I nstitute A ffa i rs Nutrition and Flavour Legislation

Lecture presented at the 17th Conference of the Canadian Institute of Food Science an¿ Technology, Montreal, June 10, 1974, by Dr. W. Schlegel, Givaudan Dubendorf Ltd., Zurich, Switzerland.

The consumer cE today acts very suspiciously towards all kind of food additives. Like aH mass phenomena this feeling is not at a1l a logical one; it is rather an emotion. On the other hand Eood technologists and scientists are aware of the fact that satisfactory nutrition for the world's population cannot be attained without food additives. Obviously there is an informa­tion gap which has to be bridged. This bridging cannot be accomplished by food laws alone, it also needs our, the industry's, active contribution.

There are two basic reasons why the consumer behaves as he does:

The consumer is afraid of possible intoxication and he objects to spending his money for something which is not what it pretends to be.

And without doubt he is fuUy entitled to demand that his food is wholesome and safe and to know what he rea1ly gets. It is the objective of the food laws to guarantee safe food and to provide for proper labelling of it.

In view of severe differences between US reguIations and European Eood laws 1 would Iike to cast sorne thoughts along these lines with spedal consideration to f1avours and flavour legislation.

The International Organisation of the Flavour Industry has developed a certain philosophy towards the probIems of safety, labeIling and legislation.

Why Do We Need Flavours? Apart from the fact that flavour and taste-imparting prepara­

tions huye been used fOl" ages in food, there are more reasons indicating that the Flavour Industry wiII contribute considerably to overcome the nutritional problems of the world's population.

Physiologists know that not only fat, carbohydrates, proteins, vitamin~ and trace e1ements are essential constituents of food, but that food must aIso be appealing in taste and be available in a wide variety of textures and flavours in order to be enjoyable and digestible.

Today there exist aIready many food preparations which would not be consumed if no flavour had been added; for example, a1l kinds of deserts, ice cream, soft drinks and sweets. It is very Iikely that this collection wiII become Iarger in the future. As the possibility of stabilizing the growth-rate of our population is extremely remote, we have to look for new, so far untapped, food sources and shall depend on them whether we like it or noto In this context the efforts to utilize soya, alfalfa, groundnuts, oi!, coal, ¡¡Igae and fish for the industrial manufac­ture of human food must be mentioned. Such food preparations wiII be more or less tasteless and it will be the contribution of the Flavour Industry to make them acceptable and enjoyable.

Another aspect is the trend towards industrialized manufac­ture of food. One of the nutritional problems of our day is the distribution of food. But to distribute food, incIuding otherwise perish¡¡ble foodstuffs, requires processing under adequate con di­tions and proper packaging in order to obtain good storage stability. These requirements are, without doubt, responsible for the fact that an increasingly larger share of our food is being manufactured by industrial enterprises. To make food stable against mierobiological, ehemical or physical changes often requires rather drastie conditions, such as heat and rigid mechanicaI treatment.

To expect that natural flavours, as supplied by nature, withstand these drastic 'eonditions and that they aIways keep their flavouring properties over a period of months is eertainly un illusion. Natural flavours have to be properly processed and then stabilized by the addition of suitable additives, such as ¡:ntioxidants, in order to obtain preparations suitable for sorne specific applications. llut many times it is found that better synthetic f1avours may be used, which can be tailor made for a

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Affaires de l'lnstitut large number of applications, for which natural flavours norm­aUy fai! for any reason, might it be a technological, an econo­micaI or another one. The art or creating flavours by mixing a number of volatile chemicals is not new. What is new is that we, nowadays, know much more about the composition of natural f1avours. This knowledge enables the creative flavourist to make flavours more similar to the original than ever befo re and to predict which flavour substances might exhibit an undesirable behaviour in the final food. Since there are hundreds of chemicaIs involved on the flavour side which may possibly interfere with another large amount of chemicals in the food, we still depend on empirical testing. Such extensive tests are preferably under­taken in coUaboration with food manufacturers.

A third reason for the need of f1avours is an economicaJ one. We have recently experienced the fact that large agricultural Jesources have been switched over from peppermint oil to soya cultivation, thus giving rise to an increasing shortage of mint oils. In view of the importance of soya such a swing is very reasonable. Not as drastic is the situation with respect to Italian lemon oi! where we had to cope with a price increase of more than 200% during the last 10 years. The increasing shortage of naturai raw material s will undoubtedly help to improve the acceptance of synthetlC f1avours, which can be manufactured at low cost and which may be more suitable than natural flavours for a large number of applications.

