codex alimentarius commission

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1 codex alimentarius commission FOOD AND AGRICULTURE WORLD HEALTH ORGANIZATION ORGANIZATION OF THE UNITED NATIONS0 JOINT OFFICE: Viale delle Terme di Caracalla ROME Tel.: Telex: FAO I codex@fao.org Facsimile: Agenda Item 5 CX/FO 99/8 JOINT FAO/WHO FOOD STANDARDS PROGRAMME CODEX COMMITTEE ON FATS AND OILS Sixteenth Session London, United Kingdom, 8 12 March 1999 PROPOSED DRAFT STANDARD FOR FAT SPREADS AND BLENDED SPREADS GOVERNMENT COMMENTS AT STEP 3 (United Kingdom, Japan, Spain, Brazil, IDF, IFMA) UNITED KINGDOM The UK is aware that the Milk and Milk Products Committee has established a Working Group to consider, inter alia, a proposed Draft for Dairy Spreads and that the question of the need for such a standard has been raised (ALINORM 99/11, paras ). In light of this, the UK believes that the Fats and Oils Committee must consider carefully whether there is sufficient international trade in fat spreads and blended spreads to justify a Codex Standard and that a decision should be made on this before any detailed discussions of the content of the draft take place. Notwithstanding the above, if the Fats and oils Committee conclude that work on elaborating the Standard should continue, the UK s previous comments on the text still stand, as follows. 2.2 Edible fats and oils The modifications which were suggested for this section at the 15 th Session of the CCFO in November 1996 would permit the use of synthetic fats in fat spreads and blended spreads. This is a significant departure from the definition agreed previously at Step 3 (ALINORM 95/17, Appendix IX) and essentially would allow novel foodstuffs on the market. Whilst we support moves to encourage product development and innovation, in our view it is essential that novel foodstuffs are not marketed before a full scientific evaluation has been carried out of both the safety aspects and potential nutritional impact. The wider issues associated with novel foods are still being discussed at an international level and we believe strongly that it would be premature for CCFO to make provision for such products at this stage. Accordingly, we would prefer the definition of edible fats and oils to be drafted as follows: Edible fats and oils means foodstuffs composed mainly of glycerides of fatty acids. They are of vegetable or animal (including milk) or marine origin. They may contain small amounts of other lipids such as phosphatides, of unsaponifiable constituents and of free fatty acids naturally present in fat or oil. Fats of animal origin must, if originating from slaughtered animals, be obtained from animals in good health at the time of slaughter and fit for human consumption as determined by a competent authority recognised in national legislation. Fats and oils that have been subjected to processes of modification including hydrogenation are included. 3.2 Permitted ingredients Inulin is more accurately defined as a polysaccharide rather than as an oligosaccharide. It is thus suggested that the text should be amended as follows: -Mono, di-, oligo- and polysaccharides, including inulin, and malto-dextrins.

2 2 7.1 Name of the food This section does not make clear that the term reduced fat may be used for all fat spreads and blended spreads which contain 61% fat. It is thus suggested that the text of this section is redrafted as detailed below: The name of the food to be declared on the label of products covered by this standard shall be as specified in Sections and Nutrition claims concerning the fat content of products covered by this standard may be used in accordance with Codex Guidelines on Use of Nutrition Claims. The use of such nutrition claims and the terms three-quarter and half shall be mutually exclusive. JAPAN 1. Scope A maximum limit of fat content in margarine is unnecessary. Because margarine and blend are used not only as spread but also for baking, frying, cooking and so on, in home cooking. The Codex Standards for Butter and Whey Butter do not specify a maximum limit of fat content. Therefore margarine and blends should be standardized in the same way as butter. 3. Essential Composition and Quality Factors Fat Spreads We propose milk fat in fat spread should be no more than 50% and blended spreads more than 50%, this classification is clearly between fat spreads and blended spreads for consumers The fat content shall be as follows: There is no need to establish a maximum level for margarine The fat content shall be as follows: There is no need to establish a maximum level for blends. 3.2 Permitted ingredients The following ingredients should be added: Fructo-oligosaccharides, galacto-oligosaccharides, isomalto-oligosaccharides, palatinose-oligosaccharides Lacto-gluco-oligosaccharides, soybean-oligosaccharides Sugar alcohol, honey, fruit and fruit products, chocolate, cocoa, spices, nuts paste, liquor, vinegar. 4. Food additives In Japan, the substances mentioned below are not allowed to be added to food. 4.1 Colours 160e, 160f 4.3 Emulsifiers 432, 433, 434, 435, 436, 472(d), 472(f), 474, 479a, 479b, 481, Preservatives 203, 212, Thickening and Stabilizing Agents 402, 403, 404, 405, 463, 464, 465, 500(iii) 4.6 Acidity Regulators 261, 263, 326, 331(i), 331(ii), 335(i) 4.7 Antioxidants 302, 308, 309, 319, 389

