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Cross-Linked Regulatory Assessment for Sub-Ingredient and Sub-Additive Management

A Harmonized Decision-Tree Aimed at Food Industry Stakeholders and Proposal for an EU Guideline

Alessio Latino, Valentina Novelli

Food ingredients can be extremely different when flavourings, food additives, vitamins, minerals, standard food or other food ingredients are taken into consideration. More and more often, in-depth checking of raw materials technical data sheets become necessary to understand if a sub-ingredient or a sub-additive might be considered as a carrier; this evaluation is crucial when assessing whether to declare the above-mentioned substances on a label. In this regard, a structured critical approach is of major importance for food manufacturers, supporting them in avoiding non-compliances of the finished product. The aim of the present study is to propose an integrated decision-tree based on European legislation to manage the declaration of sub-additives and sub-ingredients, intended as any substance used as support for additives, flavourings and other ingredients. Additionally, this work is meant also to bring forward the proposal for EU policymakers, suggesting an official implementation.

The authors work in the Group Regulatory Affairs at Perfetti Van Melle S.p.A., Lainate (MI), Italy.


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