Dairy Ingredient Verification
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1.1 Objective of Activity
To observe if:
- The list of ingredients is complete, accurate, and in the correct order,
- That the ingredients are properly named,
- Only permitted ingredients and additives are used,
- Allergenic compounds that are added or carried over, such as nuts and sulphites, are correctly declared in the list of ingredients
1.2 Required References
- Ingredient verification worksheet
Food and Drug Regulations (FDR)
- Dairy Product Regulations (DPR)
- Consumer Packaging and Labelling Regulations(CPLR)
- Guide to Food Labelling and Advertising (GFLA)
- Health Canada - Food Allergen Labelling
- Food Allergies and Allergen Labelling
- Health Canada - List of Permitted Food Additives
1.3 Inspection Procedures
Where possible, ingredient verification should be done in conjunction with a label verification as much of the information, such as the list of ingredients, must be reviewed for both activities.
Prior to commencing the exercise, a review of the master formulation should be carried out. The master formula is the recipe showing the quantity of each ingredient and component that makes up the final composition of the end product. Because of proprietary considerations, you should only record this data on a piece of paper that you will dispose of prior to leaving the establishment. The quantity of each ingredient and component is vital to assess the order in which ingredients and components should appear on the label.
This is particularly important when it comes to determining the maximum level of additives permitted by the regulations or prescribed under a specific standard of composition.
Wherever possible, the inspector should observe the addition and processing of all of the ingredients. This is not always possible in dairy plants where the milk is usually pasteurized prior to the inspector's arrival. However, the addition of any other ingredients should be witnessed.
1.3.1 List of Ingredients
Write down the list of ingredients in descending order as they appear on the package or container down the left hand side of the standardized work sheet.
1.3.2 On-Site Observations
Write down the actual ingredients that are being added to a mix with approximate quantities such as 3 x 45 kg bags of skim milk powder, 2 x 500 g scoops Poly 80, etc., down the centre of the worksheet. Ensure that you ultimately have all the compounds listed in equivalent weight or volume, using the same units (grams, kilograms, litres etc.).
Observe that these ingredients are actually being added at the mixer in the quantities prescribed. You should also ensure that if the make sheet calls for a certain ingredient from one company that they haven't switched to a different supplier, as this often results in a change of ingredients. You have to be very specific and careful here: e.g. Emulse 20 is an emulsifying agent made of guar gum, carrageenan and carboxymethylcellulose vs. Emulse 22, which contains carob bean gum, guar gum and carrageenan. These are not the same products, and they do not have the same constituent ingredients.
1.3.3 Formulation Sheet
In some cases the formulation sheet (master formula) is the same as the make sheet or recipe. Because of proprietary considerations, only record this data on a piece of paper that is disposed prior to leaving the establishment. In most cases the make sheet will be different, and will contain a breakdown of the ingredients in order to standardize the mix.
1.3.4 Ingredients or constituent components of the actual Ingredients
List all the constituent components of the ingredients being added from the make sheet down the right hand column of the worksheet. This may be retrieved from the ingredient listing on the container of each ingredient, or as is more often the case with bulk products, from the manufacturer's specification sheet.
- There are no potential allergens which may be added and not declared, or that may be introduced by cross contamination. (See section 188.8.131.52)
- All ingredients that are added are declared on the list of ingredients except those exempted by the Food and Drugs Regulations (FDR B.01.009).
- The ingredients (DPR or Division 8 of the FDR for dairy products) are permitted in the product, and that they are present at permitted levels. The food additives permitted in a given product and the prescribed levels can be found in Health Canada's List of Permitted Food Additives
- The ingredients, from the formulation sheet; appear in descending order by weight before they are combined to form the food. (FDR B.01.008(3))
Return the formulation sheet to the plant.
1.4 Supplementary Information
1.4.1 Regulatory Requirements
1) The requirement for ingredients and components to be listed for all foods consisting of more than one ingredient is found in FDR B.01.008(1)(b). Ingredient means the individual unit of food that is combined with one or more individual units of food to form an integral unit.
The above requirement does not apply to single ingredient foods, as well as the following situations (FDR B.01.008(2)):
- prepackaged food packaged from bulk at retail
- prepackaged individual portions served by a restaurant or other commercial enterprise with snacks or meals.
- individual servings sold by a vending machine or canteens
2) The following must appear on the list of ingredients but may be in any order FDR B.01.008(4) :
- spices, seasonings and herbs except salt (Spices consist of flower, seed, bud, fruit or nut of a plant. Herbs consist of leaves, stems or roots.)
