The specification for Grana Padano PDO-unlike that of Parmigiano Reggiano PDO (1,2)-allows ‘the use of lysozyme, except for Trentingrana, up to a maximum of 2.5 g per 100 kg of product‘ (3).
Lysozyme-in use for several decades, to combat Clostridium spp. bacteria and other microbiological contamination-has always been indicated as a preservative, in cheeses where its use is permitted.
The word ‘preservative’ has been excluded, however, from the labels of Grana Padano PDO only. Following a Ministry of Health circular appealed to the Lazio Regional Administrative Court in summer 2018. Still awaiting decisions.
Lysozyme in Grana Padano, preservative or technological aid?
The Ministry of Health – by circular 8.5.18, signed by the then DG for Hygiene and Food Safety Gaetana Ferri – had given a favorable opinion to the Consortium’s request to reclassify lysozyme, ‘From preservative additive to adjuvant/technological aid, in Grana Padano PDO cheese with a maturation period of nine months or more‘. (4)
Thus, the Grana Padano PDO Consortium ordered its members-in circular 14.9.18 no. 92, signed by its DG Stefano Berni – that ‘the word CONSERVATIVE’ shall disappear, once stocks are exhausted,from every label and informational material (e.g. leaflets, brochures) about Italian cheese as well as the world’s best-selling PDO. (5)
Grana Padano, with or without ‘preservative’?
Director General Stefano Berni’s circular to members of the Grana Padano PDO Consortium-after the diktat to remove ‘the word CONSERVATIVE’, however-weakened the message, almost as if to foretell possible challenges.
‘In case of objections outside Italy about the removal of the wording “preservative,” the Ministry has assured us that it will defend this position.
At the same time, it is urged not to emphasize in publications (flyers, brochures, web, etc.) the absence of the preservative, merely removing the word’.
Preservative and adjuvant, what differences?
Reg. EC 1333/08 on food additives – laying down uniform rules to apply, in its identical text, in all EU member states (6) – provides the following definitions:
“food additive.” ‘Any substance not customarily consumed as a food in itself and not used as a characteristic ingredient of food, with or without nutritional value, the intentional addition of which to food for a technological purpose in the manufacture, processing, preparation, treatment, packaging, transportation, or storage thereof has or may be expected to have the effect that the substance or its by-products become, directly or indirectly, components of such food. (…)’ (Article 3.2.a),
“technology adjuvant.” ‘Any substance that:
(i) It is not consumed as a food in itself,
(ii) is intentionally used in the processing of raw materials, foodstuffs or their ingredients, to perform a certain technological function in processing or transformation; and
(iii) may result in the unintentional but technically unavoidable presence of residues of that substance or its derivatives in the finished product, provided that these residues do not pose a health risk and have no technological effects on the finished product‘ (Article 3.2.b).
Additive or adjuvant, who decides?
The decision about ‘whether a particular substance meets the definition of a food additive in Article 3‘ rests with the European Commission, in consultation with the member states’ representations to thePlants, Animals, Food and Feed (PAFF) Committee. (7)
The so-called regulatory procedure-explicitly established by reg. EC 1333/08 in case of doubts about the qualification of a substance as an additive (or adjuvant) – excludes any autonomous decision-making power of member states. For the specific purpose of preventing obstacles to the free movement of goods in the internal market (Treaty for the Functioning of the European Union, TFEU, Article 28).
Appeal to Lazio Regional Administrative Court on lysozyme in Grana Padano cheese.
On 11.9.18, the Parmigiano Reggiano DOP Consortium filed an appeal with the Lazio Regional Administrative Court (TAR) to annul the circular Min. Sal. 8.5.18(Lysozyme in Grana Padano cheese). As well as an unknown opinion of the Superior Health Council, deduced by the ministry in support of its own circular. (8) And of a jaw-dropping 20.7.18 memo in which the health administration denied the Consortium access to the records of the proceedings, with good grace to the then 28-year-old Bassanini law.
In law, the plaintiff alleged violation of European regulations in the field (EC Reg. 1331/08 and 1333/08, EU Reg. 1129/11), pointing out the lack of competence of the Ministry of Health to comment on an interpretation of European regulations that is instead subject to a special EU procedure, as seen in the preceding paragraph. As well as challenging the refusal of access to the records to the Parmigiano Reggiano PDO Consortium, whose legitimate interest in knowing them is self-evident. (9)
Lysozyme, why is it found in Grana Padano, Provolone and Asiago, but not in Parmigiano Reggiano?
