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“Wholegrain“ – From a Food Law Perspective

Moritz Hagenmeyer

“Wholegrain” as a technical term is a human invention. Amongst food professionals, wholegrain foods have several connotations – surely the most important quality being their nutritional and health advantages over products made with superfine flour. However, mankind has not yet come up with a legally binding definition of this expression. Hence it is disputed even amongst specialists what type of product may be called “wholegrain”, especially with respect to a recombination of grain constituents. Whilst a European expert consortium has proposed criteria which would suit the industry’s practical purposes as well as consumer demands for healthy food, some German experts argue in favour of a more traditional concept purportedly rooting deeper in nature and more in line with consumer perception. Accordingly the use of the term “wholegrain” would be misleading for the marketing of certain bakery and pastry products for final consumers. A new consumer poll has now discovered current consumer perception regarding “wholegrain” in Germany. Can the results of the poll contribute to resolving the issue whether “wholegrain” may be recombined from different lots or must be produced from an identical lot?


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