The ingredients of plant origin, as seen, can perform different functions in the most varied foods. Also that of preserving meat products. A note from the Ministry of Health offers some clarifications in this regard.
Some fibers and plant extracts (in particular, from spinach and leafy vegetables) naturally contain nitrates. Which in turn are transformed into nitrites, which have the function of protecting the processed meats from microbiological contamination (eg botulinum toxin). In place of chemical preservatives, such as potassium nitrite (E 249) and sodium nitrite (E 250). (1)
The Ministry of Health is a pioneer in Europe, in addressing the issue with commendable courage. The General Manager Giuseppe Ruocco - with his own note DGISAN 12.9.17, n. 36275 (see Attachment) - has in fact admitted the use of fibers and plant extracts in the processing of meat products.
The approach is pragmatic and consistent both to the objectives of the Hygiene Package, (2) and to the current evolution of research and development in the meat sector. (3) Under the aegis of improving the characteristics of the products, also thanks to the use of natural and functional ingredients.
In food labeling - specifies the Ministry - it is essential to specify the nature of the plants from which fibers, extracts and concentrates come. (4) And above all, while respecting the basic criteria on fair information practices, (5) they must not be used claim of the type 'without additives', 'without preservatives', 'without nitrites'. Since they are not true or in any case potentially misleading. (6)
The reasoning is crystal clear, the use of ingredients of vegetable origin with specific functions can be admitted, in compliance with the general and specific criteria of food safety and correct information to the consumer. The clean labels they must therefore be complete and truthful. If anything, communicating, where appropriate, the presence of 'only natural preservatives'.
Meanwhile Europe groping in the dark. Consumers ask for 'natural' food, clean labels, thus stimulating the supply of foods without 'E…', with ingredients of vegetable origin. Preservatives and antioxidants, but also coloring foods. This positive evolution of the market, however, is an orphan of rules at EU level. And in the puzzle of national regulations, a country like Germany has come to ban the use of these ingredients on meat products, as they are not authorized as food additives. (7)
(1) The use of nitrites in cooked ham, for example, is foreseen in the specific Ministerial Decree 21.7.05 (as amended by Ministerial Decree 26.5.16). Although its mandatory nature can be doubted, where the same function can be achieved through nitrites of different origins - such as vegetable nitrates - which certainly do not alter the nature of the product with respect to the required requirements.
(2) See reg. CE 852, 853/04 and later. The Hygiene Package focuses on risk analysis, which must form the basis of any provision on food and beverages
(3) Already since 2012, among other things, the European Commission has co-financed the Phytome research project (Phytochemicals to reduce nitrite in meat products). For the precise purpose of identifying the phyto-derivatives useful to replace nitrites. See http://www.phytome.eu/v2/overview.html
(4) In line with the requirements of reg. EU 1169/11, ed
(5) See reg. EU 1169/11, articles 7 and 36
(6) Taking into account, among other things, that some phrases could be qualified as health claim and therefore fall within the scope of reg. CE 1924/06
(7) The Bundesverwaltungsgericht, Federal Administrative Court has recently ruled in this regard. According to him, the ingredients of vegetable origin with a high content of nitrates - used for their preservative and coloring functions - should be subject to specific authorization, pursuant to reg. CE 1333/08. Decision 10.12.15, case BVerwG 3 C 7.14, su http://www.bverwg.de/en/101215U3C7.14.0