Additives potentially derived from GM origins

This Appendix describes those materials that are legally defined as “additives”34
and which will generally be required to be identified on food and feed labels.
The law concerning the definitions of additives and “processing aids” and the labelling
requirements associated with these is complex but is of direct relevance to the
interpretation of some “GM avoidance” policies.
EU legislation defines a ‘food additive’ as:
“any substance not normally consumed as a food in itself and not normally used as
a characteristic ingredient of food whether or not it has nutritive value, the
intentional addition of which to food for a technological purpose in the manufacture,
processing, preparation, treatment, packaging, transport or storage of such food
results, or may be reasonably expected to result, in it or its by-products becoming
directly or indirectly a component of such foods”.
Certain categories of materials are excluded from this definition:
• processing aids35
• flavourings, as defined (Directive 88/388)
• nutrients such as vitamins, minerals and trace elements
• plant protection products.
As with “ingredients” (appendix 1), food labelling legislation grants a few, limited
exemptions from declaration of the presence of additives in food, the principal ones of
relevance to the GM debate being:
• processing aids (as defined)
• substances used to facilitate storage, sale, standardization, dilution or
dissolution of an additive / additives, providing the use is no more than
necessary.
Recent changes to labelling rules, however, over-ride these exemptions and now
require allergenic derivatives of soy to be identified on the label, whatever their
purpose or level in the food, unless they have been granted specific exemption. Thus,
all protein derivatives and products of these will need to be declared but refined oils
and their derivatives, if used in a way that is eligible for the original exemption, will
remain exempt.