The milk used to produce Parmigiano Reggiano PDO comes from cows fed exclusively on fresh fodder and hay. In contrast, other PDO cheeses-such as Grana Padano and Provolone, Asiago and Montasio-allow the use of milk from cows fed the more practical and economical silage. Irreplaceable to farmers forced to supply milk at prices close to production costs. (9) Silage is fodder stored in silos (e.g., silomais) in an acidic environment where ‘good’ microorganisms (lactobacilli) as well as ‘undesirable’ ones (clostridia) ferment.
Undesirable microorganisms (or ‘anticasears’) once passed into the milk, and cause gasogenic fermentation of the cheese during aging. Thus the structure of the dough is altered, unpleasant aromas and odors are formed, until the rind breaks and the possible bursting of the mold. Lysozyme is then added to stop clostridia in the milk of animals fed silage. It took the place of formic aldehyde, a potent antiseptic that, however, proved to be a potential carcinogen and was banned in 1991. (10)
Lysozyme, merits and demerits
‘It is one of the few substances of animal origin with antibiotic activity; its action is to attack the wall of bacteria making them more vulnerable and limiting their ability to develop.’ (11)
Lysozyme is a linear polypeptide consisting of 129 amino acids, obtained from chicken egg white. It is effective in exterminating ‘anti-caseous’ bacteria, but:
– nullifies the microbial heritage that characterizes raw-milk cheeses and contributes, among other things, to strengthening the microbiota (thus also the immune system),
– impairs the consumption of cheese by consumers with egg allergy, which is among the most frequent in the European population.
‘Recent results (Marseglia et al. 2013), indicate that intake of lysozyme-containing cheese, at 12 months of maturation, created in 5 out of 21 lysozyme-sensitive children, immediate and late adverse reactions such as itching, abdominal pain, vomiting, nausea, dermatitis, rhinitis, bronchial asthma, and urticaria’ (12,13).
What connection with the territory?
‘The introduction of silage forage represented an innovative fact of extraordinary magnitude and introduced an enormous problem in the production of grana cheese never before known by destroying an old link with the territory, indeed by establishing a strong negative link with it, so today to want to make believe that there is a good link is amateurish fantasy or a desire to pursue the ridiculous
Today it is used, for example in zone A (silage), the additive lysozyme because the milk is too polluted with spores of the genus Clostriduim…. can it be said to be according to tradition and to be within the scope of fair and consistent uses?… What is the PDO product?… Can a cheese produced with an additive be recognized as such?‘ (14)
Lysozyme in Grana, can it be avoided?
Prof. Gianfranco Piva coordinated researchers from the Catholic Universities of Piacenza and Cremona, Milan and Parma, in the research project ‘Improvement of Grana Padano PDO cheese: production trials without lysozyme (GP-Lfree)‘. Where over the course of three years, the possibility of producing Grana Padano without lysozyme was demonstrated, in compliance with the specification.
‘Everyone in the supply chain needs to become aware that the application of certain tricks, even relatively simple ones, makes it possible to decisively improve the quality of cheese production and achieve lysozyme-free production.’ (13)
Areas for improvement were therefore defined at each stage. Crops and forage storage techniques, facilities, housing, diet feeding techniques, individual milk production, milking methods, hygienic interventions in pre- and post-milking, silage-drying temperatures, and diet feeding via
unifeed
, farm hygiene and milking.
Strategic opportunities
The above research project emphasizes the reasons for eliminating lysozyme in cheese production:
‘(a) an ‘absolute’ health guarantee to all consumers, including those of pediatric age sensitive to food allergies to egg proteins,
(b) added value to the image of the product, which will no longer have to declare the presence of lysozyme on the label,
(c) a return to the Grana Padano of its origins, produced using only milk, rennet and salt, without any other added substances.’ (13)
Interim conclusions
The Coldiretto Consortium of Grana Padano PDO has played its cards on an ad hoc ministerial exemption. With the purely cosmetic goal of erasing the word ‘preservative’ from labels, before the words ‘lysozyme from EGGS’. (15)
While waiting for the Lazio Regional Administrative Court to rule on an incontrovertible question of law (albeit set forth in a somewhat sluggish appeal), the social partners involved-including consumer associations-should take action at the EU level.
