The Belgian Food Safety Authority (FAVV/AFSCA) drafted a circular letter clarifying the rules regarding food ingredients which normally are not consumed as a food in itself. The Authority argues the use and labelling of standard food ingredients which perform a technological function is becoming increasingly common with the goal to replace the use of additives. Vinegar powder, vegetal or yeast extract, fermented sugar, fibre and natural aroma are named as examples. The Authority indicates that although these ingredients may appear ‘natural’ they may have been modified intentionally by selection or by chemical means in order to have the same functionality as additives. In that case the perceived naturalness would be misleading. These ingredients, considering their specific technological function in the final product, are likely to fall under the definition of additives and should therefore be considered and treated as such.
Consequently, to be permitted for use in food, the substance needs to be authorized as an additive. If the substance is not specifically authorized it is to be considered a new food additive and needs to follow the authorization procedure to be included in the positive list of permitted additives. The use of non-authorized substances implies the food is not legal under EU food law and therefore considered unsafe for consumption.
The responsibility to comply with the applicable rules lies with the individual food business operator. However, the guidance also emphasizes that the supplier of the given raw material has the responsibility to correctly inform the buyers on the characteristics of the ingredient as well as how to adequately label it.
In Dutch: FAVV - Omzendbrief met betrekking tot ingrediënten die gebruikt worden in een ‘clean label’ context - link
In French: AFSCA - Circulaire relative aux ingrédients « clean label » - link