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CO2 for carbonating water and tapping drinks, possible food safety risks

A company leader in the supply of food gases in Italy, it signals public health risks linked to the illegal distribution of CO2, for the carbonation of water and the tapping of beverages.

The complaint was presented to some Regions, the Higher Institute of Health, the Competition and Market Authority (AGCM, Antitrust), EFSA (European Food Safety Authority). (1)

CO2, uses in the agri-food chain

CO2 - carbon dioxide or carbon dioxide - is an inert, odorless and colorless gas, naturally present in the atmosphere in limited concentrations. It is used in various phases and processes, throughout the agri-food chain:

- greenhouse agriculture (and floriculture) for carbon fertilization and weed control (as an alternative to the use of various chemical substances, e.g. methyl bromide, phosphines, insecticides),

- extraction of substances (e.g. caffeine, CBD) from vegetable raw materials (supercritical CO2),

- cold pasteurization (DPCD, Dense Phase Carbon Dioxide), in the liquid state or supercritical,

- water purification, for the purpose of recarbonation,

- refrigerated transport, production of dry ice, cryogenic freezing (in liquid form, together with nitrogen),

- modified atmosphere packaging (Modified Atmosphere Packaging, MAP), mixed with other gases, for extend the shelf life of food.

CO2, food ingredient or additive

Carbon dioxide is used as an ingredient or food additive (E 290), as appropriate:

- in the beverage industry, for their carbonation,

- in communities (bars, restaurants, canteens, cateringfood truck), for adding to the water to be served not pre-packaged, for tapping beer and soft drinks. (2)

CO2 outlaw, the complaint

The phenomena reported relate to the refilling of CO2 cylinders by subjects not registered as food sector operators (FBO) at the ASL. Instead, as a duty, to guarantee public health and the effectiveness of official public controls which must be based precisely on the census of FBOs and the traceability of foodstuffs. (3)

The situation, where ascertained, it is very serious since these subjects are obviously not able to guarantee compliance with food safety requirements. With regard in particular to:

- self-control systems and procedures (good hygiene practices, HACCP), (one)

- purity of gases intended for human consumption. Which must be considered as food, as it is intended to be ingested, pursuant to General Food Law(5)

- materials and objects in contact with food (MOCA). (6)

Carbonated water with fire-fighting CO2?

Carbonated water in some bars and restaurants, according to what has been reported, it would therefore be achieved through the supply of carbon dioxide not for food use. That is, by refilling the cylinders with gas for technical use such as that used for fire-fighting cylinders. Whose price, ca va sans dire, is much lower precisely because the operating costs of gas without guarantees of quality and purity are lower. (7)

The health risks public associated with the food use of carbon dioxide that does not comply with the relevant legal requirements derive from several factors:

- impurities. The CO2 used in fire extinguisher recharging centers does not meet the purity criteria established to guarantee food safety,

- contaminations. Cylinders for uses other than food do not guarantee the protection of the gas from migration (of particles of the materials used in the containers) and external contamination.

Rust out!

The cylinders for technical uses they do not have the safety valve which, in allowing the gas to escape, prevents the entry of other substances into the container. Thus, with the progressive emptying, the cylinder incorporates air which, once inside, creates condensation and can form liquid. Which mixes with the gas and, in case of defective sandblasting of the inside of the container, can cause the formation of rust.

Rust of the malfeasance must be removed from the Italian agri-food chain. The control authorities must carry out sweeping checks on the traceability of gas supplies to public establishments and canteens, trace the criminals and ensure their punishment. Without neglecting Responsibilities - also in criminal matters - of the owners of public establishments who have used dangerous CO2.

for further theebook 'Food safety, mandatory rules and voluntary standards '', its https://www.greatitalianfoodtrade.it/libri/sicurezza-alimentare-regole-cogenti-e-norme-volontarie-il-nuovo-libro-di-dario-dongo

Dario Dongo


(1) The complainants may have overlooked the magister magistrorum, the Ministry of Health, which is responsible for coordinating and scheduling official public controls on the agri-food chain in Italy. As well as participation in the European risk analysis network. The Lazio Region will still have taken care to notify the ministry, hopefully
(2) Legislative Decree 231/17, in implementing the reg. EU 1169/11 (Food Information Regulation) and to introduce specific sanctions, prescribes the opposition of a special sign on the tapping system or in the immediate vicinity. Prescribing to use the name 'treated and sparkling drinking water', in the event of its administration in the non-prepackaged state. V. https://www.greatitalianfoodtrade.it/etichette/alimenti-sfusi-e-preincarti-collettività (3) (3) EC Reg. 852/04, so-called Hygiene 1, art. 6
(4) EC Reg. 852/04, articles 3-5
(5) EC Reg. 178/02, article 2 (Definitions)
(6) EC Reg. 1935/04. In this regard, the following are noted:
- the recent modification of the requirements for stainless steel (see https://www.greatitalianfoodtrade.it/imballaggi/acciaio-inox-nei-moca-decreto-ministero-salute-e-lacune-in-europa),
- the criticality of toxic substances in MOCAs (see https://www.greatitalianfoodtrade.it/imballaggi/tossicità-chimica-dei-materiali-a-contatto-con-gli-alimenti-appello-dei-ricercatori)
- the snail reform of MOCAs in the EU 
(7) The purity requirements of CO2 for food use (additive E290) are defined in terms of purity (99%), CO (<10 ppm), NVOC (0,1 mg / l), passing JEFCA test on reducing agents (H2S, etc.) and acidity. See EU Reg. 231/2012, which establishes the specifications of the food additives listed in Annexes II and III of Regulation (EC) no. 1333/2008
(8) In clear violation of reg. CE 1333/08, article 4.1

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Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.

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