The specification of Grana Padano PDO - unlike that of Parmigiano Reggiano PDO (1,2) - admits'the use of lysozyme, except for Trentingrana, up to a maximum of 2,5 g per 100 kg of product' (3).
Lysozyme - in use for several decades to fight bacteria Clostridium spp. and other microbiological contaminations - it has always been indicated as a preservative, in cheeses where its use is allowed.
The word 'preservative' was however excluded, only from the labels of Grana Padano PDO. Following a circular from the Ministry of Health, challenged by the Lazio Regional Administrative Court in the summer of 2018. Decision still pending.
Lysozyme in Grana Padano, preservative or technological adjuvant?
The Ministry of Health - with circular 8.5.18, signed by the then DG for Hygiene and Food Safety Gaetana Ferri - had expressed a favorable opinion on the Consortium's request to reclassify lysozyme, 'from preservative additive to adjuvant / processing aid, in Grana Padano PDO cheese with a maturation period greater than or equal to nine months'. (4)
The Consortium of Grana Padano PDO thus ordered its members - with circular letter no. 14.9.18, signed by its DG Stefano Berni - who 'the word CONSERVANT will have to disappear when stocks are exhausted'' from all labels and informative material (e.g. flyers, brochure) on Italian cheese as well as the best-selling PDO in the world. (5)
Grana Padano, with or without a 'preservative'?
The circular of the general manager Stefano Berni to the members of the Consortium of Grana Padano DOP - after diktat to eliminate 'the word PRESERVING' - however, weakened the message, as if to foretell possible disputes.
'If you have any objections outside Italy regarding the elimination of the term "preservative", the Ministry has assured us that it will defend this position.
It invites itself at the same time not to emphasize in publications (flyers, brochures, web, etc.) the absence of the preservative, simply eliminating the word '.
Preservative and adjuvant, what are the differences?
The reg. CE 1333/08 relating to food additives - laying down uniform rules to be valid, in its identical text, in all EU Member States (6) - provides the following definitions:
"Food additive". ‘Any substance usually not consumed as a food in itself and not used as a characteristic ingredient of food, with or without nutritional value, the intentional addition of which to food for a technological purpose in manufacturing, processing, preparation, treatment, packaging, in the transport or storage of the same, has or can presumably have the effect that the substance or its by-products become, directly or indirectly, components of such foods. (...) ' (article 3.2.a),
«Technological adjuvant». 'Any substance which:
i) is not consumed as a food in itself,
ii) it is intentionally used in the transformation of raw materials, foods or their ingredients, to exercise a specific technological function in the processing or transformation; And
iii) may give rise to the presence, unintentional but technically unavoidable, of residues of that substance or its derivatives in the finished product, provided that these residues do not pose a health risk e they do not have technological effects on the finished product'(article 3.2.b).
Additive or adjuvant, who decides?
The decision approximately 'the compliance of a given substance with the definition of a food additive in Article 3'' is the responsibility of the European Commission, in agreement with the Member States' representations at the PAFF Committee (Plants, Animals, Food and Feed). (7)
The so-called procedure of regulation - expressly established by reg. CE 1333/08 in case of doubts about the qualification of a substance as an additive (or adjuvant) - excludes any autonomous decision-making power of the Member States. For the express purpose of preventing obstacles to the free movement of goods in the internal market (Treaty for the Functioning of the European Union, TFEU, article 28).
Appeal to the Lazio Regional Administrative Court on lysozyme in Grana Padano
The 11.9.18 the Consorzio del Parmigiano Reggiano DOP presented an appeal to the Lazio Regional Administrative Court for the annulment of the Min. Sal. 8.5.18 (Lysozyme in Grana Padano). As well as an unknown opinion of the Superior Health Council, deduced by the ministry in support of its circular. (8) And an amazing note 20.7.18 with which the health administration denied the Consortium access to the proceedings, with all due respect to the then 28-year-old Bassanini law.
In law, the appellant denounced the violation of the European regulations of the sector (reg. CE 1331/08 and 1333/08, reg. UE 1129/11), highlighting the incompetence of the Ministry of Health to express itself on an interpretation of the European legislation that it is instead subject to a specific EU procedure, as seen in the paragraph above. In addition to contesting the refusal of access to the documents to the Consortium of Parmigiano Reggiano PDO, whose legitimate interest in knowing them is clear. (9)
Lysozyme, why is it found in Grana Padano, Provolone and Asiago, but not in Parmigiano Reggiano?
