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Federation of European manufacturers and suppliers of ingredients to the Bakery, Patisserie and Confectionery Industries

Fedima

Fedima is the European federation of manufacturers and suppliers of ingredients to the bakery, confectionery and patisserie industries.

Lobbying Activity

Response to Commission Reg. (EU) on the application of control & mitigation measures to reduce the presence of acrylamide in food

7 Jul 2017

Fedima, the Federation of European Union Manufacturers and Suppliers of Ingredients to the Bakery, Confectionary and Patisserie Industries, welcomes the opportunity to provide input to the draft Commission Regulation and is committed to mitigate acrylamide levels in bakery goods. A challenge for the ingredient manufacturer is that any measurements of acrylamide and/or precursors detected in raw materials do not provide an accurate prediction of acrylamide levels in the finished product. Moreover, the fact that variations in acrylamide levels as a result of the baking process itself can outweigh any contribution from specific ingredients. In addition, Fedima would like to provide the following comments for consideration: • Fedima is concerned that the proposed mitigation measures are setting a strict enforcement on business operators. Stated as is, these measures form important restrictions for food production and do not leave enough flexibility to reach mitigation targets for acrylamide. The provisions are deemed extremely prescriptive in the sense that they do not include elements such as ‘where recipe permits’ or ‘without affecting quality or organoleptic characteristics’. Furthermore, room should be left for innovative ways to reduce acrylamide levels. •Of particular importance to our sector are sections III and X of Annex I. Fedima is aware of the large impact these proposed measures will have on our members and customers for the following reasons: -Recipe measures (e.g. replacing fructose, rye and wholemeal flour or sourdough) will have a major impact on the bakery chain and consumer products. -Agronomical measures: difficult to enforce and are scientifically insufficiently proven to be effective; excessively strict measures can endanger supply of raw materials -Avoidance of double heat treatment of ingredients like nuts and malt flours (see section III): it is not scientifically substantiated that this process promotes the production of acrylamide. -Risk assessment on the role of ingredients in acrylamide formation assumes that all the pathways are known, which is not the case. This requires further scientific studies. -Processing has the largest impact on acrylamide formation and is thus the best approach to mitigate acrylamide formation. Ultimately any changes in selection and processing of ingredients could compromise product quality, organoleptic characteristics and consumer expectation. It could also significantly impact the nutritional quality of the product and therefore must be taken into consideration when implementing measures to reduce acrylamide. Health benefits of wholegrain or rye bread varieties could potentially be lost when they are excluded from human consumption. •The product category ‘soft bread’ (Annex IV) is deemed too vague. A definition or cut-off level is needed for ‘soft bread other than wheat based bread’. Further, we consider this category and the unique level of 100 microgram/kg too generic and not adequate for other kinds of bread other than wheat based bread. In addition, Fedima members question the proposed reduction of benchmark levels and request scientific justification for such reduction. •We stress the need to develop accurate acrylamide determination methods. The proposed benchmark levels are approaching the detection limits. Foods with a considerable daily intake (like bread) and foods with acrylamide levels on/below the detection limits, risk being unjustly classified to contribute significantly to acrylamide intake. Fedima strongly supports the mitigation of acrylamide formation and recommends that operators are free to choose the appropriate and most effective measures indicated in the consultation and in the FDE Acrylamide Toolbox, without compromising the quality and availability of consumer products.We believe that, provided our comments on the consultation and the ones of FDE are taken into account, we can create the procedure to mitigate acrylamide.
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Response to Use of sweeteners in food category 07.2 fine bakery wares

26 Jun 2017

Fedima, the Federation of European Union Manufacturers and Suppliers of Ingredients to the Bakery, Confectionary and Patisserie Industries, welcomes the opportunity to provide input to the draft Commission regulation (EU) amending Annex II to Regulation (EC) No 1333/2008 as regards the use of sweeteners in fine bakery wares. Fedima would like to provide the following comments for consideration: Reformulation of processed and prepared foods with the aim of reducing their sugar content has become a key element for industry to improve healthy eating and help consumers through increased availability of healthier food choices. Indeed, industry committed itself to reformulation as part of the actions associated with the EU Platform for Action on Diet, Physical Activity and Health. More recently, the Roadmap for Action on Food Product Improvement was widely endorsed by European Member States, food business operators and NGOs. Following the example of fats, industry is now responding to the need to decrease the amount of added sugar in product formulations, where feasible. Even though many good-tasting, low-calorie products are already available, consumers would benefit from having additional low-calorie products available. Of particular interest are baked goods. Intense sweeteners, together with low-calorie bulk ingredients, are bringing innovative solutions to allow significant reduction of the amount of sugars used in the formulation of fine bakery wares while balancing the taste profile of these products. However, the use of sweeteners is currently not permitted in fine bakery wares in the EU. In the remit of Reg.(EC)1333/2008 there is currently no authorisation for use of sweeteners in food category 7.2 with the exception of sweeteners in ‘fine bakery products for special nutritional uses’. With the abolishment of the concept of ‘foodstuffs for particular nutritional uses’, this exception is no longer justified, as stated in the draft Commission regulation, resulting in the situation that the category 7.2 will no longer allow any more intense sweeteners. Fedima notes the consequence that fine bakery wares with these substances will no longer be marketed, and therefore suggests these additives should be allowed for use in ‘fine bakery products’ in accordance with article 7 Specific conditions for sweeteners of Reg.(EC)1333/2008. Furthermore, in relation to Reg.(EC) 1924/2006, the deletion of these additives will impede the possibility of developing fine bakery wares with nutritional improvements. Fedima members would like to maintain the possibility to provide solutions to their customers, which will allow consumers to eat fine bakery wares that are adapted to their needs and expectations, while still contributing to the reduction of sugar consumption in Europe. The use of intense sweeteners at the adequate level is a major tool for fulfilling the conditions set in the abovementioned regulation to communicate on sugar reduction through nutrition claims. We refer to the comments submitted to this public consultation by CAOBISCO, the European Association of Chocolate, Biscuit and Confectionery Industries. Fedima supports CAOBISCO’s work in preparing an application for the use of sweeteners in fine bakery wares and notes a dossier will be presented to the European Commission by end of 2017. Fedima will also propose uses of sweeteners in fine bakery wares ‘with reduced sugars’ without energy increase. In conclusion, Fedima is strongly convinced of the importance to maintain the authorisation of these sweeteners in food category 7.2 fine bakery wares. Moreover, in view of the European policies on healthy nutrition, the use of sweeteners in fine bakery wares may be one of the crucial tools for contributing to this goal, while allowing consumers to make an informed choice based on their dietary needs. Fedima’s complete comments can be found in attachment. Thank you in advance for your consideration.
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