Blog%20banner%20with%20text
Back to blog page

Heritage ingredients and Novel Foods


On 13/06/14 by Steve Livens (Policy Manager - Product Assurance & Supply Chain)


When is an ingredient not an ingredient…when it’s a novel food, of course!


Let’s be clear, natural ingredients remain part of the long and distinguished heritage of beer. It is a heritage that reaches back to soaking discs of unleavened bread with water in clay jars to create what was likely to be the earliest form of beer. Today, brewers continue to reserve the right to be an inventive bunch, always coming up with new, wild and crazy combinations of ingredients to lay down the gauntlet of taste and aroma to the unsuspecting consumer!


However the use of ‘natural’ ingredients is becoming something of a grey area and in this way, on behalf of one BBPA member, I recently found myself immersed in the murky world of food ingredients. Principally, regarding what constitutes an ingredient. When is an ingredient no longer an ingredient or worse even a ‘non-food’ and far more terrifyingly than this, when does an ingredient becomes a Novel Food. Or as I like to think of it, the ingredient equivalent of a zombie!


As part of an ongoing, broad interest in producing ‘heritage’ beer styles, brewers have shown a keenness to experiment with the use of ‘heritage’ ingredients. These are ingredients, usually derived from natural plant sources, that have been in wide spread use in the past but are perhaps less well known or used today. A typical example being that of gruit, a mixture of herbs, spices and bittering plants such as bog myrtle (myrica gale) which was in widespread use before the introduction of hops to Britain from the Netherlands around the 14th Century.


However, it seems that what Europe gives with one hand it takes with the other and an issue with the use of heritage ingredients, such as bog myrtle, becomes clear when one considers the Novel Food and Novel Food Ingredients Regulations (EC 258/97). Specifically, the European Commission ‘considers foods and food ingredients that have not been used for human consumption to a significant degree in the EU before 15 May 1997 novel foods and novel food ingredients’.


Under this premise, any such ingredients that have not been officially ‘approved’ for use since 1997 potentially require authorisation before they can legally be used for food production! Such authorisation is required primarily to show that the ingredient in question is safe for use, but also to corroborate any claims that may be associated with its use. Approvals are made on an EU wide basis and helpfully there are no definitive, approved lists!


Thankfully there is a ‘but’, if albeit a somewhat grey one! EC 258/97 is not predominant as a Regulation and in the case of a food ingredient that is used as a flavouring, whether in significant use before 1997 or not, this then becomes subject to the EU flavouring Regulations (EC 1334/2008).


Brewers wishing to use ‘heritage’ ingredients now have two options. Firstly and more definitively, demonstrating that an ingredient has been in significant use (Commission guidance on definition of ‘significant’) prior to 1997 obviates Novel Foods Regulations. An alternative is to satisfy the definition of a flavouring in EC 1334/2008.


Thankfully, using the definitions in EC 1334/2008, most plant based ingredients that are used, like hops, for the purpose of providing either or both flavour and aroma appear likely to fall within the definition of a ‘flavouring preparation’. As such the ingredient in question is not present in the final product or is removed from the process during production and for which the physical processes of either heating or steeping are used to extract the necessary compounds for aroma or flavour. As for all food producers, there remains a requirement for brewers to be sure that any ingredient they use will not endanger public health. However, in many cases, showing use in other foods can be sufficient for this purpose.


Needless to say, as with most regulations that emanate from Brussels, there is ever a healthy mix of confusion and uncertainty. The recent Consumer Food Information Regulation being a case in point! However, in the case of Novel Foods BBPA is also now working with the FSA, who profess to also be suitably confused, to raise a point of clarification with the Commission over where ingredients may fall between Novel Foods and Flavouring Regulations. We hope that this will result in some further clarity and not least to ensure that the spirit of diversity and creativity that underlies the brewing industry is not stifled.



0 Comments


Please login to comment.

Find a blog post

Refine your search here