EU LAW - REGULATIONS

1. Legal Framework

Beverage ingredients in the European Union must comply with multiple regulatory sources:

• Regulation (EC) No 178/2002 – General Food Law (safety, traceability, responsibility)

• Regulation (EC) No 1333/2008 – Food additives

• Regulation (EC) No 1334/2008 – Flavourings and certain food ingredients with flavouring properties

• Regulation (EU) No 1169/2011 – Food information to consumers (labeling)

• Regulation (EC) No 1925/2006 – Addition of vitamins, minerals, and other substances

• Novel Food Regulation (EU) 2015/2283 – For ingredients without a history of consumption in the EU before May 1997

2. Ingredient Compliance Principles

• Food-Grade Only – All raw materials must be approved for use in food & beverages

• Positive Lists – Only additives/flavours listed in EU Annexes are permitted

• Maximum Levels – Follow EU-defined limits for:

  • Sweeteners (e.g., aspartame, stevia, sucralose)

  • Caffeine (especially in energy drinks)

  • Preservatives (e.g., sodium benzoate, potassium sorbate)

  • Colourants (natural & artificial, e.g., E-numbers)

• Nutrient Addition Rules – Vitamins/minerals can be added only if listed in Regulation (EC) No 1925/2006 with defined forms and levels

3. Prohibited & Restricted Substances

• Banned in the EU (examples): Cyclamate in certain beverages, brominated vegetable oil (BVO), certain synthetic colors in children’s drinks

• Restricted – Some herbal extracts and botanicals require safety evidence or novel food approval

• Novel Foods – Ingredients not consumed in the EU before 1997 must be authorized under the Novel Food Regulation

4. Flavouring & Additives

• Must be food-grade and listed in:

  • EU Union List of Flavourings (Annex I of Regulation 1334/2008)

  • EU Union List of Food Additives (Annex II of Regulation 1333/2008)

• Natural flavour claims → at least 95% of the flavouring component must come from the named source (per EU rules)

5. Labeling Requirements

• Full Ingredient List in descending order by weight at the time of manufacture

• Allergen Declaration (Annex II of EU 1169/2011) – e.g., soy, milk, nuts

• Quantitative Ingredient Declaration (QUID) – if highlighted in product name/label

• Additive Identification – state category + E-number (e.g., “Preservative: Potassium Sorbate (E202)”)

6. Traceability & Documentation

• Maintain supplier specification sheets for each ingredient

• Keep Certificates of Analysis (CoA) for every batch

• Keep EU compliance statements from suppliers

• Ensure full traceability: one step back (supplier) + one step forward (customer) as required by EC 178/2002

7. Best Practices

• Source from EU-approved suppliers or suppliers with EU-compliant documentation

• Validate caffeine, sweetener, and preservative levels via laboratory testing

• For new botanicals or functional ingredients → verify novel food status before formulation

• Periodically review EU regulations for updates (they change frequently)