3. Compositional Aspects

Quick-frozen Foodstuffs
EU

This section provides the compositional requirements for the food category and/or food products in scope and information on permitted nutrients, ingredients, and additives. 

3.1 Composition Requirements

Category

Quick-frozen foodstuffs

There is no compositional standard at the EU level for “Quick-frozen foodstuffs”.

Product

Frozen Potato Products - Deep Fried 

There is no compositional standard at the EU level for potato products.

Frozen Cheese Snack Products - Deep Fried

There is no EU requirement on compositional standards for cheese products. However, because the name of the product must reflect the true nature of the food (for further details, see Section 4.4 of the "General Foods" guidebook for the EU), the main raw ingredient must be cheese. 

In addition, several specific types of cheese have protected composition because of Protected Designation of Origin (PDO) or Protected of Geographical Indication (PGI). The EU register eAmbrosia provides all the specifications of PDO and PGI products [1]. For instance, “Halloumi” is a PDO product and must comply with the specification (see details in Section 3.2 below).

3.2 Raw Material Requirements

Category

Quick-frozen foodstuffs

See below for product-specific requirements.

Product

Frozen Potato Products - Deep Fried

There is no EU requirement on compositional standards for the raw ingredients of frozen potato products.

Frozen Cheese Snack Products - Deep Fried

There is no EU requirement on compositional standards for the raw ingredients of cheese snack products, except when the product is using specific ingredients that are Protected Designation of Origin (PDO) or Protected Geographical Indications (PGI), such as Halloumi. Other types of cheese that are not protected by an EU quality scheme, such as Camembert and mozzarella, have no standard defined at the EU level. 

Halloumi

Halloumi is a Protected Designation of Origin (PDO) [2]. This means only Halloumi produced in Cyprus according to specific product specifications can bear their name within the EU.

Fresh Halloumi is made from curds produced by curdling milk (fresh sheep or goat’s milk or a mixture thereof, with or without cow’s milk added) with rennet. It is cooked and formed into its characteristic shape. It is semi-hard and elastic, folded (into a rectangular or semi-circular shape), white to light yellowish in color, has a close texture, and is easily sliced. The maximum moisture content is 52%, the minimum fat content is 43% (in dry weight) and the maximum salt content is 3%. [2]

Sheep, goat, and cow rearing occurs within a specified geographical area. The sheep, goat, and cow’s milk that is the raw material for the production of ‘Halloumi’ cheese is produced within the defined geographical area. Halloumi itself is also produced within the defined geographical area.

3.3 Fortification

Category

Quick-frozen foodstuffs

Vitamins and minerals are authorized to be added to processed foodstuffs [3].

Food with added ingredients, processed and deep fried before freezing, are considered processed snack foods. However, some jurisdictions may restrict the fortification of this type of product. Fortifying these foods of a typical nature with high levels of added fats, sugars, and salt may be seen as promoting unhealthy eating habits, and there may be concerns about overconsumption of fortified nutrients, especially among children. In addition, the EU Regulation contains provisions that allow further specific restrictions to be set in the future. 

Product

Frozen Potato Products - Deep Fried

Vitamins and minerals are not authorized to be added to unprocessed foodstuffs, including vegetables [3]. Frozen Vegetables without added other ingredients, such as frozen potatoes with no other ingredients than potato, are considered unprocessed food.

Frozen Cheese Snack Products - Deep Fried

Same as "Category" - Quick-frozen foodstuffs - above.

3.4 Other Permitted Ingredients

Category

Quick-frozen foodstuffs

Please refer to Section 3.4 - Other Permitted Ingredients - of the "General Foods" guidebook for the EU.

Product

Frozen Potato Products - Deep Fried

Same as "Category" - Quick-frozen Foodstuffs - above.

Frozen Cheese Snack Products - Deep Fried

Same as "Category" - Quick-frozen Foodstuffs - above. 

3.5 Permitted Additives

Category

Quick-frozen foodstuffs

Please refer to Section 3.5 - Permitted Additives - of the "General Foods" guidebook for the EU.

Product

Frozen Potato Products - Deep Fried

Potato products with added ingredients (other than potato) would fall under food category 4.2.6 – Processed Potato Products.

This category covers the following potato products: French fries, frozen or chilled potato specialties, and dehydrated potato products (flakes, granules, powder). All Group 1 additives are at levels of Quantum satis with individual restrictions as follows:

E 425 ML = 10000 mg/kg; E 620 to E 625, ML = 10000 mg/kg individually or in combination, expressed as glutamic acid; E 626 to E 635, ML = 500 mg/kg individually or in combination, expressed as guanylic acid.