The milk used to produce Parmigiano Reggiano DOP it comes from cows fed exclusively on fresh fodder and hay. Other PDO cheeses - such as Grana Padano and Provolone, Asiago and Montasio - instead allow the use of milk from cows fed with the most practical and economical silage. Essential for farmers forced to supply milk at prices close to production costs. (9) Silages are fodder stored in silos (eg silomais) in an acidic environment where 'good' microorganisms (lactobacilli), but also 'unwanted' ones (clostridia) ferment.
Unwanted microorganisms (or 'anticaseari'), once passed in the milk, and cause a gas-producing fermentation of the cheese during maturing. Thus the structure of the dough is altered, unpleasant aromas and smells are formed, up to the breaking of the crust and the possible bursting of the form. Lysozyme is then added to stop clostridia in the milk of animals fed silage. It took the place of ant aldehyde, a powerful antiseptic, however, which proved to be potentially carcinogenic and banned in 1991. (10)
Lysozyme, strengths and weaknesses
'It is one of the few substances of animal origin ad antibiotic activity; its action consists in attacking the bacteria wall making them more vulnerable and limiting their capacity to develop. ' (11)
Lysozyme is a linear polypeptide consisting of 129 amino acids, obtained from chicken egg white. It is effective in the extermination of 'anticasearic' bacteria, but:
- nullifies the microbial heritage that characterizes raw milk cheeses and contributes, among other things, to strengthening the microbiota (thus also the immune system),
- affects the consumption of cheese by consumers with egg allergy, which is among the most frequent in the European population.
'Recent results (Marseglia et al. 2013) indicate that the intake of cheese containing lysozyme, at 12 months of maturation, created in 5 lysozyme-sensitive children out of 21 children, immediate and late adverse reactions such as itching, abdominal pain, vomiting, nausea, dermatitis, rhinitis, bronchial asthma, urticaria ' (12,13)
What link with the territory?
'The introduction of silage forage represented an innovative fact of extraordinary importance and introduced a huge problem in the production of grana cheese never known before, destroying an old bond with the territory, indeed establishing a strong negative bond with it, for which today wanting to believe that there is a good bond is amateur fantasy or will to pursue ridicule ...
Today it is used, for example in zone A (silage), the additive lysozyme because the milk is too polluted by spores of the genus Clostriduim…. can it be said that it is according to tradition and that it is in the context of fair and constant uses? ... What is the DOP product? ... Can a cheese produced with an additive be recognized as such?(14)
Can Lysozyme in Grana be avoided?
The professor. Gianfranco Piva coordinated the researchers of the Catholic Universities of Piacenza and Cremona, of Milan and of Parma, in the research project 'Improvement of Grana Padano PDO cheese: production tests without lysozyme (GP-Lfree)'. Where over the course of three years it has been shown that it is possible to produce Grana Padano without lysozyme, in compliance with the specification.
'All operators in the supply chain they must be aware that the application of some tricks, even relatively simple ones, allow to decisively improve the quality of cheese production and to produce without lysozyme.(13)
Areas of improvement they have therefore been defined at each stage. Crops and techniques of forage conservation, structures, stables, diet administration techniques, individual milk production, milking methods, pre- and post-milking hygiene interventions, ensilage-desilage temperatures and diet administration via unifeed, breeding hygiene and milking.
Strategic opportunities
The research project above outlines the reasons for eliminating lysozyme in cheese making:
a) a health guarantee "Absolute" towards all consumers, even those in pediatric age sensitive to food allergies to egg proteins,
b) an added value to the image of the product, which will no longer have to declare the presence of lysozyme on the labeling,
c) a return with the original Grana Padano, produced with the sole use of milk, rennet and salt, without any other added substance. ' (13)
Provisional conclusions
The Coldiretto Consortium del Grana Padano PDO has played its cards on an ad hoc ministerial derogation. With the purely cosmetic goal of deleting the word 'preservative' from the labels, before those 'lysozyme from EGG'. (15)
Waiting for the TAR Lazio is ruling on an incontrovertible question of law (albeit exposed in a somewhat feeble appeal), the social partners concerned - including consumer associations - should act at EU level.
