2011 compliance with_eu_buyer_requirements_for_natural_thickeners

Compliance with EU
buyer requirements for
natural thickeners
Buyer requirements are all the requirements you can expect from
your EU buyer. They can be divided into two groups: legislative
requirements, which focus on food safety and additional, non-legal
requirements, which focus mainly on social and environmental
conditions.
Legal requirements
Legal requirements are the minimum requirements which must be met by products
marketed in the EU. Products which fail to meet these requirements are not allowed on the
EU market. EU legislation sets the basis for legal requirements in the EU, but there may be
some differences in the implementation into national legislation in the member states.
This information is provided in Table 1. For information on other applicable national
legislation, check the related documents on http://www.cbi.eu/marketinfo.

Food safety is the most important issue for natural thickeners. Food additives must be
authorised in order to be used in the EU. Strict requirements are in place to ensure food
safety for the EU consumer (regulation EC 1331/2008). A good method for ensuring food
safety is HACCP, as further discussed under non-legal requirements.

Table 1 Overview of legal EU requirements for natural thickeners, including
information on how member states have implemented the requirements.

Legislation Source Brief description More information Member state
implementation
Additives, Regulation (EC) The EU has set a list of permitted additives EU legislation: Automatically
enzymes and No 1331/2008 and enzymes and a number of requirements Additives, enzymes applicable in all
flavourings in No 1332/2008 for flavourings and their use in foodstuffs and flavourings in member states
food No 1333/2008 intended for human consumption. food
No 1334/2008
CASE: General Regulation (EC) The EU introduced the European rapid alert EU legislation: Automatically
product safety of 178/2002 system for food (and feed) products (RASFF) Product safety for applicable in all
food products as a tool to exchange information on the food products (cases) member states
enforcement of EU food safety legislation.
Contaminants in Regulation (EC) Within the EU food safety policy, the EU has EU legislation: Automatically
food 1881/2006 set maximum levels for certain contaminants Contaminants in food applicable in all
in specified products or product groups. member states
Extraction Directive In the EU, there are rules for the marketing EU legislation: Automatically
solvents for food 88/344/EEC and use of extraction solvents used in the Extraction solvents applicable in all
production of foodstuffs and food ingredients. for food member states
Food contact Regulation (EC) The European Union has laid down rules for EU legislation: Food Automatically
materials 1935/2004 materials and articles coming into contact with contact materials applicable in all
Directive food (including, for example, packaging) in member states
84/500/EEC order to prevent any unacceptable change in
Directive the composition of the foodstuffs and to
007/42/EEC protect human health.

Source: CBI Market Information Database • URL: www.cbi.eu • Contact: marketinfo@cbi.eu • www.cbi.eu/disclaimer

Compliance with EU buyer requirements for natural thickeners

implementation
Directive 2002/72
EC
Regulation (EC)
282/2008
Regulation (EC)
372/2007
Directive
78/142/EEC
Directive
93/11/EEC
Regulation (EC)
1895/2005
Directive
2008/39/EC
Food control Regulation (EC) All food products entering the EU are subject EU legislation: Food Automatically
882/2004 to official controls to check whether the control applicable in all
Regulation (EC) products are in compliance with the relevant member states
669/2009 food legislation. Some specific products are
subject to an increased level of control.
General food Regulation (EC) Food safety is the key issue in EU food EU legislation: Automatically
law 178/2002 legislation. The General Food Law General food law applicable in all
(Regulation (EC) 178/2002) is the framework member states
regulation in EU food safety legislation. The
legislation also introduces requirements on
traceability.
Hygiene of Regulation (EC) The EU legislation on hygiene of foodstuffs EU legislation: Automatically
foodstuffs 852/2004 (HACCP) is legally binding for food Hygiene of foodstuffs applicable in all
(HACCP) processors, and is recommended for farmers (HACCP) member states
(primary production).
Maximum Regulation (EC) In the EU, legislation has been laid down to EU legislation: Automatically
Residue Levels 396/2005 regulate the presence of pesticide residues Maximum Residue applicable in all
(MRLs) of Regulation (EC) (MRLs) in food products. Levels (MRLs) of member states
pesticides in 178/2006 pesticides in food
food Regulation (EC)
149/2008
Microbiological Regulation (EC) The EU has set microbiological criteria for EU legislation: Automatically
contamination of 2073/2005 food borne micro-organisms, their toxins and Microbiological applicable in all
food metabolites. contamination of member states
food
Nutrition and Regulation (EC) The EU aims to prevent the misleading of EU legislation: Automatically
health claims on 1924/2006 consumers by tying the use of nutrition or Nutrition and health applicable in all
food health claims to certain conditions related to claims on foods member states
nutritional profiles of foods.
Organic Regulation (EC) The EU has established requirements on the EU legislation: Automatically
production and 834/2007 production and labelling requirements with Organic production applicable in all
labelling Regulation (EC) which an organic product of agricultural origin and labelling member states
889/2008 must comply in order to be marketd in the EU
Regulation (EC) as “organic”.
1235/2008
Packaging and Directive EU packaging legislation restricts the use of EU legislation: Automatically
packaging waste 94/62/EC certain heavy metals, among other Packaging and applicable in all
requirements. packaging waste member states
Wood packaging Directive The EU sets requirements for wood EU legislation: Wood Automatically
materials used 2000/29/EC packaging materials (WPM) such as packing packaging materials applicable in all
for transport cases, boxes, crates, drums, pallets, box (transport) member states
(including pallets and dunnage (wood used to wedge
dunnage) and support non-wood cargo).
Germany Order on the In addition to EU restrictions on contaminants Germany legislation: Applicable only in
legislation: maximum in food, Germany has laid down limits for Contaminants in food Germany
Contaminants in permissible certain other contaminants in food, namely
food (additional quantities of mercury, solvents and PCBs.
requirements) contaminants in
foodstuffs of 2003
and its



