I don't believe that Alex Gonçalves' interpretation of EU Directive 95/2 is
correct. Laura Garrido has already explained that the listings in Annexe IV
of the Directive are not to be read horizontally and the way Alex has
presented them in his message is misleading and not how the Directive
presents the situation. It is quite clear to me that in Annexe IV that the E
numbers, 450, 451, & 452, the chemical compounds relating to these numbers,
and the foods they can be used in should be read as a single block within
the first 3 columns. It does not make sense otherwise. What should be read
horizontally is the food type listed in column 3 and the permitted maximum
concentration of added phosphate in column 4. It might be that the
presentation is the Directive could be clearer, but I have never found that
EU regulations are clearly explained or presented. I think you are expected
to know the purpose of the regulation and apply it without a pedantic
interpretation of the wording. Phosphates are added to foods for a variety
of purposes and the purposes are not the same for different classes of
foods. For example, diphosphates, E450, are used mainly as acidity
correctors/buffers and to some extents as complexing agents and I am not
sure if they are used in any processed fishery product. Triphosphates, E451,
and polyphosphates, E452, are added to many processed fishery products,
fresh, frozen and canned, as water retention agents which are listed in
column 3 of the Annexe. (Canned crustacean products are listed, but not
canned fish products. I think this is more probably an oversight on the part
of the drafters of the regulation rather than a desire to forbid the use of
polyphosphates in canned fish). They are used in meat products for the same
purpose and the meat products are listed near the top of column 3, opposite
E340 and a horizontal reading of the columns would suggest that
polyphosphates may not be used in meat products, which is not the case.
Analytically it is not easy to demonstrate that polyphosphates, as distinct
from orthophosphates, have been added to a fishery product because studies
have shown that tripolyphosphate is quite rapidly hydrolysed to
orthophosphate in fish muscle.
Anyone consulting the wording of the Directive should check that it is the
latest version. I have among my papers a copy of 95/2 copied from the
Official Journal of the European Communities, L61, of 18/3/95 and there are
minor differences between this and the version on the EU Internet site at
http://ec.europa.eu/food/fs/sfp/addit_flavor/flav11_en.pdf. For example, the
list in the OJ publication of 1995 does not include canned crustacean
products and unprocessed and processed molluscs which are included in the
Internet version.
Peter Howgate
----- Original Message -----
From: "Alex Augusto Gonçalves" <alaugo@terra.com.br>
To: "Chella Rao Grandhi." <gvrchella@gmail.com>; <seafood@ucdavis.edu>;
"GarridoLaura M" <shrimp@ufl.edu>
Sent: Wednesday, March 28, 2007 2:35 PM
Subject: Res: RE: Use of E450 in fishery products
Dear Laura, Chella and others colleagues,
I'm not agree with you: E450 is not allowed for fish and/or fish products
(according to EU Directive 95/2/EC):
ANNEX IV - OTHER PERMITTED ADDITIVES
The maximum levels of use indicated refer to foodstuffs ready for
consumption prepared following manufacturers' instructions.
See Page 35:
In the following applications the indicated maximum levels of phosphoric
acid and the phosphates E 338, E 339, E 340, E 341, E 343, E 450, E 451 and
E 452 May be added individually or in combination (expressed as P2O5):
ENoNameFoodstuffMaximum level
E 450DiphosphatesSauces5 g/kg
Disodium diphosphateSoups and broths3 g/kg
Trisodium diphosphateInstant tea and instant herbal infusions2 g/kg
Tetrasodium diphosphateCider and Perry2 g/l
Tétrapotassium phosphateChewing-gumq.s.
Dried powdered foodstuffs10 g/kg
Dicalcium diphosphateChocolate and malt dairy-based drinks2 g/l
Calcium dihydrogen diphosphateAlcoholic drinks (excluding wine and beer)1
g/l
Breakfast cereals5 g/kg
Snacks5 g/kg
The E 451 (I, ii, iv) are used (applied/allowed) to surimi, fish and
crustacean paste, fish fillets..
I'm very confused because this directive show us some phosphates, but
individually E450 is not applied to seafood (only E451).
Maybe added in combination, but in which level?? (0.1; 0.5 or 1%)??
All the best,
__________________________________________
Prof. Dr. Alex Augusto Gonçalves (alaugo@terra.com.br)
Food Engineering Course - UNISINOS (alexg@unisinos.br)
Gastronomy Course Coordinator - UNISINOS
Master in Food Engineering
Doctor in Production Engineering
FAO/UN International Consultant
GI-Pescado Coordinator
http://paginas.terra.com.br/educacao/seafoodgroup/
Executive member of Pan-American Network of Fish Inspection, Quality Control
Technology and Aquaculture
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