Cheese annalouge declaration

Do  I have to declare Potato Starch, sodium citrate and citric acid?

Thank you:) :biggrin:

Hi AgaMi,

:welcome: 

Welcome to the IFSQN forums

I would refer to guidance from gov.uk or the Food Standards Agency:

FSA Packaging and labelling - Legal requirements that you have to follow as a food business.

Other than in Northern Ireland (NI), any references to European Union (EU) Regulations in this guidance should be read as meaning retained EU law. You can access retained EU law via the HM Government EU Exit web archive (Opens in a new window). This should be read alongside the relevant EU Exit legislation that was made to ensure retained EU law operates correctly in a United Kingdom (UK) context. EU Exit legislation can be accessed on legislation.gov.uk (Opens in a new window)

FSA - Approved additives and E numbers

Most additives are only permitted to be used in certain foods and are subject to specific quantitative limits, so it is important to note this list should be used in conjunction with the appropriate legislation:

retained EU Regulation 1333/2008 (Opens in a new window) on food additives in England and Wales

EU Regulation 1333/2008 (Opens in a new window) on food additives and Commission Regulation (EU) 2022/63, amending Annexes II and III to Regulation 1333/2008 (Opens in a new window) in Northern Ireland

FSA Contacts - Food additives team: foodadditives@food.gov.uk

Kind regards,

Tony

Which labelling legislation are you trying to follow? 

It looks like you've written a declaration for the USA, but your account has the British flag.

It's quite possible that if you're British, you might need to follow EU law if you export to the EU.

A little bit of clarification would help.

Do  I have to declare Potato Starch, sodium citrate and citric acid?

 

According to EU food legislation, you can only leave additives out of the final declaration if they are a "carry-over" from an ingredient and do not serve a technical function in the final product (unless it is an allergen, in which case you should always include it on the label).

If you want to leave the sodium citrate and the citric acid out of the declaration, you need to be able to explain that they served a technical function in the cheddar cheese that is no longer applicable to the final product (the cheese analogue). You will have to declare the potato starch regardless as it is an ingredient in the cheese analogue itself and clearly serves a function in the product. Besides, if you don't declare it as an additive, you can't leave it out either way.