implementation
amendments

United Kingdom Chloroform in In addition to EU restrictions on contaminants UK legislation: Applicable only in
legislation: Food Regulations in food, the United Kingdom has laid down Contaminants in food the UK
Contaminants in (1980) limits for certain other contaminants in food,
food (additional Arsenic in Food namely copper, arsenic, zinc and chloroform.
requirements) Regulations
(1959)
Report of the
Food Standards
Committee on
Copper (1956)

Organic additives
A food manufacturer, which uses food additives and aims to place an organic label on its
product, has to conform to strict requirements as laid down in EU legislation. Unless all
additives are certified organic, the manufacturer is not allowed to use a label on the
product which claims that the product is 100% organic. In some cases, food manufacturers
are unable to use the organic equivalent of the product they require, because it is simply
not available on the market or cannot be procured, due to insufficient quantities. In those
cases, the EU legislation offers some room. It is permitted to use non-organic additives in
organic products when it is impossible to use organic additives. The ingredient list on the
label should then state how much of the additive is organic (e.g. 98% organic) and the 100%
organic claim cannot be made. However, it also depends on the certifier as to how strictly
the rules are followed. According to industry sources, the certifier IMO (Institute for Market
Ecology - http://www.imo.ch) does not often allow the use of non-organic additives by food
manufacturers. IMO requires clear evidence from food manufacturers when claiming that
they cannot procure an organic equivalent for a certain additive.

The new organic regulation, which came into in force in 2009, introduced several
improvements to the former legislation on the organic market. The EC no longer restricts
organic imports to those from the list of third countries which have organic standards and
a control system officially recognised as equivalent to that of the EU. Since 2009, the EC also
accepts authorisations from inspection bodies approved by the EU in third countries which
are not on this list.

Non-legal requirements
Additional, non-legal requirements reach beyond legislation, as companies can go further
in their requirements than legislation. The main categories of additional requirements are
environmental requirements and social (labour) requirements. For more information on
non-legal requirements, check the related documents on http://www.cbi.eu/marketinfo.

The module ‘Trends and segments’ has shown that EU buyers have significantly increased
their requirements regarding environmentally and socially sustainable production.
Exporters can obtain (one of) several certificates to show EU buyers that they are producing
sustainably. The following certification schemes can be applied to the production of
thickeners: organic, FairWild (http://www.fairwild.org), Fairtrade
(http://www.fairtrade.org.uk), ISO 14001 http://www.iso.org/iso/iso_14000_essentials),
Fair for life (http://www.imo.ch). More information on the former three certification
schemes is available at http://www.cbi.eu/marketinfo.

HACCP – ensuring food safety
A good method for ensuring food safety is HACCP (Hazard Analysis Critical Control Point),
which is an internationally recognised methodology to assure food safety. The



methodology focuses on critical points in your production process, where problems could
occur, with the aim of preventing problems. Several food safety management systems, such
as ISO 22000, BRC, IFS and GlobalGAP, are based on HACCP. Exporters can obtain (one of)
the corresponding certificates in order to show buyers that they are committed to food
safety. More information on the food management systems is available at
http://www.cbi.eu/marketinfo. The text box below shows a recent example of how
important it is to have adequate safety control systems in place. It could affect export
possibilities for an entire country if some shipments to the EU were regarded as unsafe for
human consumption.

Quality and safety: restrictions on guar gum supplies from India
Because the risk of dioxin contamination of guar gum imported from India remains
too high according to the EU, imports from this country are restricted under EU
Regulation 258/2010, which came into force in April last year. The EC inspection
found that the quality and safety control was inadequate. Under the new regulation:
- A health certificate is necessary, showing that the guar gum does not
contain more than 0.01 mg/kg pentachlorophenol (PCP)
- An analytical report from an accredited Indian laboratory is necessary
- Ports (and other entry points) need to be notified in advance about when
the shipment will arrive
- 5% of the shipments will be checked randomly. The food business
operators shall pay for the costs
- Customs authorities need to be provided with evidence that official
controls have taken place, and that the shipment is safe
Regulation 258/2010: http://eur-
lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:080:0028:0031:EN:PDF

Quality standards
Although the EU has not specified quality standards for individual thickeners, exporters can
benchmark their product quality against the standards of the Joint FAO/WHO Expert
Committee on Food Additives (JECFA). The JECFA sets standards for various thickeners,
which are also applied in the EU. The standards documents are available from
http://www.fao.org/ag/agn/jecfa-additives/search.html?lang=en.

This survey was compiled for CBI by ProFound – Advisers In Development

Disclaimer CBI market information tools: http://www.cbi.eu/disclaimer


2011 compliance with_eu_buyer_requirements_for_natural_thickeners

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