This Italic anomaly, moreover, underlies a far more serious one. The inability to manage a supply chain policy that can remunerate farmers’ investments to improve the product, as some already do excellently. (16) Eliminate rather than hide the preservative.
Dario Dongo
Notes
(1) Parmigiano Reggiano DOP. Production Specification. https://www.parmigianoreggiano.com/static/118c3adbbfba7f61f536bb418a820af4/c40fd4e7eff4f555239d98c418a9f918.pdf
(2) Dario Dongo, Sílvia Giordanengo. Parmigiano Reggiano, new specifications for the king of raw milk cheeses. GIFT(Great Italian Food Trade). 8.2.21, https://www.greatitalianfoodtrade.it/etichette/parmigiano-reggiano-nuovo-disciplinare-per-il-re-dei-formaggi-a-latte-crudo
(3) Grana Padano PDO. Production Specifications. https://www.granapadano.it/public/file/Disciplinare-produzione-Grana-PadanoDOPNov19-38346.pdf NB: The TrentinGrana supply chain does not allow the feeding of silage to cows or the use of lysozyme in cheesemaking
(4) See also Min.Sal. National Food Safety Committee, opinion 17.7.08 no. 1. Lysozyme in Grana Padano. https://bit.ly/3wlGJfA
(5) Dario Dongo. Grana Padano DOP, the growth of the global leader continues. GIFT(Great Italian Food Trade). 5.9.19, https://www.greatitalianfoodtrade.it/mercati/grana-padano-dop-prosegue-la-crescita-del-leader-globale
(6) Reg. EC 1333/08, on food additives. Consolidated text as of 12/23/20 at https://eur-lex.europa.eu/legal-content/IT/TXT/?qid=1625419711171&uri=CELEX%3A32008R1333
(7) Reg. EC 1333/08. Article 19, Interpretation Decisions, paragraph 1, subparagraph ‘c’
(8) The Superior Health Council (HSC), it should be remembered, is a body that assists Min.Sal. In assessing the risks associated with food or other consumer products. His opinions have no legal value
(9) Dario Dongo. Geographical indications, 75 billion euros in EU. The database and the protections that are missing. GIFT (Great Italian Food Trade). 21.2.21, https://www.greatitalianfoodtrade.it/mercati/indicazioni-geografiche-75-miliardi-di-euro-in-ue-il-database-e-le-tutele-che-mancano
(10) Augustine Macrí. The ‘Grana’ of lysozyme. Food Safety, National Consumers Union blog. 9.1.19, https://www.sicurezzalimentare.it/carni/la-grana-del-lisozima/
(11) Modena USL Company. Lysozyme: preservative, processing aid or additive? Food & Health. 5/13/19, https://www.alimenti-salute.it/rassegna-stampa/lisozima-conservante-coadiuvante-tecnologico-o-additivo
(12) Symptoms appeared when the IgE level exceeded 7 kU/L. With aging at 24 months, probably due to the increased proteolysis, only 1 in 21 children showed an adverse reaction. Excerpt from report in later note 13
(13) ERSAF (Ente Regionale per i Servizi all’Agricoltura e le Foreste), Lombardy Region (2015). Improvement of Grana Padano PDO cheese, production trials without lysozyme. Research report. https://www.ersaf.lombardia.it/it/attachments/file/view?hash=bf45af46f9f51a2e0ed824700d984623&canCache=0
(14) Bottazzi V. (1998). Grana Padano:tradition or innovation? The Agricultural Informant. 1998, 40, 27-29
(15) In both cases of classification as a preservative or processing aid, the name of the substance lysozyme and the egg allergen must still come up on the label (EU reg. 1169/11, Article 9.1.c)
(16) Dario Dongo. Latteria San Pietro, Grana Padano ‘Hay Selection’ in a digital experience. GIFT (Great Italian Food Trade). 11.6.20, https://www.greatitalianfoodtrade.it/innovazione/latteria-san-pietro-il-grana-padano-selezione-da-fieno-in-un-esperienza-digitale
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
