Illusion to the consumer and fraud on food labels is rampant at the shelf. Compound ingredients and quantity of characteristic elements in recipe (QUID) are sometimes obscure, sometimes misrepresented. An in-depth look at the rules to follow.
Compound ingredients on the label
The list of ingredients-along with the designation of the food – constitutes the true identity card of a food product. It is precisely through this information that the consumer can in fact understand the exact composition of the food and assess its quality. Because each ingredient has its own distinctive value (or disvalue), in economic terms but also in terms of nutrition and health, social and environmental impact. One example out of all, the use of an unsustainable palm oil or a higher-value fat (e.g., hazelnut, sunflower) sharply distinguishes the value of a chocolate spread.
The ABC of the criteria to be followed to compile an ingredient list that complies with legal requirements has already been provided in the
previous article
. We now turn to how to list so-called compound ingredients. That is, those that in turn are composed of multiple ingredients, such as breadcrumbs and potato starch, jam or chocolate.
‘A compound ingredient may appear in the list of ingredients under its designation, to the extent that it is provided for by regulation or fixed by use, in relation to its overall weight, and must be immediately followed by the list of its ingredients.’ (1).
Therefore, it is necessary to identify the multiple ingredient in the ingredient list, on the label, as follows:
(a) Name. Legal (e.g., figjam), where available. Otherwise usual (e.g., margarine), or descriptive (e.g., hazelnut spread),
(b) placement of the compound on the ‘list of Ingredients‘, due to its quantity, according to the general rule of descending order by weight. That is to say, for example, apricot jam used in a tart to the extent of 25 percent (out of the total weight of ingredients) will have to be listed after wheat flour (50 percent) and before butter (20 percent),
(c) composition. The individual components of the multiple ingredient should be given-after its name, in parentheses-in descending order by weight. In the above example, apricot jam (apricots, sugar, gelling agent pectin, acidity corrector citric acid).
QUID, unique value vs. total
‘Anindication of the quantity of an ingredient or category of ingredients used in the manufacture or preparation of a food is required when that ingredient or category of ingredients:
(a) appears in the name of the food or is generally associated with that name by the consumer,
(b) is highlighted in the labeling by words, pictures or a graphic representation, or
(c) it is essential to characterize a food and distinguish it from products with which it might be confused because of its name or appearance.'(2)
The quantity of the ingredient highlighted even graphically, or otherwise characteristic-so-called QUID, ‘Quantitative Ingredient Declaration‘-must be mentioned in the margin of its name. Alternatively, in the food name (e.g., apricot tart 9%) or in ingredient list. And it must be reported as a percentage of the total ingredients put into the product. (3)
‘The indication of the quantity of an ingredient or category of ingredients:
(a) is expressed as a percentage and corresponds to the quantity of the ingredient or ingredients at the time of their use, and
(b) appears in or immediately next to the name of the food, or in the list of ingredients in connection with the ingredient or category of ingredients in question
.’ (4)
On the other hand, it is prohibited, as well as misleading, to refer the QUID to only the amount of the characteristic ingredient in the compound ingredient. The indication must therefore consist of a single percentage figure and not a ‘percentage of the percentage,’ which would force the consumer to perform arithmetic calculations to derive the information he or she is entitled to. This information is essential, among other things, for comparing similar products available on the shelf.
Outlaw QUID, some examples
Numerous labels of sliced processed cheese – as we have repeatedly reported, in the ‘saga’ of the ‘
Cheese scam
‘ (the
cheese fraud
, still unpunished) – are deliberately misleading. And as such, they deserve the attention of ICQRF (Central Inspectorate for Quality Protection and Fraud Repression of Agri-food Products), AGCM (Competition and Market Authority), Public Prosecutor’s Office.
Indeed, the presence of characteristic dairy products (e.g., Emmental, Cheddar, mozzarella) is boasted through verbal and graphic evidence. With the deceptive artifice of referring their percentage share to the compound ingredient, (mixture of) cheeses. However, without reporting the amount in relation to the total of the recipe. The consumer is thus tricked into believing that the processed cheese in question contains a significant amount of the highlighted ingredient (e.g., 60 percent Emmental, in Mondelez’s ‘Mexican’ Sottilettes). Where, on the other hand, as is known only to those in the industry, the total share of cheese in a processed cheese is less than one-third of the total. The 60 percent Emmental object of boasting may therefore correspond to 20 percent of the total in reality.
This deception has been repeated for years on various references of sliced processed cheeses – under Mondelez and Inalpi brands, among others – under the guilty starvation of official public control authorities and the judiciary. While this is clearly true fraud in trade (sale of
aliud pro alio
).
Dario Dongo
Notes
(1) See reg. EU 1169/11, Annex VII, Part E(designation of compound ingredients)
(2) Specification of ingredients is not required in only the 3 cases of:
– Compound ingredients whose composition is defined by EU regulations (e.g., cocoa products, jams and marmalades, fruit juices and nectars), when present in the finished product to an extent of less than 2 percent. Subject to the presence of food additives subject to mandatory indication (i.e., excluding cases of adjuvants and carry-over additives),
– ‘mixtures of spices and/or herbs constituting less than 2 % of the finished product, with the exception of food additives‘ to be indicated,
– compound ingredient not subject to mandatory ingredient list indication (e.g., cheese to which ingredients other than dairy products, food enzymes and microorganism cultures necessary for manufacture have not been added. For the full list, see EU reg. 1169/11, art. 19)
(3) See Regulation (EU) no. 1169/11, Article 22
(4) See reg. EU 1169/11, Annex VIII
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.