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Legal "Best before" date of a composite dry mix

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Petar Petrov

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Posted 21 May 2009 - 05:47 AM

Dear colleagues,

the company I work currently is producing very big variety of dry mixes - jelly-powder (like Jell-O), instant drinks (like Tang), creme-caramel dry mix and blended milk powder with vitamins.

The common thing for all finished products is that they're produced by dry-blending different powdered ingredients and packing the resulting dry mix afterward.

Now, all the ingredients come with their best-before date.
Let's say TODAY ( 21 May 2009) we're manufacturing a jelly-dry mix by mixing a gelatin
( expiring in Dec 2009), with a food colour(expiring Feb 2010) and with a citric acid (expiring March 2010).

A food standard on shelf-life says that the maximum shelf-life for a jelly mix is 18 months. If we're following it, our product, produced today would be labeled "Best before : 20 Nov 2010" (and that is what many companies are doing).

Does it seem right to you to "artificially" extend the shelf-life of a dry-mix in such way, "forgetting" the shelf-life of the ingredients ? Do you know any regulation on such problem ?



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Posted 21 May 2009 - 07:50 AM

Welcome to the forums Petar.

Can anyone help on this one?


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cazyncymru

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Posted 21 May 2009 - 09:32 AM

Dear colleagues,

the company I work currently is producing very big variety of dry mixes - jelly-powder (like Jell-O), instant drinks (like Tang), creme-caramel dry mix and blended milk powder with vitamins.

The common thing for all finished products is that they're produced by dry-blending different powdered ingredients and packing the resulting dry mix afterward.

Now, all the ingredients come with their best-before date.
Let's say TODAY ( 21 May 2009) we're manufacturing a jelly-dry mix by mixing a gelatin
( expiring in Dec 2009), with a food colour(expiring Feb 2010) and with a citric acid (expiring March 2010).

A food standard on shelf-life says that the maximum shelf-life for a jelly mix is 18 months. If we're following it, our product, produced today would be labeled "Best before : 20 Nov 2010" (and that is what many companies are doing).

Does it seem right to you to "artificially" extend the shelf-life of a dry-mix in such way, "forgetting" the shelf-life of the ingredients ? Do you know any regulation on such problem ?


Hi Petar
You really should be establishing the shelf life of your product by carrying out tests to see if the product is still food safe and that the ingedients are still viable at the end of the products shelf life (not the ingredient)

You really ought to build up data as if you just went with a guess on shelf life you'd have no due diligence defence.

As an aside Best Before means that it is "at its optimum best quality standard" and is nothing to do with food safety.

Caz x


Petar Petrov

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Posted 21 May 2009 - 02:21 PM

Hi Petar
You really should be establishing the shelf life of your product by carrying out tests to see if the product is still food safe and that the ingedients are still viable at the end of the products shelf life (not the ingredient)

You really ought to build up data as if you just went with a guess on shelf life you'd have no due diligence defence.

As an aside Best Before means that it is "at its optimum best quality standard" and is nothing to do with food safety.

Caz x


Dear Caz,

I completely agree on your opinion on the need of real testing for determination of the shelf-life on the finished product.

My question was more focused on the legal side of the process - food authorities would put fine or would give a warning if you store for an example a skimmed milk powder having one 1 month left to the "best before" date,

but they would have no objections on using this ingredient in a dry mix which will have 1 year shelf-life from today (because the shelf-life studies confirmed earlier, that the finished product is safe and organoleptically acceptable after 1 year).

One cannot think that the same skimmed milk has gone trough some increasing it's shelf life treatments - it was just dry-blended with the other dry ingredients.

I think there should be some legislation saying "the shelf-life of a food that has been produced by means of simple mixing of several ingredients without any other processing steps (that result in reduction of the number of the microbes, the oxidation state of the fat, etc) , cannot be longer than the shelf-life of each ingredient in the mix".

Do you agree on that ? Is there such a legislation ?


AS NUR

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Posted 22 May 2009 - 12:41 AM

Dear Petar...

According to ISO 22000 (clausul 7.3.3.2), the caracteristic of end product shall be described in document to exten needed to conduct the haazard.. and the document should have information about intended shelf life....

IMO...as long as you have any external legal data to validate your product shelf life steatement, you can make it as reference..
if you don't have any external data .. you should bulit your data by yourshelf....



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Posted 22 May 2009 - 05:22 AM

Dear All,

It's an interesting question and I suspect touches a "grey" area. Presumably the actual practice will depend somewhat on the sensitivity of the product. It is also possible that the criteria for defining the shelf life on the mixed product will differ to the individual components ?

I can understand the (diligence defendable) logic in measuring the shelf life on the specific mixed product however I suspect the operational reality is often not to do this. I was reading an article recently which indicated that some operators do determine "Use By" periods (which must have a substantial safety factor I guess) and then apply a shortcut "rule of thumb" to set the "Best Before". One major practical difficulty is where manufacturers / blenders often have a stock of many, many input materials (each with its own range of production dates) which are then re-mixed into a multitude of formulations. Some kind of "representative" item(s) then becomes almost inevitable IMEX for shelf life reference.

Legally I think this is usually determined by (local) labelling regulations or those of the intended destination? Do they exist in EU ? I remember a furore over the validity of labelling data in UK 2-3 years ago, probably still on-going. Did a quick google but couldn't see any national regualtions anywhere.

Rgds / Charles.C


Kind Regards,

 

Charles.C




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