Stricter standards are coming for the use of nitrites (E 249–250) and nitrates (E 251–252) in processed meats, fish, and cheese. Through Regulation (EU) 2023/2108, the European Commission amended the annexes to the food additives legislation, effective 29 October, 2023. Excessive intake of nitrite and nitrate additives can pose potential health risks. All food products must comply with these stricter limits within two years. Does this legislation apply to your products? If so, you need to start reformulating your recipes now. The impact of this change is particularly significant for the processed meat and butchery sector. In this article, Max van Leeuwen, Director at Eurofins Food Safety Solutions, interviews Andrea Faré, Secretary of Legislation & Food Safety at the VNV (Association of the Dutch Meat Processing Industry).
Regulation (EU) 2023/2108 took effect on October 29, 2023. A transitional period of 12 or 24 months applies, depending on the product category. What is the transition period for processed meats?
Faré: “For processed meats, a 24-month transitional period applies. The tables specifying the maximum allowable levels also list potential product exemptions and restrictions. The phrase ‘similar products’ is frequently used here. Which specific items the European Commission includes under this term beyond those explicitly mentioned in the annex remains a matter of debate. The European Commission may provide further clarification on this scope.”
Faré: “We advise producers to implement the new nitrite and nitrate standards into their production processes as soon as possible. This avoids last-minute surprises and ensures you are ready before the NVWA begins enforcing the stricter limits.” Excessive intake of these additives carries potential health risks. For example, the Netherlands Nutrition Centre (Voedingscentrum) advises the following regarding processed meats: ‘Processed meats are not included in the Wheel of Five because the meat is processed. Processed meat is associated with stroke, type 2 diabetes, and colorectal cancer. The recommendation is to limit consumption of processed meats such as sausages, ham, and pâté.’
Faré: “The VNV firmly believes that, despite these stricter limits, the public debate regarding the use of nitrites and nitrates in processed meats (both in the Netherlands and across Europe) is far from over.” Rather than waiting for the outcome of this societal discussion, the VNV and its members proactively launched a collaborative project with Wageningen University & Research (WUR) to further reduce or completely phase out the use of nitrites and nitrates wherever feasible across all processed meat categories. Initial results are expected within a year.
Van Leeuwen addresses this: “Nitrites and nitrates inhibit the growth of certain foodborne pathogens that can proliferate at chilled temperatures, such as Listeria monocytogenes, non-proteolytic Clostridium botulinum, and Bacillus cereus. Predictive models, risk assessments, and challenge tests may need to be updated to account for these formulation changes. In short: revalidate product shelf life when reducing nitrites and nitrates, and investigate the microbiological impact beforehand to avoid surprises.”
Van Leeuwen: “You validate the shelf life of your product using predictive modelling and challenge tests. Challenge testing is generally preferred because predictive mathematical models are often insufficiently validated for the specific inhibitory mechanisms of nitrite against various pathogens or across diverse product matrices. Tip: Define or formulate a worst-case product for a single product category or across multiple groups. Predictive models can help you identify this worst-case baseline using available parameter data. Next, evaluate the findings to assess pathogen growth potential. You can then run a challenge test on the final worst-case product to validate both your product and the predictive model. This reduces the total volume of testing required and saves costs.”