The industry expert, who wished to remain anonymous, told FoodManufacture.co.uk:“Certain Member States may have woken up to the fact that some enzymes can have a residual role in helping to prolong shelf-life in finished products, for example. In that case, then they would have to be declared, and that could open a real can of worms regarding GM origins.”
Enzyme industry lobbying
Up to now, he explained, the enzyme industry was among those interest groups, which had successfully lobbied for a regulatory distinction between what food is ‘produced from’ and what it is ‘produced with’. This had helped to keep enzymes out of the GM debate.
“I don’t think the GM issue has triggered the Commission’s interest,” he added. “But I fear that this could turn out to be the law of unintended consequences. The labelling of enzymes is a potential minefield.”
Chair of the Food Additives and Ingredients Association (FAIA) Nigel Baldwin pointed out: “In the vast majority of cases, enzymes should fall into the category of ‘processing aids’, and so will not appear on the label at all.”
He added: “The industry will kick and scream if that vast majority of enzymes are not in fact regulated as processing aids.”
Toxicology testing
But of more concern to the enzymes industry, he said, were current proposals from the European Food Safety Authority (EFSA) for toxicology testing on enzymes used as process aids as part of the EU’s Food Improvement Agent Package (FIAP).
“By definition, the fact that an enzyme is a processing aid means that it will not be present in the finished product, or only in barely detectable amounts,”said Baldwin. “Even where there is no DNA in the finished product, or where it has been denatured, you have to go away and carry out three months of animal testing in meaninglessly high doses.”
He estimated that trials on the scale and duration required by EFSA could cost between €200,000 and €250,000 each. The likely deadline for testing and dossier completion is 2015.
Another consultant and enzymes expert, who also did not want to be named, predicted: “The Commission’s current interest in enzymes isn’t going to dig up GM issues.”
She also played down the impact of the FIAP requirements. “It’s possible that additional work will need to be done, but in some cases enzymes can be grouped in single dossiers.”
She highlighted the risk that suppliers might consider discontinuing some low-volume enzymes rather than carrying out potentially costly testing.
