a foodstuff is solely due to the fact that they were incorporated in one or more ingredients of that foodstuff. This is the "carry-over principle. This is defined in Article 18(1)(a) and (b) of the Additives Regulation.

Finally, of course, additives that have no function in the finished product and thus are used as processing aids need not be declared.

Clean label ingredients

There is a true clean label trend. But what does that have to do with additives? Clean label ingredients are ingredients with the same technological function as additives. They are often natural ingredients, such as plant extracts. It also happens that the unpurified version of an additive is used, for example buffered vinegar instead of acetic acid (E260). However, these ingredients are not on the EU list. Therefore, the use of clean label ingredients is seen by the NVWA as unauthorized additive use. Moreover, it can also be misleading to consumers.

Common mistakes

In short, there is a lot involved in the use of additives in food. A lot of information can already be found with the help of legislation and digital database. Finally, we would like to pass along some points of interest. These are common mistakes on the label:

• Both the E number and the specific designation are listed;
• The additive is declared two with two different functions;
• Specific designation or category name does not correspond one-to-one with legislation;
• The additive is not approved for use in the product category or does not meet the maximum levels;
• The carry-over principle is not met.

Want to know more?

Our Regulatory Affairs Support team is ready to assist you. For more information contact us at +31 (0)30 - 65 66 010 or email info@precongroup.com. We also have training on additives? View the training page Labeling of Additives.