- natural and artificial flavours
- flavour enhancers (except: hydrolysed (source) protein, monosodium glutamate (MSG), ammoniated glycerin, disodium inosinate, disodium guanylate, ethyl maltol, etc.)
- food additives, except ingredients of food additive preparations (see below - preparations)
- vitamins and their salts or derivatives
- mineral nutrients and their salts
3) Component means essentially the ingredients of the ingredients. These must also be declared FDR B.01.008(1)(b). Third or fourth generation components (ingredients of the components) generally don't have to be listed.
Components of ingredients must be shown immediately after the ingredient of which they are a component, (usually within brackets and used for foods with distinct components e.g., ice cream bar with coating), or by their common name in descending order with all the other ingredients (usually homogenous foods e.g., chocolate ice cream). FDR B.01.008(5).
4) Exemptions from component list: FDR B.01.009(1)
These foods when sold by themselves must have a list of ingredients, but when used as an ingredient need only be listed by the ingredient name only (i.e., no components required). Some common ingredients in dairy products that are exempt from component declaration include butter, mono and diglycerides, milk subject to compositional standards B.08.003 to B.08.027, sweetening agents subject to B.18.001 to B.18.018, cocoa, salt, bacterial culture.
Ingredients may also include preparations and/or mixtures such as food colour preparations, flavouring or artificial flavouring preparations, spice, seasoning or herb mixtures, rennet preparations, etc. These preparations/mixtures do not have to declare the ingredients and components unless these include salt, glutamic acid and salts, hydrolysed plant protein, etc. (FDR B.01.009(2) and (3))
5) Required Terminology - Common Name for Ingredients FDR B.01.010
The common names for ingredients listed in the table following FDR B.01.010(3)(a) are mandatory and must appear in the list of ingredients as shown. In the case of the table following FDR B.01.010(3)(b), the common names in Column II are optional and may be used to collectively describe the ingredients in Column I. If one of the ingredients in Column I is shown separately in the ingredient list the common name in Column II cannot be used and all the ingredients must be listed separately.
The common names of ingredients or components must be shown as they occur in these tables or as they appear in the standards.
e.g., FDR B.18.001: Sugar instead of sucrose, or FDR B.17.001: Salt instead of sodium chloride.
Water, when added as an ingredient must be declared by proportion by weight being added to the food. However, when water is used to reconstitute dry milk powders, the optional collective name of milk ingredients instead of water and dry milk powders may appear in the list of ingredients. Any water in excess of the amount required for reconstitution of the dry powder must appear in the list of ingredients.
Abbreviations are not acceptable except for B.H.T. (butylated hydroxytoluene) and B.H.A. (butylated hydroxyanisole).
1.4.2 Summary of Inspection Steps
184.108.40.206 Inspection Procedures
In conjunction with the label verification, review the master formulation which shows the amount of each ingredient and component in the final product. Observe the addition of all ingredients and write them down on the worksheet.
220.127.116.11 On the Worksheet
Using the left hand side of the worksheet, write down the list of ingredients as it appears on the product label. Use the center column to record the ingredients you observe being added. In the third column list the components (ingredients of the ingredients) using the ingredient container or the manufacturer's specification sheet.
- all allergens are correctly identified in the list of ingredients
- all the ingredients that you observed being added are identified by the correct common name in the list of ingredients
- the ingredients and additives are permitted in the product by the FDR (Division 8 and List of Permitted Food Additives)
- ingredients appear in descending order by weight
A variety of foods contain ingredients that can cause adverse reactions. Most reactions are caused by the following foods and their derivatives: peanuts, tree nuts, sesame seeds, milk, mustard eggs, fish, crustaceans and shellfish, soy, wheat, sulphites, mustard.
- Most prepackaged products must include food allergens, gluten sources, and sulphites in the list of ingredients or in a statement that begins with Contains: on their labels;
- Food allergen or gluten sources must be written in commonly used words such as milk or wheat;
- The common names for the plant sources of starches, modified starches, hydrolyzed plant protein and lecithin must be modified to provide source information. For example, the label must indicate hydrolyzed soy protein rather than just hydrolyzed vegetable protein;
- Products that include spelt and Kamut® must declare wheat as an allergen on their labels;
- Sulphites in products above 10 ppm need to be in the list of ingredients or in a statement that begins with Contains: on the label ;
- Products must list any components of an ingredient that are food allergens, gluten sources, or sulphites (when 10 ppm or more). For example, if a prepackaged food contains the ingredient spices, that food will be required to list any allergens, gluten sources, or sulphites present in the spices, such as mustard.
