The European Commission, DG Sante, is working with the Member States on the possible reduction of the limits of nitrites allowed as preservative additives in meat products.
Natural preservatives today even allow you to eliminate nitrites and nitrates, but the LOBBY industrialists from Central and Northern Europe insist on boycotting them, including through legislative measures and following the best practices.
In the meantime, Denmark has received the green light from Brussels to the national technical standard that establishes nitrite limits lower than those in force in the EU. The ABC to follow.
A) NITRITES AND NATURAL PRESERVATIVES
A.1) Nitrites in meat, a tradition of safety
The 'nitrites' issue it is delicate, as it focuses on food safety and consumer health:
- excessive exposure to nitrites and nitrates (also present in the waters), on the one hand, is related to some health risks. And it is therefore useful to reduce their use in food production,
- the microbiological safety of food, on the other hand, must always be guaranteed. With particular regard, in meat products, to the risk of proliferation of a highly pathogenic bacterium, the Clostridium botulinum(1)
- Nitrites are traditionally used effectively, as preservative additives, on those meat-based products which, due to their humidity (eg cooked hams, mortadella) or environmental and production contexts, are exposed to the risk of botulinum.
A.2) Natural preservatives, 'without nitrites'
The IARC (International Agency for the Research on Cancer), in 2018, reassessed the safety of nitrites in food. (2) Classifying nitrosamines, which are formed by the reaction of nitrites with secondary amines such as meat proteins, among potential carcinogens. As confirmed in the same regulation (EU) 1129/11, al considering 6.
Natural preservatives they have therefore been identified, developed and successfully applied to various meat products. Soon leaving aside nitrates, of which vegetables are rich, as they themselves turn into nitrites. Other phytocompounds, in special mix, on the other hand, they hit the target (3,4,5,6). Their use is hindered by protectionist measures that Germany has tried to impose throughout the EU, (7) but not also in Italy and France. (8)
B) NITRITES. LIMITS IN THE EU, WORK IN PROGRESS
B.1) EC Reg. 1333/08, current maximum doses of nitrites
The reg. CE 1333/08 - relating to food additives (9) - indicates the different categories of meat products where the use of sodium and potassium nitrites (E250, E249) is permitted, with the respective maximum doses.
- meat products in general, 150 mg / kg,
- sterilized meat products, 100 mg / kg,
- traditional meat products (cat. 08.2.4), obtained by:
- salting with immersion in brine containing nitrites and / or nitrates, salt and other components (cat. 08.2.4.1. See notes 10, 12), from 50 to 175 mg / kg,
- dry salting (cat. 08.2.4.1. See notes 11, 12), same as cs
B.2) Reduction of maximum levels of nitrites, work in progress in Brussels
France is the leader of an initiative which aims to reduce the maximum levels of nitrites on meat products in the EU. Italy - a leading player in the production of PDO hams without nitrites, as well as cured meats with natural preservatives - fully supports the initiative, instead opposed by Germany and Spain who would like to maintain the status quo, in the name of saving on production costs.
The chart of the new limits under discussion, hereinafter.
B.3) Nitrosamines, carcinogenicity and genotoxicity. EFSA and DTU assessments
EFSA (European Food Safety Authority), commissioned by the European Commission to re-evaluate the safety of nitrites as food additives, in 2017 declared the dangerousness of non-volatile nitrosamines in meat products only. (13)
The Danish National Institute of the power supply at the DTU (Technical University of Denmark) has instead demonstrated with its own scientific studies the carcinogenicity and genotoxicity also of volatile nitrosamines. Which can also be formed by adding nitrites to meat products.
C) LESS NITRITES, THE DANISH EXAMPLE
C.1) Reduction of nitrites in Denmark
Already in the 2015 Denmark has established a limit of 249mg / kg with regard to the addition of potassium nitrite (E 250) and sodium nitrite (E 60) to products of animal origin to be produced on its territory. That is, up to 3-4 times lower than those in force in the EU. (14) The national technical standard - to be applied also to products arriving from other countries (European and non-European) - had been duly notified to the European Commission, which had already approved it with EU decision 2018/702.
the 6.11.20 Denmark notified Brussels of a draft decree aimed at extending the effectiveness of the above measures. By attaching the supporting data:
- risk assessment. Formation of carcinogenic nitrosamines in meat products with the addition of nitrites, consequent need to reduce consumer exposure to these substances, suitability of lower dosages to control botulinum contamination, (15)
- free movement of goods. The application of stricter limits in Denmark has not hindered the sales on its Danish market of products from other member countries with nitrite residues adequate to its rules. Indeed, these sales have even increased in the 2017-2019 period.
C.2) Green light from Brussels
Given act of the above, the Commission, by decision (EU) 2021/741, authorized Denmark to maintain the previously approved national provisions for a further three years. (16) The positive comments from Finland are noted, which acknowledged this approach the merit of protecting the risks associated with excessive nitrite intake, while ensuring adequate consumer protection from food-borne diseases such as botulism.
EFSA moreover, it had established an admissible daily intake (ADI) of 0,07 mg of nitrite ions / kg of body weight. Clarifying that - when all sources of dietary exposure to nitrite are considered (food additives, natural presence and contamination) - the ADI is exceeded in infants, young children, children on average exposed and people of all age groups. highly exposed. (13)
Provisional conclusions
EFSA assessments attribute to food additives a contribution of approximately 17% (1,5-36,0%) of the overall dietary exposure to nitrites. A non-marginal share, taking into account that nitrosamines - especially exogenous ones, triggered by additives - are correlated with colorectal cancers and nitrites are correlated with gastric neoplasms.
