Flavour definitions and classifications

The Flavour and Fragrance Association of Australia and New Zealand is probably the best place to find out more about the latest definitions and classifications of flavours and what claims can be made on labels.

The International Organisation of the Flavour Industry (IOFI) Code of Practice version 1.2 was published in June 2010 and contains revised categories for defining flavours.

The definitions are taken from the current Codex Guidelines on the Use of Flavourings (CAC/GL 66-2008) and are as follows:

• 3.3.3 Natural flavouring substances
• 3.3.4 Synthetic flavouring substances
• 3.3.5 Natural flavouring complexes
• 3.3.6 Thermal process flavourings
• 3.3.7 Smoke flavourings

The Flavour and Fragrance Association of Australia and New Zealand (FFAANZ) is a member of IOFI and has adopted the IOFI Code of Practice. As many food and beverage processors use the PIF form, these categories are included in AFGC version 4 which is currently being finalised.

The FFAANZ Technical Committee has emphasised the following changes:

• Nature Identical (NI) flavouring substances are not retained as such.
• NI and Artificial flavouring substances are now defined as Synthetic Flavouring Substances.
• Natural flavouring complexes, Thermal Process Flavourings and Smoke Flavourings are new definitions.

FFAANZ understands that Food Standards Australia New Zealand (FSANZ) does not intend to include the new definitions into the Food Standards Code, thus there is no mandatory compliance date under Australian or New Zealand Food Law.

Food Standard 1.2.4 requires the presence of flavours to be included in the ingredient list as ‘flavouring’ or ‘flavour’. This will remain unchanged - thus these definitions will only affect products where customer voluntary ingredient descriptions or label claims are made.

Association members will support existing documentation with NI and Artificial classification for a period of 2 years from April 2011.

Natural Flavours will only consist of natural flavouring substances and/or natural flavouring complexes and will not contain other categories such as Thermal Process and Smoke Flavourings.

Thermal Process and Smoke Flavourings will not be defined as Natural or otherwise, they will just be defined as such.

The current FSANZ reference list of permitted flavouring substances will remain in Standard 1.3.1 clause 11. FFAANZ will make application for other internationally accepted lists eg, the EU Union List and Gras List updates when published.

Definitions

3.3.3 Natural flavouring substances

Natural flavouring substances (CAC/GL 66-2008 item 2.2.1.1) are flavouring substances obtained by physical processes that may result in unavoidable but unintentional changes in the chemical structure of the components of the flavouring (eg, distillation and solvent extraction), or by enzymatic or microbiological processes, from material of plant or animal origin. Such material may be unprocessed, or processed for human consumption by traditional food-preparation processes (eg, drying, torrefaction (roasting) and fermentation). This means substances that have been identified/detected in a natural material of animal or vegetable origin.

3.3.4 Synthetic flavouring substances

Flavouring substances formed by chemical synthesis are defined as Synthetic flavouring substances (CAC/GL 66-2008 item 2.2.1.2).

3.3.5 Natural flavouring complexes

Natural flavouring complexes (CAC/GL 66-2008 item 2.2.2) are preparations that contain flavouring substances obtained by physical processes that may result in unavoidable but unintentional changes in the chemical structure of the flavouring (eg, distillation and solvent extraction), or by enzymatic or microbiological processes, from material of plant or animal origin. Such material may be unprocessed, or processed for human consumption by traditional food-preparation processes (eg, drying, torrefaction (roasting) and fermentation). Natural flavouring complexes include the essential oil, essence, or extractive, protein hydrolysate, distillate, or any product of roasting, heating, or enzymolysis.

3.3.6 Thermal process flavouring

A thermal process flavouring (IOFI Guideline chapter 14.3) is a product prepared for its flavouring properties by heating raw materials that are foodstuffs or constituents of foodstuffs. This process is analogous to the traditional home cooking of ingredients of plant and animal origin.

