05/10/2012 Codex Committee on Processed Fruits and Vegetables (26 th Session) Montego Bay, Jamaica, 15-19 October 2012 EU comments on the Proposed Draft Codex Standard for Quick Frozen Vegetables (Revision of remaining individual standards for Quick Frozen Vegetables) Agenda item 5, CX/PFV 12/26/5 Mixed Competence Member States Vote The European Union and its Member States (EUMS) would like to thank the United States for having chaired this Electronic Working Group and for the comprehensive work in preparing the draft text. The EUMS would like to submit the following comments. General Comments ASSESSMENT OF DEFECTS The contents of each specific standard show that the tolerances for defects may be assessed in a variety of ways by the inspectorates, industry and laboratories in different countries, either by a maximum number of points per defect category (minor; major; serious), or by mass, since some defects may be assessed by number (extraneous vegetable material (EVM), stems etc.). For industry and laboratories, the second system is the most straightforward to apply. SIZE Sizing practices vary for some vegetables. Therefore, it seems a better idea not to specify the type of check, but to ensure instead that the tolerances take sufficient account of these practices. 1
PRODUCT PRESENTATION Some products lend themselves better to being kept together in blocks, whereas this may substantially impair the quality of other types of product. In any event, presentation in blocks must allow the specific characteristics of these products to be maintained. OTHER AUTHORISED INGREDIENTS Although added sugars appear under certain standards, this is not in line with industry s practices and is contrary to the WHO s global strategy for combating obesity. Frozen vegetables must remain free of sugars, salt and food additives for non-prepared vegetables. On the other hand, processing aids may be used. Furthermore, practices in industry are developing along with consumer tastes, and the addition of limited quantities of certain plant products, such as aromatic plants, cannot be excluded. This requires further examination in the Annexes. Specific comments CODEX STANDARD FOR CERTAIN QUICK FROZEN VEGETABLES 7.1.3 Lot Acceptance A lot should be considered as meeting the requirement of Section 8.1.1 when the number of defectives, as defined in Section 8.1.2, does not exceed the acceptance number (c) of the appropriate sampling plan with an AQL of 6.52.5. The international rules on sampling plans provide for the application of an AQL of 2.5 for quantity. 8.2.3 When any ingredient, [other than salt], has been added which imparts the distinctive flavour to the food, the name of the product shall be accompanied by the term with X or X flavoured, as appropriate. Frozen vegetables are marketed without salt, in some cases with the addition of plant products (cf. General comments). 8.2.4.2 Other styles If the product is produced in accordance with the other styles provision (Section 2.2.1), Section 2.4.1 8.2.5 Size Designation Option (a) should be retained and amended on a case-by-case basis in line with the products in the Annexes. 2
(a) When the vegetables are sized, the size, as defined in the corresponding Annexes, may be declared in conjunction with, or in close proximity to, the name of the product. 10. METHODS OF ANALYSIS AND SAMPLING An examination of the various standards shows that the methods of analysis must be specified for maize (Alcohol-Insoluble Solids (AIS) and Brix) and peas (AIS), for French fried potatoes (moisture content and fatty acids) and for green beans and wax beans (stringy). Detailed information on these methods will be provided at a later stage. ANNEX I: BROCCOLI 2.1.1 General Requirements [Quick frozen Broccoli shall be of reasonably uniform dark green to light green depending on the varieties. The inflorescences must be firm, compact of fine/close grain with floral buttons completely closed]. These criteria are essential for broccoli. If the floral button is not firm with a close grain, this means that the product is over ripe. This requirement is listed in the standards on fresh broccoli. 2.1.4. Defects and Allowances The practice in industry and official laboratories is to assess the tolerances for defects by mass. The term 'cut spears' should be added to the table. [3.1 PROCESSING AIDS] Citric acid (SIN 330), used as an antioxidant in bleaching. This additive is used as a processing aid by industry. ANNEX II: BRUSSELS SPROUTS 1.2.1 Sizing The broad sizing range in the table should be retained. 2.1.1 Other Permitted Ingredients: c.f. General comments (a) Sugars as defined in the Codex Standard for Sugars (CODEX STAN 212-1999). 2.2.2 Definition of Visual Defects (e) Decayed Decomposition: a sprout which shows significant internal or external decay [decomposition] deterioration but which remains fit for human consumption. 3
