Food Grade (Englisch)

The Problem

Flavouring manufacturer customers request increasingly that products they buy have the status “food grade”. A binding definition of the term “food grade” does not exist. The following information can help to interpret the term “food grade”

Back Ground

The US Food Chemicals Codex (FCC) defines the quality of “food grade” chemicals according to their identity, effects and purity on the basis of safety and Good Manufacturing Practice (GMP). The 6th edition (2008) of the FCC lists about 1000 of such chemicals.

In the European legal space there is no binding definition of the term “food grade”. Article 2 of the European Directive (EC) No 178/2002 laying down the general principles and requirements of food law, establishing the European Food Safety Authority and laying down procedures in matters of food safety defines “food” as “any substance or product, whether processed, partially processed or unprocessed, intended to be, or reasonably expected to be ingested by humans”. Food “includes drink, chewing gum and any substance, including water, intentionally incorporated into the food during its manufacture, preparation or treatment”. Thus additives and flavourings come under EC Regulation No 178/2002 and furthermore under the German Food and Feed Code (LFGB).

Food is deemed to be safe if it is considered not to be injurious to health and fit for human consumption (EC Regulation No 178/2002 Article 14 (2)).

Detailed indications are given (Article 14 (3) and (4)) as to which criteria are to be taken into account to consider food as safe and not injurious to health.

Furthermore attention must be drawn o EC Directive (2001/95/EC) on general product safety which defines as “product” any product which “- including in the context of providing a service – is intended for consumers or likely, under reasonably foreseeable conditions, to be used by consumers …” (Article 2 (a)). “A product shall be deemed safe, as far as the aspects covered by the relevant national legislation are concerned, when, …, it conforms to the specific rules of national law of the Member State in whose territory the product is marketed, …, and laying down the health and safety requirements which the product must satisfy in order to be marketed” (Article 3 (2)). Other elements can also be taken into account such as standards, guidelines, product safety codes of good practice (Article 3 (3)).

Conclusions

In conclusion it is to be noted that flavourings can claim the status of “food grade” if the following criteria are met:

• Flavourings must be fit for human consumption.
• According to scientific knowledge flavourings must not be injurious to health and must be safe.
• The intended use (in foods) of flavourings must not represent a health hazard to consumers.
• Flavourings must comply with EC Flavouring Directive 88/388/EEC and the national flavouring regulation.
• Furthermore the general and specific legal provisions on flavourings are to be met such as the German Food and Feed Law, EC Regulation No 178/2002, the German Regulation on the Authorization of Additives, additives purity criteria, maximum contaminants levels and pesticides.
• The principles of Good Manufacturing Practice must be observed.

Last update: 2009-06-18