Better Training for Safer Food

Initiative

Marta Dmitruk

Smoke flavourings legislation

Traceability
BTSF
A4.07

2019
Food safety

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 Content
• The UE legislation applicable to smoke flavourings
• General and specific provisions on the labelling of smoke
flavourings
• The union list of smoke flavourings (example of a primary
product and the notes 1-4)
• Specific control points to take care of during an audit with
• Producers of smoke flavourings
• Users of smoke flavourings or premixes of smoke
flavourings in food production
• Importers (and retailers) of smoke flavourings and
premixes of smoke flavourings
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 UE legislation applicable to smoke flavourings
• Regulation (EC) 1334/2008 • Regulation (EC) 2065/2003 on
on flavourings smoke flavourings
• General requirements for Specific autorisation procedure :
• flavourings responsabilities of MS, Cion, EFSA and
• Definition of different types of FBO (new, reapproval, modifications)
flavourings, also smoke flavourings Content of application
• General composition of flavourings Condition of production, incl raw material
(general safety, may contain food Certain purity criteria
additives annex III of (EC) Possibility to adapt criteria for analysis
n°2008/1333) MS responsability : inspections
• General labelling of flavourings Specific traceability requirements
• Monitoring of flavourings MS Establishment of the list
• Reporting use of flavourings FBO
Regulation (EC) Regulation (EU)
627/2006 on 1321/2013 on the
criteria for analytical Union list of 2
methods and sampling primary products
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 General provisions on labelling applicable to
smoke flavourings
• Labelling B to B (Art 14,15 The net quantity;
1334/2008) : A date of minimum durability or use-by-
• The sales description date
• Statement specifically « for food » Allergen labelling
flavourings, also smoke flavourings For consumer (Art 17)
• Special conditions for storage and Statement either « for food » or
use restricted use in food
• Mark identifying the batch or lot FIC Regulation (EC) n°1169/2011
• In descending order of weight : the General requirements apply
categories of flavourings present and Specific : labelling of smoke flafourings in
the name of each of the other the list of ingredients (annex III)
substances or materials in the
product or, where appropriate, their
E-number;
« Smoke flavourings » or
• The name of the manufacturer,
« Smoke flavourings from…
packager or seller
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Smoke flavourings can not be
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labelled « natural »

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 Specific provisions on labelling applicable to
smoke flavourings

• In addition to the general provisions for labelling of

flavourings (EC) n° 1334/2008 and (EC) n° 1169/2011, the
following specific information must be transmitted (art 13) :

• The Unique code of the authorised product as given in the

list (ex SF-001)
• The conditions of use of the authorised product as set out in
the list
• In the case of a derived smoke flavouring, the quantitative
relation to the primary product

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 The Union list of smoke flavourings (example)
(EU) n°1321/2013

Primary product SF-001 Conditions of use g/kg

Name of the product Scansmoke PB 1110 1.7 Cheese 2,0
Name of the AZELIS Denmark A/S
autorisation holder 3 Edible ice 0,005
Address of the Lunghoftvej 95 9800 …
autorisation holder Lungby Denmark
Description and characterization …

Source material 90% beech (Fagus 14.1 Non alcoholic 0,2

sylvatica), 10% oak beverages
(Quercus alba)
14.2 Alcoholic 0,2
Specification pH, water, acid, beverages
carbonyls…etc.
15 Snacks.. 2,0
Purity criteria Ld, Ar, Cd, Hg

Notes 1-4 5

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 The Union list of smoke flavourings (note 1-4)

1 Maximum levels refer to levels in or on food as marketed. If primary products

are used for the production of the derived smoke flavourings, the maximum
levels shall be adjusted accordingly
2 When combinations of smoke flavourings are used in or on foodstuffs, the
individual levels shall be reduced proportionally
3 Fish and meat may be smoked with regenerated smoke in accordance with
good manufacturing practices
4 The presence of a smoke flavouring shall be permitted :

(a) In a compound food other than as referred to the annex, where the
primary product is permitted in one of the ingredients of the compound food
(b) In a food wich is to be used solely in the preparation of a compoud food
and provided that the compound food complies with the Regulation
This shall not apply to infant foods and foods for young children
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 DG Health and Food Safety missions findings
related to SF
Non-compliancies noted by the inspectors during the audit where the specification
of a premix which do not mention the added smoke flavouring

CA did not identify in one case that the technical information available for the
smoke flavouring derived from a primary product approved by regulation (EU)
1321/2013 did not include the quantitative relationship between the primary
product and the derivative concentrations as required bu article 13 of Regulation
(EC) n°2065/2003.