Decomposing products may not be placed on the market. (h) Poorly Trimmed or Mechanically Damaged Unit: i, iii: 5 mm of the butt end should be retained. 2.2.4.2 Sizing The broad sizing range in the table should be retained. The changes made to the size tolerances should be retained. In fact, for any given size, only sprouts of sizes graded directly below or above the declared size may be accepted. In addition, only 5% of sprouts of size (c) 30 to 36 mm may be accepted into the 'very small' size category. 2.2.4.3 The by mass proposal is more practical for industry and laboratories. [3.1 PROCESSING AIDS] Citric acid (SIN 330), used as an antioxidant in bleaching. This aid is habitually used by industry. ANNEX III: CARROTS 2.1.1 Other Permitted Ingredients: cf. General comments (b) Aromatic herbs and spices ; stock or juice of vegetables and aromatic herbs; garnishes composed of one or more vegetables (e.g. lettuce, onions; pieces of green or red peppers, or mixtures of both) up to a maximum of 10% m/m of the total drained vegetable ingredient of the total weight of the vegetable ingredient. 2.2.5 Defects and Allowances The by mass proposal is more practical for industry and laboratories. ANNEX IV: CAULIFLOWER 1.2.2 Sizing 1.2.2.1 Quick frozen cauliflower florets may be presented sized or unsized. [Size is determined by the maximum minimum diameter of the equatorial section.] The clarification in brackets is supported but needs to be corrected as indicated above. 1.2.2.2. The sizing proposal is supported. 2.1.1 General Requirements 4
Quick frozen cauliflower shall be of reasonably uniform white to dark cream colour over the tops of the units which may be slightly dull and have a tinge of green, yellow or pink. [The inflorescences must be firm, compact, of fine/close grain.] The description in brackets is a vital characteristic of cauliflowers. 2.1.4 Defects and Allowances TABLES 1 and 2 and the proposal should be included under Section 2.1.4, not under Section 2.3 LOT ACCEPTANCE. If the tables are included once again under Section 2.1.4, Section 2.1.3 should read: 2.1.4: visual defects shall be assigned points in accordance with the Tables in Section 2.1.6 below. The maximum number of defects permitted is the Total Allowable Points rating indicated for the respective categories Minor, Major and Serious or the Combined Total of the foregoing categories. PROPOSAL Tolerances by mass are preferable. ANNEX VI: FRENCH FRIED POTATOES TITLE Given the addition of sweet potatoes under Annex VI, the title should be changed as follows: FRENCH FRIED POTATOES and FRIED SWEET POTATOES 1.1 Product definition It should be clarified that fried potatoes coated in batter or breadcrumbs are outside the scope of the standard. 2.1.2. Optional Ingredients (d) Batters should be excluded cf. General Comments 1.2.1.3 PROPOSAL The table and designations have been reviewed to make them easier to understand. The 'length' criteria are currently used in industry. DESIGNATION LONG Dimension in mm across the largest cut surface 50% of units over 50 mm in length, and small pieces (defined in Section 2.2.3.2 (b)) representing under 6% in number 5