3 3 4.9 Flavor Enhancers 624, 626, 628, 629, 632, 633, Miscellaneous 920, 938, 942 In Japan the following food additives are permitted to be added to margarine and fat spreads 4.4 PreservativesMax. level 200, 202, 210, 211 1g/kg singly or in combination 4.5 Thickening and Stabilizing Agents 405 1% 461, 466 2% singly or in combination 4.6 Acidity Regulators 327, 333, 341, 526 1% 4.6 Antioxidants g/kg g/kg 4.8 Antioxidant synergists 385 not allowed 4.9 Flavor Enhancer 509, 623 1% 4.10 Miscellaneous % 8. Methods of Analysis and Sampling Determination of Vitamin A and D should be replaced with Liquid Chromatography Method. 8.6 Vitamin A According to AOAC (Liquid Chromatography Method) 8.7 Vitamin D According to AOAC (Liquid Chromatography Method) SPAIN Section 1. Scope It is proposed that the minimum percentage of fat should be 10% and the maximum 90%. Section 2. Description Spanish version only Section 3. Essential Quality and Composition Factors The following alternative wording is proposed to points a) and b) of section : a) Margarine: 80% - 90% b) Three-quarter Fat Margarine: 60% - 62%

4 4 Sections 3.1.2, and : Spanish version of the term "Blended Spreads" The following alternative wording is proposed for points a) and b) in section : a) Blend: 80% : 90% b) Three-quarter fat blend : 60% - 62% 3.2 Spanish version only Section 4. Food Additives Colours 4.1 Title (Spanish only) The use of additives 100, 160 a) and 160 b) is considered sufficient for this type of products. Additives 160e) and 160f) should be deleted in order to avoid excessive use of colours. Emulsifiers The use of additives 432 to 436 is restricted to baking fat emulsions and the use of 473 and 474 to frying fat emulsions. They should be deleted from the Standard. Similarly 477 Propylene glycol esters of fatty acids and 479b) Thermally oxidised soya bean oil are used only in frying fat emulsions, consequently these additives should be deleted from the standard, as their use is not justified. The use of 479a) is not justified in these products. Preservatives Additives 210 to 213, Benzoic acid and Benzoates should be deleted as the sorbates cover the need for preservatives in fat spreads. Moreover benzoates are additives with a low ADI and their use should not be extended without necessity. Thickeners and Stabilizers Additives 339 Sodium Orthophosphates and 450 (i) Disodium diphosphate should be deleted. Their use is not justified The level of 405 Propylene glycol alginate should be limited to 3g/kg. Substances 1400, 1401, 1402, 1403 and 1405 are not considered as additives in the European Union. Number 1411 is superfluous, as Distarch phosphate has been assigned Number Cellulose and Microsrystalline cellulose have been assigned Number 460 Acidity Regulators Additives 339 Sodium Phosphates, 340 Potassium phosphates and 341 Calcium phosphates should be deleted as their use is not justified

5 5 Antioxidants So called "strong antioxidants" - 310, 320 and 321 which can be added to the fat component of the products covered by the standard (they are included in the lists for animal and vegetable fats) should not be included. Moreover, they should not be used at levels superior to what corresponds to the percentage of fat in these products. In addition JECFA withdrew the ADI for 310 in Additive 319 TBHQ has a temporary ADI of 0.2 mg/kg. It should be deleted for the reasons exposed in the other standards. Additive 389 Dilauryl thiodipropionate has an temporary ADI of 0.3mg/kg. It should be deleted Antioxidants synergists 384 Isopropyl citrates has an temporary ADI of 0.3mg/kg. It should be deleted Miscellaneous The levels for polyols should be specified, as they have an action as humectants and sweeteners. If used as sweeteners they should be referred to in that category. 338 Orthophosphoric acid should be entered as a processing aid. The level for 405 Propylene glycol should be limited to 3 g/kg. 551 Silicon dioxide, amorphous has an anticaking function. It does not make much sense to include it in this standard. The use of L-Cysteine salts does not seem justified. It is an amino-acid. BRAZIL Section 2.1 We understand that the definition should include the product in liquid form. It is common in Brazil as well as in other countries to find products being sold under the name of LIQUID MARGARINE. The product in the liquid form was already in the Codex Stan Codex Standard for Margarine. Section The Delegation of Brazil indicated that terms like half margarine, three-quarter fat margarine do not correspond to what is normally used in Brazil and understands that such terms are confusing to the consumers especially when we consider such terms translated into other languages. The Delegation suggests that the Standard should also allow the use of the term MARGARINE for all products as long as the information of the total fat percentage is indicated on the label. Section 7.1 Name of the Food The Standard should also allow the use of the term Margarine and the information of the total fat percentage on the label panel. The Delegation suggests that the conditions for the use of nutrition claims such as reduced and low should be included in the Standard, once these conditions differ from the horizontal Guidelines for Use of Nutrition Claims. IDF Information on the food additives cited in the Proposed Draft Standard: these views are supported by both IDF and the International Federation of Margarine Associations (IFMA). See IFMA comments below.

