The European Commission, DG Sante, is working with member states on the possible reduction of the limits of nitrites allowed as preservative additives in meat products.
Natural preservatives today even make it possible to eliminate nitrites and nitrates, but industrial lobbies in Central-Northern Europe insist on boycotting them, including through ad hoc legislative measures.
Denmark, meanwhile, has received the green light from Brussels for a national technical standard setting lower nitrite limits than in the EU. ABC to follow.
(A) NITRITES AND NATURAL PRESERVATIVES
A.1) Nitrites in meat, a tradition of safety.
The ‘nitrite’ issue is sensitive, as it revolves around food safety and consumer health:
– Excessive exposure to nitrites and nitrates (also found in water), on the one hand, is correlated with 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 special regard, in meat products, to the risk of proliferation of a highly pathogenic bacterium, Clostridium botulinum, (1)
– nitrites are traditionally used effectively as preservative additives on those meat products that, because of their moisture content (e.g., cooked hams, mortadella) or environmental and production contexts, are exposed to botulinum risk.
A.2) Natural preservatives, ‘nitrite-free‘
The IARC(International Agency for the Research on Cancer), in 2018, re-evaluated the safety of nitrites in food. (2) Ranking nitrosamines, which are formed by reaction of nitrites with secondary amines such as meat proteins, among potential carcinogens. As confirmed in Regulation (EU) 1129/11 itself, in Recital 6.
Natural preservatives have therefore been identified, developed and successfully applied to various meat products. Soon leaving aside nitrates, in which vegetables are rich, as they themselves turn into nitrites. Other phytocompounds, in appropriate mixes, have instead hit the target (3,4,5,6). Their use is being hindered by protectionist measures that Germany has tried to impose throughout the EU, (7) but not including Italy and France. (8)
(B) NITRITES. LIMITS IN EU, WORK IN PROGRESS
B.1) Reg. EC 1333/08, current maximum doses of nitrite
Reg. EC 1333/08 – on food additives (9)-indicates the different categories of meat products where the use of sodium and potassium nitrites (E250, E249) is permitted, with their 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 by immersion in brine containing nitrites and/or nitrates, salt and other components (cat. 08.2.4.1. See notes 10, 12), 50 to 175 mg/kg,
– Dry salting (cat. 08.2.4.1. See notes 11, 12), idem c.s.
B.2) Reducing maximum nitrite levels, work in progress in Brussels.
France is spearheading an initiative to reduce maximum nitrite levels on meat products in the EU. Italy – a leading player in the production of nitrite-free PDO hams, as well as cured meats with natural preservatives – fully supports the initiative, which is instead opposed by Germany and Spain, which would like to maintain the status quo, under the banner of saving on production costs.
The table of new limits under discussion, below.
B.3) Nitrosamines, carcinogenicity and genotoxicity. EFSA and DTU evaluations.
EFSA(European Food Safety Authority), which was mandated by the European Commission to re-evaluate the safety of nitrites as food additives, had declared only non-volatile nitrosamines to be dangerous in meat products in 2017. (13)
The Danish National Food Institute at DTU(Danmarks Tekniske Universitet), on the other hand, has demonstrated through its scientific studies that volatile nitrosamines are also carcinogenic and genotoxic. Which can also be formed by addition of nitrites to meat products.
(C) LESS NITRITE, THE DANISH EXAMPLE
C.1) Nitrite reduction in Denmark.
Already in 2015 , Denmark established, with regard to the addition of potassium nitrite (E 249) and sodium nitrite (E 250) to animal products to be made on its territory, a limit of 60mg/kg. 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 by EU Decision 2018/702.
On 6.11.20 Denmark notified Brussels of a draft decree to extend the effectiveness of the above measures. Attaching data to support them:
– risk assessment. Formation of carcinogenic nitrosamines in meat products with added nitrites, consequent need to reduce consumer exposure to these substances, suitability of lower dosages to control botulinum contamination, (15)
– Free movement of goods. Denmark’s implementation of stricter limits has not hindered sales in its Danish market of products from other member countries with nitrite residues adjusted to its rules. Indeed, these sales have even increased, over the period 2017-2019.