Nutritional, technological and eeonomical considerations demane! that the flavour industry continues its efforts to discover the composition of natural flavours, to study the interactions of flavour and food constituents and to develop more suitable, and hence better flavours for an ever incréasing number oE food preparations.

Safety of Flavouring Chemicals Flavours, Iike foon, are complicated mixtures of chemicals.

For all chemicals Parace)sus's statement is applicable: "SOLA DOSIS F ACIT VENENUM"

(Only ¡he dose makes a poison) It is the Havour industry's firm opinion, that the safety of

flavouring substances - especially of nature-identical synthetic products - has to be looked at in a different manner than that used for other food additives. This belief is based on the follow­ing reasons: ::. Flavouring substances are normally used at levels below

100 ppm - in fact an average level is about 10 ppm in hod - whereas Eeveral other eategories of food additives afe used at levels up to 100,000 ppm (e.g. stabilizers, emul­sifiers, sweeteners, etc.).

2. Sorne food additives are used' beca use of their toxic effect on biological life, for example antimicrobials, fungicides, etc. No f1avouring substance is used for such reasons.

3. NI) other food additive is as self-Iimiting with respect to ¿osage as is a flavouring substance due to its organoleptÍc properties. An euoneous overdosing automatically makes food unpalatable.

4. Flavours are al so added to food to provide variety. There is very liule chance that one and the same flavouring substance will be eonsl\med day after day for years. In other words the risk is once again minimized by the distribution over hlludreds of different substances.

5. Many categories of food additives exhibit chemical structures which ha ve absolutely no relationship to the structure of normany ingested material. Most f1avouring substances are cither "already known" to the human metabolism (nature­identical flavouring substances) or they are homologues of naturaJly occuring products (ethyl vani1lin, ethylma1tol and others). The chemical structures of f1 avouring substances are genera)]y very simple.

6. Fur nature-identical f1avouring substances we possess long tenn experience which must certainly be rated higher than any rat feeding study. vVith respect to natural flavours, such as preparations

ohtaiw r1 eron-¡ e"ible f.~od hv extraction. percoJation. concentra­tion, distillation or similar physical procedures, it is without doubt

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t-hat as long as they are manufactured from food, there are good reason, to assume that such preparations are safe. Sorne doubt has been cast on a few products such as tonka, calamus oi!, sassah-~s oi! and sorne athers. These products are of rather small impmt"nce in relation to the whole group of natural flavours. Of cours~ we must be critical cnough to admit that some of thesc mate:'ials which are used as natural flavours are not exactly derivl:d from edible food, and it .goes without saying that, con­sequcntly, they will no longer be used. Except for those natural prodncts of which we know that there is sorne doubt regarding their safety, the rest of this flavour class can be considered safe on the basis of long term human experience.

\Vhat is true for a mixture of chemicals must logically apply for the single components, provided that they are not consumed in excessively high amounts. From a scientific point of view, there is no reason why natural material should be less toxic than artificial. To the contrary, it was nature which was always man­kind's most important enemy in the early ages. The term "nature­identical" might be a little confusing in this respecto But as soon as Wf define "nature-identical substances" as constituents of traditional food, it is very logical to argue that this c1ass of wbstances can be considered as innocuous. Not to accept this argumentation means doubting the safety of food in general.

This argument is the first and most important point why sorne European food Jaws, the Codex Alimentarius and IOFI clistinguish between nature-identical and artificial flavour sub­stances.

For artificial, that is man-made, flavouring substances which are not known to ba part of human food, long term human experience cannot be c1aimed; their safety must be proved by c1assical methods, for example feeding studies, metabolic studies, etc.

It can be predicted that artificial flavouring substances become less and less important in the future. Flavour research become les s and less important in the future. Flavour research is being more and more directed towards the analytical approach. And in fact, what is more logical than to make synthetic flavours by imitating nature? This trend and the results of our own research efforts lead to another observation: With the dramatic improvement of analytical equipment and methods, flavour re­search is quickly cntering the "ppm" and ppb" range of flavour constituents. It is certainly true, that the quantitywise dominat­ing portions of natural flavours have been identified long ago. ;\Jew discoveries can only be expected in the submicro area. This statement is not a hypothetical one, it can be supported by lookillg at the average use levels of synthetic flavouring sub­stances as published in FEMA'S GRAS list No 3, 4, 5 and 6.

