[Having seen the reactions to "E450" I believe that somewhere my reaction got lost]
Peter is right.
Anyway: the EU inspector was wrong.
About Peter's remark on 'latest version': allways download the consolidated (CONSLEG)
legislation (however not official - but from there you may consider downloading the Official
Journal's texts).
see: http://eur-lex.europa.eu/en/index.htm select [simple search] and on the next page:
[consolidated text], and fill in for Directive [1995] & [2].
The direct link is in my message to Chella Rao.
I copy in my e-mail here:
========= START ==========
Dear Chella Rao
The inspector and you should have read this beforehand ...
download the directive:
http://eur-lex.europa.eu/LexUriServ/site/en/consleg/1995/L/01995L0002-20060815-en.pdf
then goto page 35 and read
" 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): "
read further on page 36 about seafood.
For exporters:
Note that it is possible that in specific EU countries the implementation of a DIRECTIVE
might slightly differ from the directive's exact text. This is because a Directive is a
'guideline' in contrast to a Regulation which is by definition equal in each member state.
=============== END =============
Sincerely
Jan
On 28 Mar 2007 at 20:20, P Howgate wrote:
> 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
>
>
-- JV
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