3.3.7 Smoke flavourings

Smoke flavourings (CAC/GL 66-2008 item 2.2.3) are complex mixtures of components of smoke obtained by subjecting untreated wood to pyrolysis in a limited and controlled amount of air, dry distillation, or superheated steam, then subjecting the wood smoke to an aqueous extraction system or to distillation, condensation, and separation for collection of the aqueous phase. The major flavouring principles of smoke flavourings are carboxylic acids, compounds with carbonyl groups and phenolic compounds.

‘All Natural’ claims

‘All Natural’ is a marketing term which is open to interpretation. There is no legal definition for ‘All Natural’ and as such FFAANZ cannot support the use of ‘All Natural’ claims for flavours.

Consideration should be given to the following publications when determining whether an ‘All Natural’ claim can be used for products containing flavours - The ACCC Food and Beverage Industry Food Descriptor Guideline to the Trade Practices Act Nov. 2006, page 17 section on Natural, and The definition for Natural flavourings defined in the International Organisation of the Flavour Industry (IOFI) Code Of Practice.

Answers to frequently asked questions about flavour classifications

Q. Is FSANZ likely to change labelling regulations for a ‘flavouring or flavour’ and, if so, when?

FFAANZ: It is our opinion and understanding that Food Standards Australia New Zealand (FSANZ) does not intend to include the new definitions into the Food Standards Code and as such there would be no change to labelling regulations for a flavouring or flavour.

Q. Will flavour company specifications for flavours change for existing flavours.

FFAANZ: Yes - member companies will be changing specifications as and when they are due for review. This is a major administrative undertaking and will commence during 2011.

Q. FFAANZ communique 10/02 indicated that Association members would support existing documentation with NI and artificial. What does this support mean and what is the significance of “2 years from April 2011”?

FFAANZ: Documentation containing NI and Artificial classification issued before April 2011 will remain valid for 2 years. Two years was considered to be sufficient for association members to issue revised documentation for existing products with the new definitions. April 2011 is 6 months post issue of the PIF Form V4 used by many manufacturers.

Q. If we as a company use a flavour and list “flavour” in the ingredients will the change of definitions have any implications for us?

FFAANZ: No.

Q. If we as a company use a currently defined natural flavour and list as natural flavour will the change of definitions have any implications for us?

FFAANZ: No - the new product specification must indicate Natural flavouring substances and/or Natural flavouring complexes only. If there are Thermal Process or Smoke flavourings present the “natural flavour” classification will become invalid.

Q. Most flavours will contain carriers which may or may not be classified as natural - can natural flavouring substances or complexes include these carriers without declaration?

FFAANZ: Yes. Carriers are excluded from the flavouring.

Q. Can a natural flavouring substance be sourced from any plant or animal origin and/or a number of sources?

FFAANZ: Natural flavouring substances can be sourced from any plant or animal but must comply with the full definition (see above).

Q. Does a natural chicken flavour need to be sourced from chicken only or can it contain other natural flavours?

FFAANZ: A natural chicken flavour can contain Natural flavouring substances and/or Natural flavouring complexes derived from sources other than chicken.

Q. If FSANZ does not require inclusion of flavour definitions in labelling, who will decide on whether label claims are acceptable?

FFAANZ: The new IOFI definitions are for flavour classification purposes only. They are not claims. Just as Natural, NI and Artificial flavours are for flavour classification purposes, they are not claims either. Label claims are the voluntary choice and sole responsibility of individual companies who need to take into account provisions of the Consumer Protection Act.

Q. Can we as a company continue with a “No Artificial Claim” where no current definitions exist?

FFAANZ: A label claim is an individual company decision. The company needs to take into account whether such claims can be deemed as false or misleading to the consumer. These definitions are not regulated under Australian or New Zealand Food Law but need to take into account provisions of the Consumer Protection Act.

Q. Can Smoke flavours and process flavours be classified as Natural?

FFAANZ: No - they have their own classification.

Q. Who will be monitoring the natural flavour claims made on packaging?

FFAANZ: In terms of the Consumer Protection Act, the ACCC and delegated state authorities will investigate formal complaints where a claim is said to be misleading as per the current practice.