FSA consultation on proposals for new EU regulations
Our views represent in particular the views of consumers, producers, and retailers with interests in the markets directed to the population describing themselves as meat-reducers, dairy-frees, vegetarians and vegans. It is probably the biggest “ethnic” group with specific cultural aversions to practices, ingredients, and descriptions of foods and beverages in the British market.
Water is an ingredient added in many processed foods, especially beverages such as fruit juices (e.g. when made up from concentrates) and drinks; manufacture of fermented products such as beers and bakery goods involves the use of water in various stages of preparation. Sources of the water will be variable in content, e.g. in minerals and trace elements, and be of some dietary significance (e.g. in burtonized water used by brewers and for fluoridised water used as a diluent).
2. Processing Aids
We welcome reduction of exemptions of these products from listings of ingredients. Some may indeed not be contained as such in the consumed food, but the sources and need for them concern some consumers. The longstanding complaint over exemptions for all contents of certain beverages and omissions of processing aids (e.g. for clarification, chill-proofing etc.) adds to the rankling over usage and sources of fining agents (which may be derived from animal, fish or egg by-products or from minerals). GM-generated agents may be used undisclosed as brewing aids and adjuncts without disclosure on labels or at point-of-sale. Customers buying cask-beers or unpasteurised “live” bottled beers are, for instance, denied information that should be readily accessible.
Microorganisms, such as “live” yeasts and bacteria, are commonly employed sources of mixtures of enzymes advantageous in manufacture and processing. These agents may be the result of GM (in modern definitions of the term) and they may be obtained from animal sources or from cultures containing animal-derived by-products. The chymosins and ripening and maturing agents for making cheeses illustrate this point. Similar issues arise in the origins and derivation of fortifying agents, e.g. of riboflavin (vitamin B2) and cobalamines (vitamin B12). Labelling and descriptions may lead to misunderstandings: for instance, the presence of lactobacilli in supposedly dairy-free yoghurts appears at first sight contradictory, and ingredients named as lactones may have no connection with milk nor dairy products.
4. Proteins and Allergens
Curtailed descriptions on labels of enzymes must be accompanied by accessibility for the customer of detailed information. IT should make this easy. Allergies and intolerances are attributed to proteinaceous products of various types, and aversions are attributed in blanket exclusions and warnings (e.g. “does not contain nuts”), as well as in what could be better-informed specific attributions and production from dedicated factories (e.g. for oat or quinoa cereal products of special interest to the population with enteropathies caused by gluten). In some instances foods such as dairy products may need differentiation on the basis of their inflammatory content of carbohydrate material (e.g. of lactose and galactose), as well as of polypeptides and proteins. Genomics and metabonomics are illustrating the increasing significance of usefully informative labelling and deference to the needs of customers otherwise unnecessarily denied choice.
Foods, feeds and pet food, as well as supplements, must be covered in common regulations on additives, nutritional details, and labelling. Fortification of feedstuffs and residues of processing aids (e.g. disinfectants) make milk a major source of iodide in most British diets. Contrary to general belief and to practice in other European countries hardly any iodised salt is consumed. In our experience there are confused populations in Europe deficient in the essential element iodine. Certain additives derived from seaweeds (such as agar, alginates, and carrageen) as texturising factors may make good a perceived lack, but at the moment customers are not furnished with enough information of this type to resolve the dilemma.
6. Encapsulation, Beadlets etc.
Flavourings and nutritional supplements are examples of additives to manufactured foods and dietary adjuncts included in protective envelopes in the form of capsules or beadlets to prevent volatilisation and to preserve delicate flavours and unstable molecules. The coatings of the capsules which, as processing aids, are not declared on labels, violate the principles of customers trying to lower their complicity in the exploitation of animals (e.g. use of gelatin). This exception should be lifted.
7. Unnecessary and Objectionable Artefacts
Additives used as colorants represent a cosmetic purpose objectionable because of its avoidable demand for animal tests for frivolous purposes. They offend customers seeking cruelty-free foods and the general trend in curtailing experimentation on animals. Labelling and descriptions should differentiate cruelty-free foods from those that entail such frivolous exploitation. Caramels (E150) offer good subjects for such alerts.
Dr. Alan Long
Hon. Research Adviser