For one meat product verified, the FBO could not provide information on the type
of smoke flavouring in the additive mixture used

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 Case study of controls in producers of smoked
food or food with smoky flavour
Proposed approach : Target specific controls at meat and fish producers of ham, lard,
sausage, bacon, Knack, salmon, herring, trout……

I-Check consistancy of method of smoking with the sale name of the final
product and the ingredient list :
If a smoke flavouring is added in the mass : sales name with mention related to smoky
flavour and ingredient list with smoke flavouring

II-check compliance of the composition and self contrôles :

Avaibility of informations on the type of smoke flavouring and the quantitative
relationship between the primary product and the derivative concentrations
Primary product is allowed in the food and the maximum amounts are respected
Self controls in case of regenerated smoke

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 Specific control points to take care of during an
audit with a producer and/or « mixer »
• The quality of the raw material for the production of the primary products fulfills
requirements ( Reg. 2056/2003 art 5)
• Production process meets the requirements (Reg. 2056/2003 art 5)
• Use of food additives and solvents in conformity with EU legislation
• Primary products fulfills the purity requirements ( annex I 2056/2003 and
annex I 1321/2013)
• Producer has analytical results to show and procedures to follow (sampling
etc.) of the primary product (quality, purity check, own check)
• The producer can confirm the amounts in the premix (analytical results and
recipe count of premix is available)
• General and specific labelling requirements B to B or for consumer market
• Primary product is allowed in the food for with it is marketed and in amounts
calculated for use according to food groups 9

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 Specific control points to take care of during an
audit with a user
• Primary product is allowed in the food and the maximum amounts are
respected (1321/2013, notes 1,2,4)
• Good manufacturing practices (particularly with regenerated smoke)
• The FBO can confirm the amounts in the food according to food recipe (own
check is available)
• Premixes used are accurately labelled and understood (own check)
• Supplier (producer, importer, retailer) has provided information on
concentrations so that maximum amounts can to respected, and on purity of
the substance specificate; if not :
• The user has requested the supplier to provide information on
concentrations so that maximum amounts can be respected
• The use has requested information on purity
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 Specific control points to take care of during an
audit with an importer/retailer
• General and specific labelling requirements B to B or for consumer market
• Primary product is allowed in the food for which it is marketed and in amounts
calculated for use according to food groups
• The importer/retailer can confirm the amounts in the premix (analytical results
from the producer and recipe count of premix is available), if not :
• The importer has requested the producer information on content so that
maximum amounts can be respected.

• The importer/retailer can confirm purity of primary product and quality of

premix (analytical results from the producer); if not :
• The importer/retailer has request information on purity

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 Questions

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 Question
During an audit with a mixer of primary products, which of these
two control points do not need to be taken into account?

A) The conformity of quality and raw material used for producing the
primary product
B) Documentation of the purity criteria as set out in the union list for the
specific primary product in question
C) Indication of the levels of primary product in relation to the food
groups in which the smoke flavouring is allowed
D) The list of ingredients : « smoke flavouring », or « smoke flavouring
producted from »

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 Thank you for your attention

AETS Consortium

Address : 17 av. André Marie Ampère, 64 140 Lons, France

Tel/fax: +33 5 59 72 43 23 / + 33 5 59 72 43 24
Email: contact@aets-consultants.com

Better Training for Safer Food

BTSF
• European Commission
Consumers, Health and Food Executive Agency
DRB A3/042
L-2920 Luxembourg

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