How to label food additives

To help consumers make informed decisions about the foods they choose to eat, the South African labelling regulations stipulate how food additives must be declared in the ingredient list for a food. FACTS has summarised the labelling requirements for food additives to make them easier for manufacturers to implement.

The two regulations that refer to the labelling of food additives are the regulations relating to the labelling and advertising of foodstuffs (R. 146) and the regulations relating to the use of sweeteners in foodstuffs (R. 733).

Firstly, all ingoing ingredients – including food additives (refer to R. 146 for the definition) – must be declared in the ingredient list in descending order of mass.

The declaration of food additives depends on the technological function of the additive. Annexure 1 in R. 146 lists additive categories by function. Additives added to perform the function of one of the listed categories may be indicated by the name of the category. Examples of these categories include acidity regulators, bulking agents, flavourings, thickeners, etc. Therefore, if you are adding sodium bicarbonate as a raising agent, you may list it as ‘Raising Agent’ only; you need not include the common name of the additive. But there are a few exceptions:

Preservatives

Preservatives must be indicated by their common chemical name in parenthesis, preceded by the word ‘Preservative’. For example: ‘Preservative (Sodium Benzoate)’. Note also that sulphur dioxide (or related compounds) need only be declared if it is used at a level of 10mg/kg or more.

Curing agents

In the case of sodium or potassium nitrite and sodium or potassium nitrate used in shelf-stable cured meat products, the words ‘Curing Agent’ should be used, followed by the listed curing agents in parenthesis.

Antioxidants

An antioxidant as an additive must be indicated by the common chemical name or abbreviation in the list of ingredients, for example ‘BHA’ or ‘BHT’.

Tartrazine

Although other colourants may be indicated by their category name, if a food contains tartrazine, the word ‘Tartrazine’ must appear in the ingredient list. 

MSG

Other flavour enhancers may be indicated by their category name only, but MSG must be indicated as ‘Monosodium Glutamate’ or the abbreviation ‘MSG’ followed by the words ‘Flavour Enhancer’.

Sweeteners

Sweeteners must be indicated by their common name in the list of ingredients. In the case of a non-nutritive sweetener, the words ‘Non-Nutritive Sweetener’ must appear in parenthesis immediately following the name of the sweetener; or the words ‘Non-Nutritive Sweetener’, followed by a semicolon and the name of the non-nutritive sweetener. And in the case of the sweetener steviol glycosides, it must be described as ‘Steviol Glycosides’ or ‘Steviol Extract’. A foodstuff containing aspartame and aspartame-acesulfame salt must bear the term ‘aspartame’ or ‘aspartame-acesulfame salt’ in the list of ingredients, followed by an asterisk; and an asterisk must then appear on a separate line directly below the list of ingredients, followed by the words ‘Contains phenylalanine’ or ‘Phenylketonurics: contains a source of phenylalanine’.

Common allergens

Any additive or carrier for an additive that is derived from or contaminated with a common allergen must indicate the origin of the common allergen in parenthesis after the name of the additive; for example, ‘Emulsifier (Soya)’.

Carry-over of food additives

A food additive carried over into a food because it was a constituent of an ingredient of such foodstuff, at a level less than that required to achieve a technological function, is exempted from declaration in the list of ingredients. The exemption does not apply to food additives derived from common allergens, preservatives, antioxidants, MSG and tartrazine.

E-numbers

The use of E-numbers in the ingredient list is not mandatory; they may therefore be omitted.

Artificial vs Natural

Additives must not be qualified further by making use of wording such as ‘natural’, ‘synthetic’, ‘artificial’ or ‘nature-identical’.

Pre-packed food additives

Regulation 35 of R. 146 stipulates additional labelling requirements for pre-packed food additives and blends of food additives.

Apart from considering the manner in which food additives should be labelled, it is important to always consult the relevant regulations to ensure that an additive is permitted to be used in that category of foodstuffs, and at what level. By correctly following the regulations, food manufacturers can ensure that their products are legally compliant and safe for consumers.

Other articles and resources you may be interested in:
How do I know whether a certain additive is permitted in my product?
Allergen Labelling: Processing aids and additives
Minimum labelling infographic
South Africa’s Regulatory Framework