C.2) Green light from Brussels
Noting the above, the Commission, by Decision (EU) 2021/741, authorized Denmark to maintain the previously approved national provisions for an additional three years. (16) Positive comments are noted from Finland, which has credited this approach with protecting against risks associated with excessive nitrite intakes while ensuring adequate consumer protection from food-borne diseases such as botulism.
EFSA had, after all, established an acceptable daily intake (ADI) of 0.07 mg nitrite ion/kg body weight. Clarifying that-where all sources of dietary exposure to nitrite (food additives, natural occurrence, and contamination) are considered-the ADI is exceeded in infants, young children, moderately exposed children, and people of all age groups who are most highly exposed. (13)
Interim conclusions
EFSA assessments attribute food additives to contribute about 17 percent (1.5-36.0 percent) of total dietary exposure to nitrites. Not a marginal share, considering that nitrosamines-especially exogenous nitrosamines triggered by additives-are correlated with colorectal cancers and nitrites are correlated with gastric neoplasms.
The European Commission itself has completed monitoring of average levels of nitrite added to meat products in member states, based on questionnaires (inevitably exposed to risk of ‘minimalist’ responses). The results were consistently below the EU limits, as expected, but above the thresholds set in Denmark (as equally expected).
Pending the reduction of EU limits, consumAtors can exercise their power by always choosing ‘nitrite-free’ products, meaning ‘with natural preservatives. In order for the supply of products on the shelf to change accordingly.
Dario Dongo and Andrea Adelmo Della Penna
Notes
(1) Silvia Bonardi, Dario Dongo. Botulinum, a dangerous bacterium to keep away from. GIFT(Great Italian Food Trade). 7/19/18, 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 meats. GIFT(Great Italian Food Trade). 6.11.17, https://www.greatitalianfoodtrade.it/etichette/conservanti-naturali-nelle-carni
(4) Galiano Quartaroli. Antimicrobials from vegetable waste, University of Parma patent. GIFT(Great Italian Food Trade). 5.7.19, https://www.greatitalianfoodtrade.it/tecnologia-alimentare/antimicrobici-da-scarti-vegetali-brevetto-università-di-parma
(5) Marta Strinati. Natural preservatives in meats, prickly pear. Study University of Catania. GIFT (Great Italian Food Trade). 12/23/19, 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. GIFT(Great Italian Food Trade). 10/27/20, https://www.greatitalianfoodtrade.it/integratori/resveratrolo-conoscenze-attuali-e-prospettive
(7) Dario Dongo. Plant extracts in meats, short circuit in Europe. GIFT(Great Italian Food Trade). 8.5.19, https://www.greatitalianfoodtrade.it/consum-attori/estratti-vegetali-nelle-carni-cortocircuito-in-europa
(8) Plant nitrates, which labels? Attorney Dario Dongo replies. FARE(Food and Agriculture Requirements). 4.3.18, https://www.foodagriculturerequirements.com/archivio-notizie/domande-e-risposte/nitrati-vegetali-quali-etichette-risponde-l-avvocato-dario-dongo#
(9) Reg. EC 1333/2008, on food additives. Consolidated text as of 8.8.21 at https://eur-lex.europa.eu/legal-content/IT/TXT/?uri=CELEX%3A32008R1333&qid=1633166689673. See its All. II, Part E, item 08.2, in reg. EU 1129/11 at https://bit.ly/3A16C6o
(10) E.g. , 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) E.g. , dry cured bacon, presumed, presumed from pa and paio do lombo and similar products. Nitrate limits of 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 no. 1247. The table with the various limits, which on some products can be as high as 150 mg/kg, can be found in Recital 13 to EU Decision 2021/741 (see footnote 16)
(15) Cases of botulism due to the consumption of meat and meat products have been absent in Denmark since the 1980s. Italy, conversely, is the first country in the EU for prevalence of botulism. V. Silvia Bonardi, Dario Dongo. Botulism in Italy, beware of homemade preserves. GIFT (Great Italian Food Trade). 4/29/20, https://www.greatitalianfoodtrade.it/sicurezza/botulismo-in-italia-attenzione-alle-conserve-fatte-in-casa
(16) Commission Decision (EU) 2021/741 5.5.21 on 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.
