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Labelling Exemptions for Carry-Over Additives and Processing Aids: The Requirement of No Technological Effect on the Final Product

Sonja Schulz

Carry-over additives and processing aids are exempted from the mandatory listing as ingredients. In both cases, this exemption requires that the respective substance has no (more) technological effect on the final product. The interpretation of this element of European law shows that such a technological effect is only to be understood as the (lasting) active effect on the final food which is marketed to the consumer. The mere fact that one can tell from the qualities of the final product that a substance with a technological effect has been used is not sufficient. This can in particular be deduced from the decision of the Union legislator itself in the area of organic food. There, the use of certain additives as processing aids has expressly been authorised although (or precisely because) their use leads to a change in the final food. The aforementioned interpretation of the requirement of no technological effect on the final product is in line with the case law of the European Court of Justice.

Sonja Schulz is a Partner at ZENK. For Correspondence: <>


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