Re: Use of E450 in fishery products

From: Remi Michalowski (remi.michalowski@cpp.co.id)
Date: Tue Mar 27 2007 - 21:06:24 PDT

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    Dear Laura, Dear Chella,

    Mea culpa... Mistake while reading.

    Perfectly agree and it is the same for EU, French or UK legislations.

    European countries do not offer difference in Directive interpretation (would be killing their business within the EU).

    Rgds,

    Dipl. Ing. Rémi Michalowski
    Deputy General Manager IQA Food Processing
    PT. Centralpertiwi Bahari - Lampung, Indonesia
    HP + 62 815 4040 484
    Yahoo Messenger ID: michalowski_rmi@yahoo.fr<mailto:michalowski_rmi@yahoo.fr>
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    CPB - Integrated Shrimp Farming. "From Pond to Plate"
    A CPP Company. Member of Charoen Pokphand Group

    On Mar 27, 2007, at 10:31 PM, Garrido,Laura M wrote:

    Dear List Members:
    E450 is ALLOWED. The inspector should have known this. However I can understand the confusion because the format in which the regulations in EU directive 95/2/Act are illustrated is very confusing if you are are familiar with it.
    In Annex IV of EU directive 95/2/EC there are 4 columns. The first column to the left has the E number (I.e. E450, 451, etc.), the second column has the name of the additives represented by the E number (Diphosphates: Disodium phosphates, trisodium diphosphates etc). Now, the the third column lists the foodstuffs that the additives listed on column 1 or 2 (from E338 to the column break E468), can be added to, singly or in combination. This list starts with non alcoholic flavored drinks (page 31)and and ends with solid dietary supplements (page 33). As you can see 1) fillets of unprocessed fish, frozen and deep frozen 2) unprocessed, processed mollusks and crustaceans frozen and deep-frozen, 3) surimi, and 4)fish and crustaceans paste are all included in this list to which E450 can de added singly or in combination. Again, the ending point for the list is marked with a column break. I have seen through the years that many people have interpreted that E450 is only allowed sauces, soups, instant tea etc. which are the items listed right next to it. This is a mistake.

    Now column # 4 is the maximum level that is specific to the foodstuff listed right next to it in column # 3. Maximum levels of phosphates will varied depending on the product. For example surimi is 1g/kg while processed and unprocessed mollusks and crustaceans frozen and deep frozen is 5 g/kg expressed as P2O5.

    CARNAL and others phosphates that contain E450 can be used in fishery products.
    Go Gators!
    Laura Garrido
    Shrimp School
    University of Florida

    ________________________________
    From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu] On Behalf Of Chella Rao Grandhi.
    Sent: Tuesday, March 27, 2007 7:27 AM
    To: seafood@ucdavis.edu<mailto:seafood@ucdavis.edu>
    Subject: Use of E450 in fishery products

    Dear List Members,

    One of the EU - FVO inspectors who visited India in November 2006
    objected to the use of "CARNAL" in fishery products. CARNAL is a
    mixture of phosphates E 451, E 452 and E450. The objection was on
    the ground that E 450 is not permitted by EU DIRECTIVE 95/2/EC for
    use in fishery products. Carnal is manufacured by BUDENHEIM - a
    German company and EU importers require us to use it in fishery
    products. Will any one clarify whether E450 is really not permitted by
    EU for use in fishery products ?

    Thanks and best regards.
    Chella Rao Grandhi.

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