When it comes to listing ingredients or processing aids derived from a substance or product that may cause allergies or intolerances, the EU regulation to be considered is two-fold.
Article 48a (4) of European Commission’s Delegated Regulation (EU) 2019/33 says that « Without prejudice to Article 41(1) of this Regulation, the terms to be used to indicate the oenological compounds causing allergies or intolerances in the list of ingredients, are laid down in column 1 of Table 2 of Part A of Annex I to Delegated Regulation (EU) 2019/934. » This means that additives and/or processing aids that may cause allergies or intolerances can be indicated, in the list of ingredients, using their specific names as listed in Delegated Regulation 2019/934 (e.g. potassium metabisulphite, ammonium bisulphite, lysozyme, casein…)
This, however, applies without prejudice to Article 41(1) of the same regulation, which says that « For the purposes of indicating certain substances or products causing allergies or intolerances, as referred to in Article 21 of Regulation (EU) No 1169/2011, the terms concerning sulphites/sulfites, eggs and egg-based products and milk and milk-based products that shall be used are those listed in Part A of Annex I. », with Article 21 (1) (a) of Regulation (EU) 1169/2011 stating that “they shall be indicated in the list of ingredients in accordance with the rules laid down in Article 18(1), with a clear reference to the name of the substance or product as listed in Annex II ».
Concretely speaking, this means that all oenological compounds that are derived from a substance or product that may cause allergies or intolerances should be included in the list of ingredients:
- Either by using one of the terms listed under Delegated Regulation (EU) 2019/33, Annex I, Part A
- Or by means of their specific name but accompanied by one of the terms listed under Delegated Regulation (EU) 2019/33, Annex I, Part A, so that there is a clear reference to « sulphites », « egg » or « milk ».
Considering the above, the sulphite-related oenological compounds proposed in the drop-down list of the ingredients’ list editor will now be displayed as follows:
- Potassium bisulphite (sulphites)
- Potassium metabisulphite (sulphites)
- Ammonium bisulphite (sulphites)
The egg-, milk- and wheat-related oenological compounds proposed in the drop-down menus will remain unchanged, as they already include a clear reference to the substance causing potential allergies or intolerances : egg albumin, egg lysozyme, milk casein and wheat protein.
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