What is an additive?

An additive is a substance added to food for a specific technological function. For example:

to preserve a food and increase its shelf-life - preservative
for colour
as a flavour enhancer
to give a sweet taste to the food - sweetener

Unlike other ingredients, additive substances on their own are not normally consumed as a food.

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How to recognise an additive

Additives are often present in curing and seasoning mixes and blends, batters, marinades and other ingredients you may buy in.

They will appear in the ingredients list either by name or as an E number.

Common additives you will come across as a butcher include:

sulphites;
potassium and sodium nitrites (E 249 and E 250);
sodium and potassium nitrates (E 251and E 252); and
colours.

You must check the ingredients to see what additives are present and read the instructions carefully to be sure you are using them correctly

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Sulphites

Sulphites cover the following range of additives so you might see any of these on an ingredients list, product specification, etc.:

Sulphur dioxide (E 220)
Sodium Sulphite (E 221)
Sodium hydrogen suphite (E 222)
Sodium metabisulphite (E 223)
Potassium metabisulphite (E 224)
Calcium sulphite (E 226)
Calcium hydrogen sulphite (E 227)
Potassium hydrogen sulphite (E 228)

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Correct use

Sulphites are only allowed in breakfast sausages and burger meat (with a minimum vegetable and/or cereal content of 4 % mixed within the meat), as well as some traditional Spanish and Portuguese meat preparations
You cannot use these additives in any other products
The maximum permitted level for total sulphites is 450 mg per kg of finished burger or breakfast sausage
Check seasoning mixes and other ingredients used in the manufacture of these products as they too may already contain some of these additives. This must be taken into account when formulating the product to ensure it complies with the maximum permitted levels
Follow the manufacturer’s instructions carefully. If there are no instructions for use, you should contact the supplier. Inappropriate use of these products can lead to too much additive in the finished product.

Sulphur dioxide and sulphites at levels above 10 mg/kg in the final product are considered allergens. Their presence in the food must be indicated to the consumer. See the section on allergens for more information on how to do this.

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Nitrates and nitrites

used for curing meats and add to the flavour and colour
the maximum permitted level depends on the type of product and are set out in legislation
the maximum amount of nitrates and nitrites which can be used in cured meat products is generally based on the in-going amount of the additives added to the meat
however, for some products (e.g., Wiltshire cured bacon and ham), which are traditionally cured, the maximum permitted levels for these additives is based on the amount remaining in the meat at the end of the production process

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When to use the in-going amount of nitrates/nitrites

You must use the maximum levels set for the in-going amount of nitrates/nitrites for:

meat products which are cured by an injection process only
meat products cured by an injection process which may possibly be followed by a short period of immersion curing (for less than three days)
dry cure products which are dry cured for less than four days

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When to use the amount of nitrates/nitrites remaining in the product after curing

those products produced by ‘traditional’ curing processes. For example, ‘Wiltshire bacon’ which is “meat that is injected with curing solution followed by immersion curing for 3 to 10 days. The immersion brine solution also includes microbiological starter cultures.”

These 'traditional' products are listed in the legislation and generally have higher maximum levels. Therefore, it is important to know whether the curing mix purchased is suitable for its intended use or you could end up exceeding the permitted levels for nitrates/nitrites.

For more detailed information on this area, please refer to our guidance document.

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Using colours with meat preparations

Colours are not allowed to be used with fresh meat or meat preparations.

Meat preparations are defined as fresh meat, including meat that has been reduced to fragments, which has had foodstuffs, seasoning or additives added to it or which has undergone processes that do not change the internal structure of the meat so that it still has the characteristics of fresh meat, e.g., where meat is marinaded but the marinade has not penetrated through to the interior of the meat.

You are permitted to use marinades or sauces containing colours for your meat preparations but only where:

the colour is permitted for use in the marinade or sauce (if in doubt, check with the supplier or contact info@fsai.ie for advice)
the colour does not penetrate into the meat itself.

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Seasoning mixes, cures and marinades

When buying and using these types of products, you must make sure that they:

come with a letter, certificate or product specification sheet declaring that the additives they contain comply with specifications set out in legislation (namely Regulation 231/2012)
have sufficient instructions for use to enable you to safely use these additives in your product and enabling you to comply with the relevant maximum levels for use set out in legislation
state the cereal/vegetable content of the mix so you know how much cereal/vegetable to add, if any, to reach the 4 % level for burgers and sausages

If mixing two or more different products from different suppliers, you must be sure you can calculate how much additive will be present in the final product in order to comply with the legislation.

Remember! Always follow the manufacturer’s instructions for use and weigh out amounts carefully. It is your responsibility to comply with the legislation.

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Records and Traceabilty

It is important to keep accurate records on the following and have them available when required by an inspector:

Details of the individual additives, mixes or blends, or other products containing food additives bought in
Copies of instructions for use for such products
Details of recipes used for different products, including quantities used and specifying the particular cure or seasoning mix used in such formulations
Records of calibration checks for injection-curing equipment and balances and scales used to weigh out ingredients

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