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Most people look at an ingredient listing on a food label and don’t pay a lot of attention to it. Many don’t understand that all those ingredients are listed from biggest to smallest, those random % are very precisely placed, and that not all ingredients need to be listed.

The FSANZ Food Standards Code is very prescriptive on how you must construct an ingredients list. Standard 1.2.4 – Information requirements – Statement of Ingredients lists most of the general rules, but simply understanding this section of the code will not be enough to get you through most ingredient listings without the risk of mistake.

Food startups don’t realise how tricky this is and approach us after making costly mistakes, and end up having to pay more to get them fixed up. Below we have listed the five mistakes we consistently see

Using e numbers

Most people are familiar with e numbers, the codes used for food additives, and in the day and age of smartphones, we can all figure out what they mean quickly and easily.

The problem here is that in New Zealand and Australia, FSANZ doesn’t recognise e-numbers.

Confused? Let me explain.

Here’s what Wikipedia has to say about E-numbers…

“E numbers (“E” stands for “Europe”) are codes for substances used as food additives for use within the European Union (EU) and European Free Trade Association (EFTA). Commonly found on food labels, their safety assessment and approval are the responsibility of the European Food Safety Authority (EFSA).

“Having a single unified list for food additives was first agreed upon in 1962 with food colouring. In 1964, the directives for preservatives were added, 1970 for antioxidants and 1974 for the emulsifiers, stabilisers, thickeners and gelling agents.”

So, we don’t have e numbers because the E stands for Europe. We just have numbers. In the European Union citric acid is e330. In New Zealand, its just 330, or more precisely, Acidity Regulator (330). Some labels will state Food Acid (330) – this is also incorrect. The Food Standards Code does not define Food Acids, only Acidity Regulators which may also include the conjugate bases of acids, such as sodium citrate.

As far as I know, the numbers that are used by FSANZ and the EU are exactly the same. There are a few subtle differences between approvals though. For instance, magnesium citrate may be allowed for use in other countries, but not here in New Zealand.

So, if you see an e number like e201, a mistake has been made.

Using Additive Numbers Incorrectly

Additives have a fair few rules associated with their use, so care needs to be taken when labelling them. The ingredient’s function must first be stated, followed by the name or number. For instance, if sodium benzoate is being used as a preservative, the following statement is correct:

Preservative (Sodium Benzoate) or Preservative (211).

You cannot state that Sodium Benzoate is in there without identifying it as a preservative. Why? Some companies aren’t all that honest.

For example, I have seen one company state “all our products are preservative free” in their marketing collateral, and in the ingredient listings, both sodium benzoate and potassium sorbate were present without “preservative” stated. A lot of people don’t recognise these two chemicals as preservative, but it is hard to ignore when it is listed as Preservative (211)

Not Applying Characterising Ingredient Rules

It’s easiest to explain characterising ingredients by using an example.

Below we have an ingredient listing for a Mince and Cheese Pie. The mince and the cheese are the stars of the show here (the characterising ingredients), so you need to tell the consumer exactly how much mince, and how much cheese they are getting. In the listing below, both ingredients have a % value.

Water, Flour (Wheat, Soy, Rice), Minced Meat (15%) (Beef, Mutton), Animal Fats/Oils, Vegetable Fats/Oils, Cheese (5%) (Milk), Salt, Emulsifiers (Soy Lecithin, 331, 451, 471, 481), Maize Starch, Onion, Soy Protein, Flavour (Lactose, Flavour Enhancers (621, 635), Soy, Wheat, Barley, Yeast Extract), Colour (100, 150c, 160a), Acidity Regulators (263, 270, 330), Stabilisers (415, 466), Antioxidant (320)

Sometimes it can be difficult to determine the % values. In this example, consider this pie. The mince may be fried, then stewed, and both of these processes will result in a percentage water loss (or gain), and potentially a fat/oil % change. It is then put into a pastry outer and that pastry will be cooked, resulting in further loss. Which values should you use? Precook, post cook? What if you add something like sundried tomatoes, and these rehydrate?

Sometimes adding characterising ingredients is easy, sometimes hard. It’s not always obvious to a verifier if you have calculated the numbers incorrectly, but it’s very obvious if you’ve missed them completely.

Not Applying Characterising Ingredient Rules Correctly

Once again, this is probably easiest to demonstrate using an example.

Imagining the pie above is a mince, cheese and tomato pie, and that pie contains tomato sauce. The tomato sauce becomes a characterising ingredient, and the tomatoes in the tomato sauce are a characterising ingredient. You may be able to do a calculation and have just one % value, but sometimes you won’t have a choice because of compound ingredients, and this will require two %.

Water, Flour (Wheat, Soy, Rice), Minced Meat (15%) (Beef, Mutton), Tomato Sauce (Tomatoes (28%), Sugar, Salt, Food Acid (Acetic Acid), Spices, Natural Flavours)(10%), Animal Fats/Oils, Vegetable Fats/Oils, Cheese (5%) (Milk), Salt, Emulsifiers (Soy Lecithin, 331, 451, 471, 481), Maize Starch, Onion, Soy Protein, Flavour (Lactose, Flavour Enhancers (621, 635), Soy, Wheat, Barley, Yeast Extract), Colour (100, 150c, 160a), Acidity Regulators (263, 270, 330), Stabilisers (415, 466), Antioxidant (320)

Characterising ingredients seem easy enough at first, but in practice they can be really tricky. There are a few other stumbling blocks we see. Sometimes when using compound ingredients you won’t have the % available of a key ingredient. For instance, apple isn’t a characterising ingredient of barbeque sauce, but if you added it to an apple pie (please don’t, this is just the first hypothetical example I could think of), then the apple content of the barbeque sauce would become characterising.

Not Using Compound Ingredients Correctly

The tomato sauce example above illustrates this mistake perfectly. I’ve seen this done a lot.

A person takes their recipe, turns it into an ingredient list in descending order, and runs with that. The problem is that tomato sauce might be on the recipe as a single ingredient, but it is made up of a bunch of different ingredients and they all have to be listed too.

In the pie example, this mistake would look like this

Water, Flour (Wheat, Soy, Rice), Minced Meat (15%) (Beef, Mutton), Tomato Sauce (10%), Animal Fats/Oils, Vegetable Fats/Oils, Cheese (5%) (Milk), Salt, Emulsifiers (Soy Lecithin, 331, 451, 471, 481), Maize Starch, Onion, Soy Protein, Flavour (Lactose, Flavour Enhancers (621, 635), Soy, Wheat, Barley, Yeast Extract), Colour (100, 150c, 160a), Acidity Regulators (263, 270, 330), Stabilisers (415, 466), Antioxidant (320)

For this exercise, it was no coincidence that I picked on pies. Pies are really hard to do labelling for, and not only for the reasons listed above. The nutrition panels are really tricky to calculate too.

Conclusion

The rules associated with ingredient listings are complicated and span many of the standards, not just the one dedicated to ingredient listings. I tell clients I can usually spot an error in an ingredient listing in less than 10 seconds – this is not an exaggeration. The problem for you might be that your food control plan or national programme verifier, or competitor might also be able to spot one of these errors, and then you’ll probably have a problem on your hands.

Don’t derail your food project from the outset. A food labelling specialist is a worthwhile investment.

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