The European Commission itself completed a monitoring of the average levels of nitrites added to meat products in the Member States, based on questionnaires (inevitably exposed to the risk of 'minimalist' responses). The results were always below the EU limits, as foreseeable, but above the thresholds established in Denmark (as expected).
Pending the reduction of limits EU, consumers can exercise their power by always choosing products 'without nitrites', that is 'with natural preservatives'. So that the offer of the products on the shelf changes accordingly.
Dario Dongo and Andrea Adelmo Della Penna
Footnotes
(1) Silvia Bonardi, Dario Dongo. Botox, a dangerous bacterium to keep away. GIFTS (Great Italian Food Trade). 19.7.18/XNUMX/XNUMX, https://www.greatitalianfoodtrade.it/salute/botulino-un-batterio-pericoloso-da-tenere-alla-larga
(2) IARC (2018). Ingested Nitrate and Nitrite, and Cyanobacterial Peptide Toxins. IARC Monographs on the Evaluation of Carcinogenic Risks to Humans Volume 94. ISBN 978-92-832-1294-2. https://publications.iarc.fr/112
(3) Dario Dongo. Natural preservatives in meat. GIFTS (Great Italian Food Trade). 6.11.17/XNUMX/XNUMX, https://www.greatitalianfoodtrade.it/etichette/conservanti-naturali-nelle-carni
(4) Galiano Quartaroli. Antimicrobials from plant waste, University of Parma patent. GIFTS (Great Italian Food Trade). 5.7.19/XNUMX/XNUMX, https://www.greatitalianfoodtrade.it/tecnologia-alimentare/antimicrobici-da-scarti-vegetali-brevetto-università-di-parma
(5) Marta Strinati. Natural preservatives in meat, prickly pear. University of Catania study. GIFTS (Great Italian Food Trade). 23.12.19/XNUMX/XNUMX, https://www.greatitalianfoodtrade.it/tecnologia-alimentare/conservanti-naturali-nelle-carni-il-fico-d-india-studio-università-di-catania
(6) Salvatore Parisi, Dario Dongo, Carmelo Parisi. Resveratrol, current knowledge and perspectives. GIFTS (Great Italian Food Trade). 27.10.20/XNUMX/XNUMX, https://www.greatitalianfoodtrade.it/integratori/resveratrolo-conoscenze-attuali-e-prospettive
(7) Dario Dongo. Plant extracts in meat, short circuit in Europe. GIFTS (Great Italian Food Trade). 8.5.19/XNUMX/XNUMX, https://www.greatitalianfoodtrade.it/consum-attori/estratti-vegetali-nelle-carni-cortocircuito-in-europa
(8) Vegetable nitrates, which labels? The lawyer Dario Dongo answers. DO (Food and Agriculture Requirements). 4.3.18/XNUMX/XNUMX, https://www.foodagriculturerequirements.com/archivio-notizie/domande-e-risposte/nitrati-vegetali-quali-etichette-risponde-l-avvocato-dario-dongo#
(9) EC Reg. 1333/2008, relating to food additives. Consolidated text as of 8.8.21 on https://eur-lex.europa.eu/legal-content/IT/TXT/?uri=CELEX%3A32008R1333&qid=1633166689673. See of him All. II, Part E, items 08.2, in reg. EU 1129/11 on https://bit.ly/3A16C6o
(10) Ex. cured tongue, kylmâsavustettu poronliha / kallrökt renkött, Wiltshire bacon, Wiltshire ham, entremeada, entrecosto, chispe, orelheira, cabeca - salgados, toucinho fumado, bacon, filet de bacon, rohschinken, nassgepökelt and similar products
(11) Ex. dry cured bacon, presumed, presumed from pa and pair of loin and similar products. The nitrate limits, up to 250 mg / kg, are then provided for jamon curado, paleta curada, lomo embuchado y cecina, jambon sec, jambon sel, rohschinken, trockengepökelt and similar products
(12) NB: These use limits are defined in terms of maximum residue levels on finished products
(13) EFSA Panel on Food Additives and Nutrient Sources added to Food (ANS). Re-evaluation of potassium nitrite (E 249) and sodium nitrite (E 250) as food additives. EFSA Journal 2017; 15 (6): 4786. https://doi.org/10.2903/j.efsa.2017.4786
(14) Denmark, decree 4.9.15 no. 1044, as amended by the subsequent decree 30.10.18 n. 1247. The table with the various limits, which on some products can reach 150 mg / kg, is given in considering 13 to EU decision 2021/741 (see note 16)
(15) Cases of botulism due to the consumption of meat and derivatives have been absent in Denmark since the 80s. Italy, on the other hand, is the first country in the EU for the prevalence of botulism. V. Silvia Bonardi, Dario Dongo. Botulism in Italy, beware of homemade preserves. GIFT (Great Italian Food Trade). 29.4.20/XNUMX/XNUMX, https://www.greatitalianfoodtrade.it/sicurezza/botulismo-in-italia-attenzione-alle-conserve-fatte-in-casa
(16) Commission Decision (EU) 2021/741 5.5.21 concerning the national provisions notified by Denmark concerning the addition of nitrites to certain meat products. EUR-Lex, https://eur-lex.europa.eu/eli/dec/2021/741/oj/ita
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
Graduated in Food Technologies and Biotechnologies, qualified food technologist, he follows the research and development area. With particular regard to European research projects (in Horizon 2020, PRIMA) where the FARE division of WIISE Srl, a benefit company, participates.