The table below shows additives in other groups:

Frozen Cheese Snack Products - Deep Fried

Each component of the frozen cheese snack, batter, cheese, etc. must comply individually with the permitted additive authorized in their food category. Then, by the carry-over principle, the food additive can be present in the compound food. For example, the permitted additives in cheese ingredients are presented below.

Camembert and Swiss-style cheese

Camembert falls under section 1.7.2 Ripened cheese [4]. The following additives can be used:

Mozzarella

Mozzarella falls under section 1.7.1 Unripened cheese excluding products falling in category 16 [4]. The technical functions of the permitted additives are:

• Preservatives
• Acidity Regulators
• Colors
• Anti-caking Agents

Mozzarella can be split into low moisture content and high moisture content:

• Preservatives and anti-caking agents can be used for the surface of sliced, cut, shredded, or grated low moisture content mozzarella and also in the cheese mass if low moisture content.
• If it is a high moisture content mozzarella, preservatives can only be used in the cheese mass. Anti-caking agents are not allowed.

The following additives can be used:

Halloumi

The milk used to make Halloumi must not contain casein salts, colorings, preservatives, or other additives.

3.6 Permitted Flavors and Colors 

Flavors

Category

Quick-frozen foodstuffs

Please refer to Section 3.6 - Permitted Flavors and Colors - of the "General Foods" guidebook for the EU.

Product

Frozen Potato Products - Deep Fried

Group 11 colors at quantum satis can be used in categories 6.6 – (Batters) and 12.2.2 (Seasoning and Condiments).

Frozen Cheese Snack Products - Deep Fried

Same as "Category" - Quick-frozen Foodstuffs - above. 

Colors

Category

Quick-frozen foodstuffs

Please refer to Section 3.6 - Permitted Flavors and Colors Ingredients - of the "General Foods" guidebook for the EU.

Product

Frozen Potato Products - Deep Fried

Under food category 4.2.6 – Processed Potato Products: colors are not allowed to be used in category 4.2.6, only in dehydrated potato products (flakes, granules, powder).

Frozen Cheese Snack Products - Deep Fried

Colors are allowed in Camembert and Swiss-style cheese only to obtain the color characteristics of the product. The following colors are allowed:

3.7 Permitted Processing Aids 

Category

Quick-frozen foodstuffs

Please refer to Section 3.7 - Permitted Processing Aids - of the "General Foods" guidebook for the EU.

Product

Frozen Potato Products - Deep Fried

Same as "Category" above.

Frozen Cheese Snack Products - Deep Fried

Same as "Category" above.

3.8 Additional Notes 

Category

Quick-frozen foodstuffs

Please refer to Section 3.8 of the "General Foods" guidebook for the EU for additional notes on:

1. Novel food
2. Extraction solvent
3. GMO
4. Food enzyme

Product

Frozen Potato Products - Deep Fried

Same as "Category" - Quick-frozen Foodstuffs - above. Additionally, the below applies:

For fried food, acrylamide is a low molecular weight, highly water soluble, organic compound that forms from the naturally occurring constituents asparagine and sugars in certain foods when prepared at temperatures typically higher than 120°C and low moisture. It forms mainly in baked or fried carbohydrate-rich foods where raw materials contain its precursors, such as potatoes or batter of cheese snacks.

Commission Regulation (EU) 2017/2158 of 20 November 2017 [5] establishes mitigation measures and benchmark levels for the reduction of the presence of acrylamide in food to protect public health. It applies to food business operators involved in the production, processing, and distribution of food products, including fried potato products.

This includes following codes of practice based on best practices and industry guidelines to minimize acrylamide levels during production and processing.

The benchmark level for acrylamide in fried potato products is 500 micrograms per kilogram (µg/kg) of food. This benchmark level serves as a reference value to assess compliance with mitigation measures. Food business operators must ensure that acrylamide levels in their products do not exceed these benchmark levels and are required to monitor acrylamide levels in their products regularly and keep records of these measurements.

Frozen Cheese Snack Products - Deep Fried

Same as "Frozen Potato Products - Deep Fried" above.

3.9 References

1. eAmbrosia the EU geographical indications register-Main page

https://ec.europa.eu/agriculture/eambrosia/geographical-indications-register/

2. eAmbrosia the EU geographical indications register- Halloumi

https://ec.europa.eu/agriculture/eambrosia/geographical-indications-register/details/EUGI00000015984

3. The addition of vitamins and minerals and of certain other substances to foods Regulation (EC) No. 1925/2006  

Regulation - 1925/2006 - EN - EUR-Lex (europa.eu)

4. Regulation EC 1333/2008 on Food Additives

Regulation - 1333/2008 - EN - additives - EUR-Lex (europa.eu)

5. Regulation 2017/2158 - Establishing mitigation measures for acrylamide in food

Regulation - 2017/2158 - EN - EUR-Lex (europa.eu)