SHORT 15% of units over 50 mm in length, and small pieces (defined in Section 2.2.3.2 (b)) representing under 10% in number 2.2.5 Tolerances for Visual Defects Table 1 - Tolerances for Visual Defects The total number of defects ( serious + major + minor ) is far too high at 60 by comparison with what is being observed on the market. It is proposed that this figure be reduced to 27. 3.1.4 The words Quick Frozen shall also appear on the label, except that the term Frozen 1 may be applied in countries where this term is customarily used for describing the product processed in accordance with Section 2.2 of this standard. This section is already included in the general provisions. 4. FOOD ADDITIVES The list of food acceptable food additives can be reduced considerably if fried potatoes coated in batter or breadcrumbs are excluded from the standard. ANNEX VII: GREEN BEANS AND WAX BEANS 2.1.1 Other Permitted Ingredients: cf. General comments (a) Sugars as defined in the Codex Standard for Sugars (CODEX STAN 212-1999). 2.2.2 Definition of Visual Defects (c) Major Blemish: each piece blemished due to insect or pathological damage affecting an area greater than a 6 mm diameter circle, [2 mm to 4 mm for the extra small size] or blemished by other means to a degree which seriously detracts from its appearance. (d) Minor Blemish: each piece blemished due to insect or pathological damage affecting an area greater than a 3 mm diameter circle, [2 mm to 4 mm for the extra small size] or blemished by other means to a degree which seriously detracts from its appearance. For the small sizes of bean, such as extra small, the size of the blemishes must be reduced in line with the text in brackets. 2.2.4.1 Presentation (a) When the product is presented as free flowing a tolerance of 10% (m/m) shall be allowed for pieces which are stuck together to such an extent that they cannot easily be separated in their frozen state. When assessing this factor, the sample unit shall be the entire contents of the pack or 1 kg. This provision is included under Section 2.4.1 of the General Standard. 2.2.4.2 Visual Defects An error under the table requires correction: 6
TOTAL TOLERANCES: b) c to h: 20%; and if any one of the defects is over 1.5 times the tolerance of the table. ANNEX VIII: LEEK 1.2 PRESENTATION 1.2.1 Styles (d) Leek rings - parts of the whole leek, cut perpendicularly to the longitudinal axis into slices, not thinner than 10 mm and not thicker than 20 30 [20] [30] mm. These references should be in brackets. 30 mm better reflects the products on the market. 2.1.3 Definition of Visual Defects (a) Minor: discolouration which is light in colour. Each area or combined area of 4 cm² = 1 defect; (or if the greatest dimension is less than 20 mm) (b) Major: discolouration which is dark in colour. Each area or combined area of 4 cm² = 1 defect; (or if the greatest dimension is over 20 mm) The references in brackets should be retained, as it is easier to measure in millimetres. 2.1.6 Defects and Allowances The by mass proposal is preferable. ANNEX IX: PEAS 1.2.1 Sizing The sizing proposal is taken from the standard on preserved peas, and is justified here, given that the sizing practice is the same for preserved peas as it is for frozen peas. 2.1.1 Other Permitted Ingredients: cf. General comments Sugars as defined in the Codex Standard for Sugars (CODEX STAN 212-1999). 2.2.1 Analytical Characteristics The AIS measurement is rarely used by laboratories. However, any such existing analyses show that the difference between peas and sweet peas in terms of AIS limits is negligible. ANNEX X: SPINACH 1.2.1 Styles (b) Leaf Spinach - substantially whole leaves, most of which are separated from the root crown [with a maximum stem length of 10 cm]; It is very important to set a limit for the length of the root crown. This is usually fibrous, and the leaf is the part that consumers expect to be marked as spinach. In addition, laboratory analyses reveal a higher nitrate content in the stem than in the leaves. ANNEX XI: WHOLE KERNEL CORN 2.2.5 Defects and Allowances 7
PROPOSAL An error in the last line of the table requires correction: Total allowable points Total in % m/m METHOD USED TO DETERMINE the drained deglazed weight Two changes need to be made to improve the text: 2. EQUIPMENT: Scales - sensitive to 1 g sensitive to 0.1 g; since the measurement is in grams. 3.3 REMOVAL OF CONTAINER CONTENTS DEGLAZED WEIGHT The water bath shall contain an amount of fresh potable water equal to at least 8 times the weight of the sample taken with the sieve. The temperature should be adjusted to 27 C ± 1 C± 3 C The experience in laboratories shows this margin to be necessary and that it has no impact on the result. 8