This anomaly Italica, however, underlies a much more serious one. The inability to manage a supply chain policy capable of remunerating farmers' investments to improve the product, as some already do very well. (16) Discard rather than hide the preservative.
Dario Dongo
Footnotes
(1) Parmigiano Reggiano DOP. Production regulations. https://www.parmigianoreggiano.com/static/118c3adbbfba7f61f536bb418a820af4/c40fd4e7eff4f555239d98c418a9f918.pdf
(2) Dario Dongo, Silvia Giordanengo. Parmigiano Reggiano, new regulations for the king of raw milk cheeses. GIFTS (Great Italian Food Trade). 8.2.21/XNUMX/XNUMX, https://www.greatitalianfoodtrade.it/etichette/parmigiano-reggiano-nuovo-disciplinare-per-il-re-dei-formaggi-a-latte-crudo
(3) Grana Padano PDO. Production regulations. https://www.granapadano.it/public/file/Disciplinare-produzione-Grana-PadanoDOPNov19-38346.pdf NB: the TrentinGrana supply chain does not allow the feeding of cows with silage or the use of lysozyme in cheese making
(4) See also Min Sal. National Committee for Food Safety, opinion 17.7.08 no. 1. Lysozyme in Grana Padano. https://bit.ly/3wlGJfA
(5) Dario Dongo. Grana Padano PDO, the growth of the global leader continues. GIFTS (Great Italian Food Trade). 5.9.19/XNUMX/XNUMX, https://www.greatitalianfoodtrade.it/mercati/grana-padano-dop-prosegue-la-crescita-del-leader-globale
(6) EC Reg. 1333/08, relating to food additives. Consolidated text as of 23.12.20 on https://eur-lex.europa.eu/legal-content/IT/TXT/?qid=1625419711171&uri=CELEX%3A32008R1333
(7) EC Reg. 1333/08. Article 19, Interpretation decisions, paragraph 1, letter 'c'
(8) The Superior Health Council (CSS), it should be remembered, is a body that assists the Min. Sal. when assessing the risks associated with food or other consumer products. His opinions have no legal value
(9) Dario Dongo. Geographical indications, 75 billion euros in the EU. The database and the protections that are missing. GIFT (Great Italian Food Trade). 21.2.21/XNUMX/XNUMX, https://www.greatitalianfoodtrade.it/mercati/indicazioni-geografiche-75-miliardi-di-euro-in-ue-il-database-e-le-tutele-che-mancano
(10) Augustine Macrí. The 'Grana' of lysozyme. Food safety, blog of the National Consumers Union. 9.1.19, https://www.sicurezzalimentare.it/carni/la-grana-del-lisozima/
(11) Modena Local Health Authority. Lysozyme: preservative, processing aid or additive? Food & Health. 13.5.19, https://www.alimenti-salute.it/rassegna-stampa/lisozima-conservante-coadiuvante-tecnologico-o-additivo
(12) Symptoms appeared when the IgE level exceeded 7 kU / L. Aged to 24 months, probably due to increased proteolysis, only 1 in 21 children showed an adverse reaction. Extract from the report in subsequent note 13
(13) ERSAF (Regional Agency for Agricultural and Forestry Services), Lombardy Region (2015). Improvement of Grana Padano PDO cheese, production tests without lysozyme. Research report. https://www.ersaf.lombardia.it/it/attachments/file/view?hash=bf45af46f9f51a2e0ed824700d984623&canCache=0
(14) Bottazzi V. (1998). Grana Padano: tradition or innovation? The agricultural informant. 1998, 40, 27-29
(15) In both cases of classification as a preservative or processing aid, the name of the lysozyme substance and the UOVO allergen must in any case be reported on the label (EU regulation 1169/11, article 9.1.c)
(16) Dario Dongo. Latteria San Pietro, Grana Padano 'Selection from hay' in a digital experience. GIFT (Great Italian Food Trade). 11.6.20/XNUMX/XNUMX, https://www.greatitalianfoodtrade.it/innovazione/latteria-san-pietro-il-grana-padano-selezione-da-fieno-in-un-esperienza-digitale
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
