In recent years there has been much to do with regard to the planned European regulations with regard to smoke condensates, liquid smoke or smoke aromas. Mainly due to the unfamiliarity with this matter among officials and ministers, the discussion initially seemed to go in the wrong direction for producers and users. Thanks in part to the Dutch contribution, EU legislation is now in place, averting the calamity for many users in the meat, fish and other food industries. Smokers can live well with the new rules.

Peter Dingelhoff, Sales Manager Western Europe and the Middle East of Red Arrow, was an expert and naturally interested co-initiator of and closely involved in (influencing) decision-making by the European Commission. Meat & Co. Peter asked to explain the new rules.

The new regulations refer to primary products and derived smoke flavors. What is the difference?

Peter Dingelhoff: “That is indeed a question that we expect to hear a lot. The primary product is the basic product, the raw material for the “derived smoke flavors”. Red Arrow has two approved primary products, of which we can produce different smoke aromas. For the meat-processing industry, some are particularly suitable for regenerating a cloud of smoke; others for showering and dipping. Then there are aromas, which only give a taste and are mainly used in the aroma industry. The differences are adapted to the use. Chardex H, for example, is a spray-dried version of SmokEz C10. Enviro 24 is again a slightly concentrated version of Enviro 23. The products that we have on the market are therefore all permitted.”

What do “GMPs”, “clean technological conditions” and “specific conditions of use” mean exactly?

What do “GMPs”, “clean technological Peter Dingelhoff: “Good manufacturing practices are particularly important for the smoking process where a smoke flavor is converted into a cloud of smoke. The European Commission has found that smoking through smoke flavors has many benefits for employees, the environment and not least for consumers. Because the regeneration of a smoke aroma produces a real cloud of smoke and a smoke box has to be filled with smoke, regardless of the quantity of product it contains, the EC has decided that control is not feasible and the same rules apply as for direct smoking with wood. The clean technological conditions apply if several smoke aromas are used. For example in a herbal blend or when dipping. In that case, the maximum dose may not be exceeded. With specific conditions of use, it is finally made clear how many grams per kg may be present as an ingredient on the final consumer product. ”

There is a difference in the maximum permitted level (g / kg) of the different smoke condensates in, for example, “processed meat”. For example, 5.0 for SmokEz Enviro-23 is high compared to other condensates. What does that mean?

Peter Dingelhoff: “That is correct. Red Arrow has chosen to apply for admission for two primary smoke condensates. SmokEz C10 is a product that we use widely in the meat processing industry and the aroma industry. Enviro 23 is extremely suitable for the meat processing industry and we are also the market leader in this. By offering Enviro 23 only as a real counterpart to direct smoking with wood, we can use higher values. This has many advantages, especially where meat products are dipped or showered, such as with co-extrusion.”

Is it true that the doses considered safe by the producers have been adjusted downwards because, according to the EFSA, they had insufficient safety margin?

Peter Dingelhoff: “The doses have indeed been adjusted downwards. However, this has more to do with the question. In the beginning, questions were asked about usage quantities and afterwards how much is in the end product. There is a big difference in that. During the shower, more than 50% of the smoke does not end up in the end product. Dr. Honnikel even came with a number of> 90% when it comes to fogging. That is why the quantities in the end product could be adjusted downwards. The permitted doses are, however, so high that you will hardly ever arrive there. The product would then get a much too dominating smoke taste.”

What can you tell about the trajectory that has been taken to achieve this result?

Peter Dingelhoff: “If you want to publish a book, I have enough text. All kidding, the Netherlands has had a very positive input. The Dutch food industry is the only one in Europe to pick up the baton. The FNLI, Unilever, Zwanenberg, the VNV, the VSF, the Dutch aroma association and we as producers have sat around the table with Kees Planken of the Ministry of Health, Welfare and Sport. During our discussions, Mr. Planken gained so much insight into the matter that RIVM carried out an alternative study to refute the intake calculation used by EFSA. Together with the fact that 90% of the smoke flavors sold are used in particular in the meat-processing industry, which is also recognized by the law as safer, has led the Member States to view smoke flavors differently. Ultimately, this bill was passed by a vast majority of votes. Only two small countries voted against and two Member States abstained.”

What do you think of these regulations in terms of content? Is there any inaccuracy or lack of clarity?

Peter Dingelhoff: “First of all, I am pleased that there is now regulation after a longer period of uncertainty, which has resulted in many inaccuracies being published. However, the regulations are not entirely clear. This is partly because the Member States have difficulty with the complexity of a smoke flavor. Of course, it remains strange that a GMP standard applies when a smoke aroma is sprayed, but if the same product is used for showering, measurements must suddenly be taken. In addition, it is not possible to measure the amount of smoke flavor in a meat product. There is simply no parameter in smoke that can be found as such in a product. Even with roads you can’t get there, since smoke simply tends to extract moisture in the first instance. This is due to the acids in the smoke and the carbonyls, which causes the intestine to contract, the well-known cross-linking reaction. Because of this we can only make a rough estimate. Fortunately, the dosages are such that we do not expect any problems, but it remains strange.”

Is something changing for the producer? And if so what?

Peter Dingelhoff: “Producers now have the certainty that their smoke product can be used safely. All permitted primary smoke aromas have an authorization number. Red Arrow’s, for example, is SF005 for SmokEz C10 and SF006 for Enviro 23. This allows producers to see where their smoke comes from. In addition, producers must demonstrate to the supervisory authority that no more smoke flavorings are used in a product than permitted. To create clarity in this, we come up with clear documents, so-called Usage Level Data Sheets (ULDS).

As a producer, we indicate from which primary product the smoke flavor originates and how much of it can be contained in the consumer product. This is because the derivative can be concentrated, but it can also be diluted. That all sounds rather complicated, but this will be easy to calculate using the ULDS. In addition, we have properly instructed our distributors, such as Smoky Light for the Benelux, and they will support our customers where necessary. To be clear: if smoke aromas are sprayed, as with the Tarber system, no calculation is required.”

What are the direct consequences of this EU regulation for users of smoking condensates?

Peter Dingelhoff: “The most important thing is that users are now one step ahead of their competitors. Firstly, it is now clearly recognized that smoke aromas are safer than direct smoking with wood. The expectation is that more customers will set requirements for this. In addition, from the beginning of September 2014, stricter rules will apply with regard to PAHs. The Benzo (a) pyrene content is reduced from 5.0 μg / kg to 2.0 μg / kg and the total of four PAHs from 30.0 μg / kg to 12.0 μg. These PAHs are mainly in the tar. Since a smoke flavor is a traditional smoke filtered with water, from which the tar has been removed, our products always fall within these new standards.”

Permitted smoke flavors

The European Commission has approved 10 primary smoke flavorings in its decision
for a period of 10 years. The smoke flavors are:

Scansmoke PB 1110 en Scansmoke SEF 7525 van Azelis Denmark
Zesti Smoke Code 10 van Draycott Mills
Smoke concentrate 809045 van Symrise
SmokEz C-10 en SmokEz Enviro-23 van Red Arrow Products Company
Tradismoke A MAX van Nactis
ProFagus-Smoke R709 van ProFagus
Fumokomp van Kompozíció
AM 01 van Aromarco

The admission period is automatically extended after 10 years at the request of the producer.