6 6 IFMA (International Federation of Margarine Associations) IFMA welcomes the Proposed Draft Standard for Fats Spreads and Blended Spreads but has the following comments to: 1. Scope IFMA would like the removal of the brackets containing more than 95% fat. 2. Description Section 2.1 IFMA suggests the deletion of and that is firm and spreadable at 20ºC as there are on the different markets more and more products in liquid and solid form, used for both consumer purposes as well as industrial and bakery purposes. Also the Scope takes this into account using the words primarily for use as spreads. Moreover, the present Codex standard for margarine explicitly includes liquid margarine. 3. Essential Composition and Quality factors Sections and IFMA suggests the addition of the word average/typical (i.e. the average/typical fat content shall be as follows..) to take into account oscillations in the fat content, which are technically unavoidable. Furthermore, the wording should be consistent with chapter 7.3.1, which refers to the declaration of the typical fat content. Sections and IFMA supports the current wording, which does not leave any dead zones. Section 3.2 IFMA suggests to add polysaccharides under the last point. IFMA also suggests the removal of the brackets containing including inulin. 4. Food Additives: See below 5. Contaminants Section 5.1 IFMA suggests the following wording: the products covered by the provisions of this standard, shall be free from heavy metals in amounts which may represent a hazard to human health. This sentence alone should suffice to establish the principle that fat spreads and blended spreads should be free from heavy metals. 6. Hygiene IFMA supports the current wording. 7. Labelling Section 7.1 IFMA suggests the addition of the following labelling specifications: low fat : not more than 41% total fat content. cholesterol free : not more than 5 mg/100g fat and at least 70% cis- unsaturated fatty acids. low in saturated fatty acids : not more than 25% of total fatty acids as saturates and at least 70% as cis unsaturates.

7 The deviation from the Codex Guidelines for Use of Nutrition Claims is based on the reference in the Codex Procedural Manual (CAC, July 1995) that commodity committees may diverge from the general principles, if justified and endorsed by the relevant horizontal Committees (9 th edition, p.111). IFMA also believes that it should be possible for all those products containing less than 61% to be labelled reduced fat and all those containing less than 41% to be labelled low fat. Section IFMA supports the retention of the word typical. 8. Methods of Analysis and Sampling Section 8.1 and 8.2 IFMA suggest deletion in line with the new wording proposed under Technological Justification for the Use of Additives Additives agreed at the 14 th Session of the CCFO and endorsed by the CCFAC as well as additives generally permitted for use in accordance with GMP of the GSFA (adopted at Step 8 by the Codex Alimentarius Commission in June 1997) may be used and have been justified before. In addition the following additives are requested by IFMA for use in fat spreads, at the levels indicated: INS Additive Maximum Level Justification 310 Propyl Gallate 311 Octyl gallate 312 Dodecyl gallate 200ppm singly or in combination Very effective antioxidant. Necessary especially in very hot climatic conditions. Their use is important for fats going to the professional 321 BHT > 80% fat: 200 ppm < 80% fat: 100 ppm 319 TBHQ 200 ppm, singly or in combination with gallates 334 Tartaric acid 335 Sodium tartrates 336 Potassium tartrates 337Potassium-Sodium tartrate 338 Phosphoric acid 339 Sodium orthophosphate 341 Calcium orthophosphate 450a Disodium diphosphate 384 Isopropyl citrate monoglyceride citrate 5000 ppm singly or in combination 5000 ppm as P2O5 singly or in combination manufacture of heat-treated foodstuffs A very effective antioxidant, especially in hot climates, used for professional market applications, more effective than tocopherols This powerful antioxidant is used in tropical climates Acidity regulator, an alternative to phosphates ph regulator. Stabilizes the proteins in aqueous solutions, and prevents precipitation 200 ppm Isopropyl citrate is an antioxidant with metal ion scavenging properties and also emulsifying properties. Monoglyceride citrate is a flavour stabilizer. It splits during the process of digestion into glycerides and citrates, both harmless ingredients 385 Calcium Sodium EDTA 75 ppm Metal scavenger and antioxidant in low fat spreads, used in food products. By binding heavy metals the mentioned products are protected against oxidative deterioration and discolouration 7

8 8 389 Dilauryl Thiodipropionate 200 ppm Stabilizer of emulsions, stabilizes the consistency of certain fat spreads, especially for products with a very long shelf life, like army supplies and for catastrophe rescue services 405 Propylene glycol alginate 3000 ppm Thickener effective in certain product formulation 476 Polyglycerol polyricinoleate 5000 ppm Its use is essential in fat spreads with a low fat content. It creates a very fine water in oil emulsion with better stability use 479a Thermally oxidised soya 5000 ppm Is an emulsion reducing spattering in frying or bean oil 479b Thermally oxidised soya bean oil interactive with mono- and diglycerides of fatty acids cooking oil 5000 ppm Is an emulsifier reducing spattering in frying or cooking oil 942 Nitrous oxide GMP Propelling gas used for aerosol package 938 Argon GMP Is an inert gas, used to prevent oxidation 1410 Monostarch phosphate 1411 Distarch phosphate 5000 ppm singly or in combination Gelling agent and thickener for the aqueous phase of fat spreads. Increases physical and microbiological stability