Information Note to manufacturers regarding Sulphites or Sulphur dioxide in Sausages and Burgers
We have received results from the Public Analysts Laboratories on levels of sulphites / sulphur dioxide in breakfast sausages* and burger meat** following routine sampling undertaken as part of the national chemical programme. Some samples were not in compliance with the legislation regarding allergens labelling and/or additives.
Sulphur dioxide and sulphites are known allergens and can cause reactions in certain persons especially those sensitive to asthma.
Sulphur dioxide and sulphites are covered by the following pieces of legislation:
- Allergens legislation - Directive 2001/13/EC as amended by Directive 2003/89/EC and E.C. (Labelling, Presentation and Advertising of Foodstuffs) Regulations 2002 as amended [S.I. No.432 of 2002 and S.I. No. 228 of 2005]
- Additives legislation – Annex III B of Directive 95/2/EC as amended and E.C. (Food Additives other than Colours and Sweeteners) Regulations 2004 as amended [S.I. No. 58 of 2004 as amended]
Sulphur dioxide (E220) and the sulphites (E221-E228) are permitted in a wide range of foodstuffs including breakfast sausages* and burgermeat** (with a minimum vegetable and/or cereal content of 4%). The maximum amount that may be added to breakfast sausages* and burgermeat** is 450mg/kg sulphur dioxide(SO2). The maximum level refers to the total quantity of sulphur dioxide present from all sources. Where sulphur dioxide is added at a concentration of more than 10mg/kg to pre-packaged foods, including the breakfast sausages * and burgermeat* * mentioned above, it must be declared on the labelling.
Sulphur dioxide / sulphites may not be added to burger meat* with less than 4% vegetable and/or cereal content.
| Additive |
Food |
Maximum Levels |
Label |
E220 Sulphur dioxide
E221 Sodium sulphite
E222 Sodium hydrogen sulphite
E223 Sodium metabisulphite
E224 Potassium metabisulphite
E226 Calcium sulphite
E227 Calcium hydrogen sulphite
E228 Potassium hydrogen sulphite |
Pre-packaged
- Breakfast sausages*
- Burger meat** (with a minimum vegetable and/or cereal content of 4%
|
450mg/kg (total of all sulphites)
|
Sulphur dioxide and sulphites at concentrations of more than 10mg/kg
|
| |
Loose
- Breakfast sausages*
- Burger meat** (with a minimum vegetable and/or cereal content of 4%
|
|
Not applicable |
Action
If you are manufacturing breakfast sausages* or burger meat* (with a minimum vegetable and/or cereal content of 4%), you must ensure that such products comply with the rules regarding allergens labeliing and/or additives?.
You should assess all such products you produce to determine compliance.
Seasoning mixes and other ingredients used to prepare breakfast sausages* and burger meat** may contain the additives listed above. So they must be used according to the manufacturers instructions.
Where sulphites / sulphur dioxide are present in a product at levels exceeding 10mg/kg or 10mg/l expressed as SO2, then this substance must appear on the label under its full name, (See Table above).
Further sampling and checks will be carried out by your inspector. Products found not to be in compliance will result in enforcement action.
*Both Breakfast sausages and ** Burger meat are listed in italics in Directive 95/2/EC, which indicates that they are Member States national products. Other Member States may produce such products as long as they conform to the description of the product and the manufacturing process it undergoes.
Last reviewed: 30/8/2010