- Prepackaged fruits and vegetables that have a protective edible coating or wax must include the source of any allergen or gluten on their labels
18.104.22.168 Ingredients and Components
Must be declared in the list of ingredients by their:
- common name or
- mandatory common name or
- optional common names or
- common name of the active ingredient.
22.214.171.124 Common Names
These are prescribed by regulation (FDR, DPR etc.) or the name by which the food is commonly known. (e.g., cream cheese, cheese sauce etc.)
126.96.36.199 Mandatory Common Names
Refer to Mandatory Common Names of Ingredients and Components FDR B.01.010(3)(a)
These exist for some foods used as ingredients and components in other foods. (e.g., vegetable oil margarine or corn oil margarine.)
188.8.131.52 Optional Common Names
Refer to Collective or Class Names for Ingredients FDR B.01.010(3)(b)
These exist for foods or classes of foods used as ingredients or components in other foods. (e.g., milk ingredients.)
184.108.40.206 Active Ingredients
Preparations of vitamins, mineral nutrients, food additives or flavour enhancers are shown in the list of ingredients by the common name of the active ingredient(s). (e.g., vitamin A palmitate.)
Components are ingredients of ingredients. They must be declared either: in brackets following the ingredient name in descending order of proportion by weight in the ingredient; or by their common name in descending order of proportion by weight in the finished food.
220.127.116.11 Ingredients Exempt from Component Declaration
Some foods when used as ingredients in other foods are exempt from a declaration of their components (ingredients). However if any exempt components consist of food allergens, gluten sources or sulphites (at 10 ppm or more), the allergen, gluten source or sulphites must be declared. They may be declared in the list immediately in parentheses after the ingredient which they are components of or in the Contains statement immediately following the list of ingredients.
Refer to: Ingredients Exempt from Component Declaration (FDR B.01.009(1)) (e.g., butter)
18.104.22.168 Preparations and Mixtures
Preparations and mixtures do not have to declare ingredients and components unless they contain priority allergen, gluten, added sulphite, salt, glutamic acid, hydrolysed plant protein, aspartame, potassium chloride, any ingredient that performs a function in or has an effect on the food, peanut oil, hydrogenated peanut oil and modified peanut oil.
These ingredients must be declared as per the allergen regulations or as if ingredients of the food.
22.214.171.124 Compositional Standards
DPR and Division 8 of FDR
- composition standards for dairy products.
- List of Permitted Food Additives
- permitted foods and the allowable level of use.
126.96.36.199 Order of Ingredients
Must be listed in descending order of proportion by weight in the food
- spices, seasonings and herbs(except salt), natural and artificial flavours, flavour enhancers, food additives, and vitamin and mineral nutrients and their derivatives or salts, which may be shown at the end of the ingredient list in any order.
1.5 Non satisfactory Inspections
- If a potential health and safety concern such as undeclared allergens (sulphites, nuts and their by-products etc.) is found, the inspector must detain all affected product. The Program Officer should be contacted immediately to determine if a product recall will be necessary. (See recall procedures)
- In a non-health and safety situation, the non-compliant ingredient(s) should be noted on the CFIA/ACIA 950 with a request for written corrective action by the establishment. Details such as existing stock and the time required to exhaust the non-compliant stock should be noted. A copy of the corrected label should be forwarded to the inspector. When possible, if an ingredient is added but not declared, the establishment should discontinue the use of the ingredient immediately.
Appendix - Ingredient Verification Worksheet
Date of Inspection:
- Check Bulk
- Check Prepackaged
- Check CAPA product
- Check Graded
- Check Standardized
- Check non-CAPA product
|List of Ingredients (and Additives) as listed on label||Ingredients (Additives) and Quantities (Recipe)||Components||Correct Ingredient Listing|
|1. Are all potential allergens (nuts, sulphites etc.) declared on the label?|
|2. Are ingredients (additives) added according to the listing on the label, and do they appear in descending order by weight?|
|3. Are all ingredients (additives) approved for use in this product?|
|4. the food additives used meet the prescribed levels of use as outlined in the List of Permitted Food Additives?|
Note: Please attach a copy of the label to this worksheet.
- Date modified: