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Acrylamide, ABC of the new rules

The Regulation EU No. 2017/1258 ‘laying down mitigation measures and standards of supply to reduce the presence of acrylamide in foodstuffs’ (1) – to be applied on April 11, 2018 – provides a wide range of requirements on 10 food categories. Bread and baked goods, chips and potato-based products, breakfast cereals, coffee and its substitutes, baby food.

All food business operators who produce and/or place on the market foods belonging to the cited categories must adopt a set of measures. Revision of contracts for supply of raw material, recipes and manufacturing processes, self-monitoring manuals, labeling and B2B information. In addition to systematic sampling and analysis, to be shared with the health authorities. 

These are Reg. EU 2017/1258 requirements, in a nutshell. (2) With the specific objective of  keeping the levels of acrylamide monitored and reducing them, within the limits of reference provided for each product category. (3) Following, the ABC’s in provisions borne by the Food Business Operators (FBO’s).

1)  Raw potato-based products 

Choice – to be documented – of ‘potato varieties suitable to the type of product and with the lowest level of acrylamideprecursors, such as reducing sugars  (fructose and glucose) and asparagines.’ To be used ‘within the optimum date of storage.’ (4) Storage and transit temperatures, preferably under 6°C, humidity control to prevent sweetening, use of ‘appropriate media’ to prevent germination.

French fries, potato-based products either fried or cooked in the oven  

Potatoes preventive analysis, ‘for example through a frying test, by using a color scale as indicators of a potentially high content in reducing sugars.’ Removal of unripe tubers and cutting scraps. Poaching of ‘potato sticks to eliminate part of the reducing sugars from the external surface.’ Prevention of discoloration and blackening after cooking, avoidance of reducing sugars use for browning. If the oil temperature coming out of the fryer exceeds 175° C, the FBO must present data on risk monitoring.

On the label, ‘recommended methods for the preparation of food products specifying timing, temperature, quantity in cases of oven cooking/deep frying/pan frying preparations’ must be provided.

The B2B information must be validated per type product so to guarantee products with optimal organoleptic characteristics to the lighter between the acceptable colors for a specific cooking method (for example fryer, oven) and a tenor of acrylamide below the level of reference’ set out.

2) French fries to potato slices (chips)

All relates to the cooking method. If ‘the oil temperature coming out of the fryer exceeds 168°, the food business operator shall submit data capable to demonstrate that the content of acrylamide in the finished product is the lowest that can be reasonably obtained’, within the limits defined. The water content after frying must be the highest possible, never below 1%. Where appropriate, ‘select by color (optical and/or electronic  manual) in the production line of french fries (chips) after frying.’

3) Fine bakery wares

On biscuits, treats, toasts, cereal bars, scones, cones, waffles, crumpets and spiced bread – but also crackers, crisp bread and bread substitutes – a primary focus is placed on the farming methods employed by the suppliers. Good Agricultural Practices (GAP’s), in fertilization as well as in protection against fungal infections, ‘in order to avoid elevated levels of asparagines in cereals.’

In the recipe, ammonium bicarbonate ought to be reduced or replaced – partially, at least – with alternative raising agents, such as ‘sodium bicarbonate and acidifying substances’, or ‘sodium bicarbonate and disodium phosphate with organic acids, or related potassium variants’. Carefully, so not to increase the total sodium content. Where possible, ‘fructose or ingredients containing it, such as syrup and honey’ must be replaced ‘with glucose and non-reducing sugars such as sucrose, especially in recipes that include ammonium bicarbonate.’ 

The use of cereals with a lower asparagines content (‘the highest levels can be found in rye and, in descending order, in oat, wheat, maize and rice which presents the lowest levels’) is also to be considered. Finally making sure that ‘ the suppliers of heat-treated ingredients that present an acrylamide formation potential carry out a risk assessment related to acrylamide and implement the necessary mitigation measures.’

In the manufacture, ‘the heat’ is to be applied ‘at a temperature and during a time that allows to reduce more effectively the formation of acrylamide.’ Cooking is performed until it reaches a lighter color, increasing the level of moist of the finished product. Taking also into account that ‘certain ingredients used in the production of fine bakery wares may have undergone heat treatment(for example cereals, nuts or pretreated seeds, dried fruit ect.).’

Labels and B2B information. ‘With regards to the pre-mixtures placed on the market cooked in the home or in food service operations, the Food Business Operators provide their clients with preparation instructions so that levels of acrylamide in finished products are the lowest that can be reasonably obtained and lower than the reference levels’.

4) Breakfast cereals

In supplying agricultural raw materials, attention must be given to the compliance with GAP’s either in fertilization and protection from fungal infections, ‘in order to avoid elevated levels of asparagines in cereals’.

In the recipe and development of new products, it must be kept in mind that ‘maize and rice based products tend to contain less acrylamide compared to products made with wheat, rye, oat and barley.’ Attention also is due when adding ‘reduced sugars (for example fructose and glucose) and ingredients that may contain them (for example honey), bearing in mind (…) that they may serve as precursors for the formation of acrylamide if added in the initial stages of heat treatment’.

In the manufacturing process, ‘the Food Business Operators detect an effective combination of temperature and time of heating in order to minimize acrylamide formation.’ In order to avoid the generation of acrylamide spikes the FBO’s must control temperature, timing and feed rates in the heating process, as to achieve the minimum levels of moist specifically defined for the different categories of finished products. Evaluating the impact on acrylamide levels in rework, o be reduced or eliminated accordingly.

5) Coffee

In the mixture of coffee blends, the FBO’s must assess the acrylamide levels. Taking into account that ‘Robusta beans based products tend to present higher contents of acrylamide with respect to the Arabica beans variation’.

In the roasting process, the FBO’s identify the critical conditions in order to minimize acrylamide formation, introducing their systematic monitoring within the Pre-Requisites Program (PRP’s), which is part of Good Manufacturing Practices (GMP’s). They also examine ‘the option of using asparaginase, if at all possible and effective in reducing the presence of acrylamide’.

6) Cereal-based coffee substitutes (>50%)

Careful attention to GAP’s, as expected for breakfast cereals. Favoring cereals with a lower level of asparagines. Caution in adding reducing sugars and cereals that contain them. When ingredients different from cereals are used, dutiful care is also to be applied. Systematic monitoring of the roasting process, as for coffee.

7) Chicory based coffee substitutes (>50%)

The FBO’s care to cultivate only through a low level of asparagines and make sure that to the growing season no excessive nor delayed nitrogen is applied.’ In the recipe, the use of other coffee substitutes (for ex. chicory fibers, roasted cereals) is conditioned to their demonstrated effectiveness of ‘reducing acrylamide levels in the finished product.’ A systematic monitoring of the roasting conditions in the self-control procedures is also due.

8) Biscuits for early childhood and cereals for infants

GAP’s implementation must be verified, as to avoid a presence of high contents of asparagine. The FBO’s ‘use asparaginase to reduce the content of asparagine in raw flour material’. Which means that, when the conditions do not allow it, they employ ‘raw flour material with a low content of acrylamide precursors, like fructose, glucose and asparagines.’

In the recipe, the use of cereals with a lower content of asparagine must be considered. Without forgetting that the presence of bran requires closer attention. The addition of reducing sugars must be carefully considered, as well as every option aimed to reducing their content in the finished product. Caution in the use of ingredients that have been heat treated, with thorough scrutiny of also those offered by new suppliers. More details following.

During the process, the water content and the acrylamide levels must be monitored in the dry substance. Temperature monitoring has to be included in the HACCP plan.

9) Prune-based baby food

The FBO’s select ‘raw materials with a low level of (…) reducing sugars such as fructose and glucose, and asparagines.’ Verification is due on the GAP’s applied in cereals production. ‘In the purchase contracts of mashed prunes the OSA indicate obligations regarding the granting that, in the production process of mashed prunes, heat treatment regimens have been applied aimed to reduce the presence of acrylamide in such product.’ Temperature monitoring must be focused also on microbiological risks. 

10) Bread

In the supply contracts of raw materials, the FBO’s verify, also through periodic checks, that their direct suppliers respect GAP’s – either in fertilization and protection from fungal infections – ‘in order to avoid high contents of asparagines in cereals.’

In the recipe, ‘they substitute the ingredients that may potentially increase acrylamide levels in the finished product (…); this concerns for instance the use of nuts and seeds roasted at a low temperature rather than a high one.’ Fructose ought to be replaced with glucose, ‘especially in recipes that contain ammonium bicarbonate’ (E503).

In the processing, the FBO’s must extend ‘the time of yeast fermentation’. Furthermore, ‘they ensure that the bread is baked until it reaches a lighter final coloration’. More in general, ‘they reduce the applied heat by optimizing temperature and cooking time, as far as possible’.

Labels and B2B information. The FBO’s ‘provide the instructions for cooking bread when it is finalized at home, in areas predisposed for cooking, in points of sale or food service operations.

Sampling and analyses (Reg. EU 2017/1258, Annex III)

The objective of products sampling and analysis is ‘ensuring the presence of acrylamide and verifying the effectiveness of mitigation measures, so the contents of acrylamide remain constantly lower than the levels of reference’ defined in Reg. EU 2017/1258, Annex IV.

The sampling must be representative of each product – i.e. SKU (Stock Keeping Unit), intended as ‘groups of products with ingredients, recipes, design of process and/or monitoring of identical or similar process, where such elements are able to act on the levels of acrylamide on the finished product’.

Frequency. ‘The food business operators undertake the sampling and analysis on an at least annual basis for the products with known and monitored level of acrylamide.’ On the basis of risk analysis, the FBO’s ‘undertake the sampling and analysis more frequently for the products that may potentially exceed the reference levels.’

The methods of analysis, as well as laboratories accreditation requirements, are defined in Annex III, Part II.

Corrective actions, mitigation measures. If the analytical result (…) shows a product exceeding the reference levels, or containing an amount of acrylamide higher than expected (keeping in mind prior analysis, but lower than the reference levels), the food business operators perform a review of the mitigation measures applied and possibly adopt further measures of mitigation, so to guarantee that the acrylamide content in the finished product is lower than reference levels. This must be demonstrated through a new representative sampling and new analysis, after the introduction of further mitigation measures.’

Information to the competent authorities. ‘The food business operators shall make available each year by request of competent authorities the analytical results obtained from the analysis, along with the description of the analyzed products. The mitigation measures adopted to reduce the contents of acrylamide beneath the level of reference are described in detail for those products that exceed such reference level.

Dario Dongo


(1) Refer to http://eur-lex.europa.eu/legal-content/IT/TXT/HTML/?uri=CELEX:32017R2158&qid=1516272415708&from=EN

(2) See Reg. EU No. 2017/1258, Annex I and II

(3) Refer to Reg. EU No. 2017/1258, Annex IV

(4) In the contracts relating to the supply of potatoes, food business operators should ‘specify the maximum level of reducing sugars and the maximum quantity for bruised, stained or damaged  potatoes.

(5) See Note 3

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Dario Dongo, avvocato e giornalista, PhD in diritto alimentare internazionale, fondatore di WIISE (FARE - GIFT – Food Times) ed Égalité.


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