SGF International e.V.
SGF
Wir sind als leistungsstarker Industrieverband ein Pionier der industriellen Selbstkontrolle und setzen uns im Interesse unserer Mitgliedsunternehmen und der Verbraucher für die Sicherung der gesetzlichen und industriellen Qualitäts- und Sicherheitsstandards und für einen weltweit sicheren und fairen Fruchtsaftmarkt ein.
ID: 289634819603-57
Lobbying Activity
Response to Commission Regulation setting maximum residue levels for chlorate in or on certain products
18 Feb 2019
SGF International e.V. is an industrial association of industrial auto-control for fruit juices, fruit nectars and other products made from fruits and vegetables and fights for safeguarding the compliance with European legal and industrial quality and safety standards and for a safe and fair worldwide market on behalf of our more than 600 members in 60 countries and the consumers. In fulfilling its statutory task, SGF carries out targeted market observations and plant audits at the member production plants in the framework of the Voluntary Control System (VCS) to monitor compliance with the food and labelling regulations.
The intake of chlorate in fruit and vegetable juices is a result of disinfection of the drinking water used during food production to protect human health from the adverse effects of any contamination of water intended for human consumption. According to Council Directive 98/83/EC this includes all water used in any food-production undertaking for the manufacture, processing, preservation or marketing of products or substances intended for human consumption. The following techniques represent the common ways of water chlorination:
• Drinking water disinfection with hypochlorite which is added from a prefabricated sodium hypochlorite solution.
• Drinking water disinfection with onsite chlorine plants where hypochlorite is obtained by electrolysis and added to the water being disinfected.
• Drinking water disinfection using chlorine dioxide; in this case, chlorite is the main byproduct of disinfection. However, if chlorine is added (usual procedure in the chlorine/chlorine dioxide process) at the same time, then chlorite can be oxidised to chlorate.
In order to guarantee drinking water in hygienically impeccable quality, on a worldwide scale it is indispensable in some regions for the drinking water to be treated and disinfected (regardless whether supplied by the local utility company or from the company‘s own well). Some countries outside the European Union even stipulate the need for such disinfection by law.
The procedures described above using hypochlorite or chlorine/chlorine dioxide often constitute the only technically and economically feasible alternative to other potential disinfection methods such as thermal procedures, disinfection with ozone or radiation with UVC (254 nm), particularly for small and medium-sized companies.
In the production of fruit juices water intended for human consumption is used in accordance with Council Directive 2001/112/EC in different stages of processing. Therefore, the intended maximum residue levels of chlorate of 0.02 and 0.03 mg/kg are no realistic limits for processed fruits, especially as up to 0.7 mg chlorate per kg are possible (WHO reference value).
The lawful use of chlorinated drinking water in fruit juice processing shall not lead to final products evaluated as not marketable while being produced according to community law.
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