These listings can be considered as being a broad summary of world-wide flavour research activities.

D 'sregarr!;ng the natural flavours and food additives which make part of Iist No 3 and calculating the overal! average maximum level of nature-identical and artificial chemicals in food, as given in the Iists, the fol!owing result is obtained:

Fema List Number of Chemicals Overall Average Maximum Use Level (Ice Cream) (ppm)

No 3 650 10.67 No 4 77 7.92 No 5 35 5.65 No 6 49 (48)" 9.61 (5.64) A trend towards smaller use levels can c1early be established.

This fa.ct is certainly a very important aspect for all those who are actively engaged in food and flavour legislation. " One of the 49 substances listed in GRAS 6 is used at rather

high lcvels, resulting in an unduly large average.

Food LabeIling The need for proper labelling of food is undoubted. Only the

fact lhat different crileria for the labelling prescriptions are ápplied from one country to another, make it difficult to put forward a harmonized proposition. In any case label!ing must never be misleading, it must be informative and it must be honesto Excessive loading of the label with a large number of terms which mean nothing to the layman might be as misleading as no declaration at al!.

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The labelling of added flavours should be restricted to those cases where it becomes necessary in order to avoid deception. This ¡, particularly the case when the addition of flavours to food ipso facto could result in deception.

In conclusion IOFI proposes the following criteria for flavour labelling:

- to use generic terms, such as natural flavour, (nature­identical) flavour or artificial flavour.

- to omit flavour labelling where the added flavour is automatically a part of the food.

- to declare added flavour where the lack of declaration would tend tú deceive because the addition of flavours is not expected by the consumer.

- to always declare the addition of artificial flavouring substances.

Flavour Legislation Since many y8ars IOFI has proposed a differentiation

between nature-identical synthetic and artificial flavouring sub­stances. The exact definition of both terms is given below. This differentiation already exists in the legislation of ITALY and GERMANY and it has be en consistently used by the Codex Alimentarius Committees. IOFI realizes that the splitting of man­made flavouring substances into two categories sounds strange, especial!y for those ears which are ad/justed to the US practice.

It seems necessary to outline again why such a differentia­tion is felt to be practical and justified, beca use we suspect that our proposition was not always correctly understood in the past.

- Nature-identical flavouring substances are identical with the naturally occuring substances, hence they fit into food in a physiological manner. Artificials do noto For practical analytical purposes no distinction can be made between an ad:ded nature-identical substance amI the natural!y occuring product. Artificials can easily be detected. A listing of nature-identical substances will never be complete due to our growing amount of knowledge. The number of these items is not limited. The number of artificials can be limited by regulations. They can easi!y be listed, and their addition to food can be detected and controlled. A last, not unimportant point, which favours the pro­posed distinction between the two classes, is that we should not discourage our research to look deeper into the nature of our food!. If artificials and nature-identical flavouring substances would be equal in the eyes of the law, scientists would hardly be encouraged to further investigate our natural environment.

The flavour industry and IOFI believe that these are very so lid reasons to adopt the difference between the two classes of man-made flavouring substances, a differentiation which facili­tates the regulation of the use of flavours in food as well as the labelling, and last, but not Ieast, the control of such amendments.

IOFI has proposed the fol!owing:

"Suggested Model Flavour Regulation"

"In view of the foregoing, it is appropriate to suggest those key features which lead to an equitable and effective regulation for flavourings. For historical and linguistic reasons, uniform wording seems not appropriate in different countries, but the basic principIes should be universal!y applicable.

Article 1 - Definitions 1. Flavourings are concentrated preparations, with or without

solvents or carriers, used exclusively to impart flavour. They are not intended to be consumed as such.

2. Flavourings may contain the following flavouring ingredients: (a) Aromatic raw materials: vegetable or animal products

used for their fl avouring properties, either as such or processed for human consumption.

(b) Natural flavours : concentrated preparations obtained exclusively by physical methods from aromatic raw materials.

(c) Natural f1avouring substances: substances isolated from aromatic raw materials exclusively by physical method5.

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