Better Training for Safer Food

Initiative

Indre Stoskuviene

Working groups exercises

Inspection procedures.
1. Carry over principle
A2.05

2019
Food safety
 Control of compliance with the ML of FA is based on

• - documentary checks, i.e. the examination of commercial documents of the

ingredients/product specifications, exact recipes etc.;
• - ‘identity check’, i.e. a visual inspection to ensure that certificates or other
documents tally with the labelling of the product;
• - ‘physical check’, i.e. a check on the food itself which may include checks on the
packaging, labelling and the sampling of premixes/end products for analysis and
laboratory testing and any other check necessary to verify compliance with food
law;
• - weight value balance;
• - combination of above stated.

Food safety
 Key steps to verify if the carry-over principle is applicable

Verification if FA is NOT added on purpose

NOT added ADDED

Consideration of the level of the food additive Final decision if the foodstuff comply with the
analysed in the product as a whole and the provisions of Regulation (EC) No 1333/2008
level of the additive introduced by the carry- as well as with Regulation (EU) No
over principle. 1169/2011.

In case of sweeteners consideration the of

special provisions of Article 18.4 of
Decision if the carry-over principle can be Regulation (EC) No 1333/2008.
applied.

In case of ‘reverse carry-over’ if the principle

Practical application? can be applied as well as if it could be 3
demonstrated that the food is to be used
solely in the preparation of a compound food.
Food safety
Marshmallows: Ingredients: sugar, apple purée (apples, preservative sulphur dioxide) –
25,3%, corn starch syrup, egg whites, gelling agent pectin, acidity regulators: sodium
citrates, citric acid, flavor „Vanilla“.
Food Category – 05.2 Other confectionery including breath freshening microsweets.
Marshmallows and apple purée are composite foods.
1st case 2nd case 3d case

Art. 18: Art. 18: Art. 18:

a) in a compound food other than as
referred to in Annex II, where the
food additive is permitted in one of
the ingredients of the compound
food;
e.g. Marshmallows, except for cases other
than those listed in Annex II where sulfur
dioxide is authorized for use in one of the
Marshmallows ingredient (apple purée )
b) in a food to which a food additive, food enzyme or food c) in a food which is to be used solely
flavouring has been added, where the food additive: in the preparation of a compound food
(i) is permitted in the food additive, food enzyme or and provided that the compound food
food flavouring in accordance with this Regulation; complies with this Regulation.
and
(ii) has been carried over to the food via the food
additive, food enzyme or food flavouring; and
(iii) has no technological function in the final food;

Permitted if meets conditions: Permitted: Permitted if:

• Exemption does not apply (Annex II
states that sulphur dioxide in
Marshmallows can be from glucose
only, not more than 50 mg/kg, when
ML in glucose syrup is 20 mg/kg)
• Apple purée is used in production of
Marshmallows, when sulphur dioxide
in apple purée does not exceed 50
mg/kg.
 To use apple purée in production of Marshmallows  Apple purée would be intended
and not to declare sulphur dioxide in the label if: only for production of
Sulphur dioxide in apple purée does not exceed 50 Marshmallows and if sulphur
mg/kg dioxide in apple purée would be
AND useful in technological process
Sulphur dioxide in Marshmallows does not have of Marshmallows, when sulphur
technological function and total quantity of sulphur dioxide would be permitted to
dioxide does not exceed 10 mg/kg (no need to declare on use in Marshmallows (this is 4
the label) not the case)

Food safety
 FBO must prove, that:
Sulphur dioxide complies the
requirements in each composite
ingredient (how much is in raw
material, how much is in final
product from each ingredient
or in combination) in order to
ensure that the marshmallow has
been produced in accordance with
legal requirements.
Sulphur dioxide does not have
technological function and is less than 10 Sulphur dioxide as
mg/kg (otherwise should be labeled as technological ingredient
allergen) is not permitted to use
in production of
Marshmallows
Conformity is assessed on the basis of
the manufacturer's documents

Conformity is assessed on the

basis of the manufacturer's
documents

Concluding
May be placed on the market if evidence are provided / Not allowed to be
Not allowed to be placed on the market if there are no evidence placed on the market5

Food safety
 Thank you for your attention
AETS Consortium

Address : 17 av. André Marie Ampère, 64 140 Lons, France

Tel/fax: +33 5 59 72 43 23 / + 33 5 59 72 43 24
Email: contact@aets-consultants.com

Better Training for Safer Food

BTSF
• European Commission
Consumers, Health and Food Executive Agency
DRB A3/042
L-2920 Luxembourg

Food safety
Consumers,
Health And Food
Executive Agency
Food safety