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Artificial additives

Have you ever read the ingredients list on a factory loaf? Quite possibly not.

After all, you don’t read the label on butter or milk because you trust that all you're getting is obvious: butter (which at most may also contain salt) or milk. This is even protected by law. 

Sadly, the same does not always apply to a loaf. In fact, the law enshines the right of a manufacturer to use a whole cocktail of additives, should he/she wish.

What's perhaps worse is that supermarkets don't have to put any sort of ingredient list at all on the wrapper or shelves of their in-store bakery loaves.


What are additives?

We'd suggest that the 'anything your granny wouldn't recognise as food' principle is a useful day-to-day rule of thumb when determining what counts as an artificial additive.

The Miscellaneous Food Additives Regulations 1995 gives the legal definition of a food additive as:

“…any substance not normally consumed as a food in itself and not normally used as a characteristic ingredient of food, whether or not it has nutritive value, the intentional addition of which to food for a technological purpose in the manufacture, processing, preparation, treatment, packaging, transport or storage of such food results, or may reasonably be expected to result, in it or its by-products becoming directly or indirectly a component of such foods…”

Compare and contrast to the regulations' definition of a processing aid.

The baking industry on additives

Here's what The Federation of Bakers, which represents the manufacturers of the industrial loaves that account for around 80% of the loaves we buy, has to say on the subject:

“Additives are not new. Additions to food have been made since pre-historic times, mainly to help preserve food and make it safer to eat. Salt, vinegar and sugar are traditional methods of preservation.”

Hmm, so when was the last time you stirred a spoonful of sodium stearoyl-2-lactylate into your tea or sprinkled mono and diacetyl tartaric acid esters of mono and diglycerides of fatty acids onto you chips?

“Before they can be used for food production, additives must pass rigorous approval procedures at national, European and international level. They must be shown to be both necessary and safe. Because they undergo such stringent testing, more is known about their biological, physiological and toxicological effects than about many of the natural foods we commonly eat. Consumers can therefore be confident that approved additives are safe and serve a useful purpose.” The Federation of Bakers

Are you reassured?

Cocktails and safety

Though all of the following have been declared safe (or in the more pragmatic terminology of the US Food and Drink Administration, ‘generally recognised as safe’), they have only been tested in isolation over relatively (in terms of human history) short periods.  What has not and might never be understood is what effect the cocktail of artificial additives we consume, not only in factory loaves, but in many industrially processed foods, have on the human body in combination over time.

Furthermore, what is declared safe can change over time: think of the chlorine-based bleaching agents that were defended by industry but then banned from UK bread flour production in 1999 due to health concerns.  Though designated an ingredient rather than an additive, partially hydrogenated vegetable oil/fat is another synthesised substance that only very recently fell from grace, once often advertised to be a healthy alternative to butter but now known to contain artery-clogging trans-fats - see the 'other ingredients' section below.

To highlight the fact that history is littered with questions being raised about supposedly safe additives, we list some below.

Legal loopholes

It should be noted that loaves, dough or flour imported from or via other EU or EEA member states is not subject to UK regulations. 

Imported products

As long as loaves or flour are produced and/or available lawfully in the member state from which they're imported, they can be sold in the UK, even if they contain additives or have been produced using bleaching agents that are not permitted in UK produced bread or flour.

So, whilst it is illegal to import bleached flour directly from the USA, if that flour was first imported into an EU or EEA member state where bleaching is permitted, it can then be re-imported to the UK.  This flour could then be used in baking and the bleaching agent would not have to be mentioned on the label. 

Processing aids

Compare the above definition of a food additive with the same document’s definition of a processing aid: “any substance not consumed as a food by itself, intentionally used in the processing of raw materials, foods or their ingredients to fulfil a certain technological purpose during treatment or processing, and which may result in the unintentional but technically unavoidable presence of residues of the substance or its derivatives in the final product, provided that these residues do not present any health risk and do not have any technological effect on the finished product…” [our italics]

We’ll leave it to you to spot the distinction between the two.  For more about processing aids, click here.

In-store fakery?

We believe that people have the right to make as fully-informed choices as possible about the food they eat.

Sadly, The Food Labelling Regulations 1996 state that in the case of foods (e.g. loaves) that are “…prepacked by a retailer for sale by him on the premises where the food is packed or from a vehicle or stall used by him,” or “prepacked by the producer of the food for sale by him either on the premises where the food is produced or on other premises from which he conducts business under the same name as the business conducted on the premises where the food is produced…” (e.g. in-store bakeries), all that the retailer has to indicate on the shelf labels or packaging of such loaves is the presence of certain allergens and the use of any flour treatment agent. For the latter, however, the name and composition would not even have to be given.

So, a supermarket can throw in all sorts of artificial additves into their so-called 'fresh bread' and, unless you ask a member of staff to go off and fetch an ingredients list, you'll never know what else went into its manufacture.

The Real Bread Campaign calls for mandatory ingredient (including any and all additives and processing aids) labelling of all loaves, and in the meantime encourages all bakers to do this voluntarily.

Clean labels

“Consumers nowadays want fewer and fewer additives in their food. The baking industry has responded by developing breadmaking techniques that reduce additives to a minimum.” The Federation of Bakers

The Real Bread Campaign would agree that many people do not like seeing ingredients lists littered with E numbers, long chemical names and other substances that ‘granny wouldn’t recognise as food’.

Sadly, rather than making moves back towards the production of 100% natural Real Bread, the ‘clean label’ efforts of some big bakers could mean only that: fewer things on the ingredients list.

Every week, novel enzymes are released onto the market to perform the functions of chemical additives.  Unlike the additives, these processing aids, as they are known, do not have to be listed. See our processing aids page for more on these ‘label friendly’ replacements.

Additives permitted for use in UK bread production

In theory, the range of artificial additives that can be used in loaf production should be quite limited.

The Miscellaneous Food Additives Regulations 1995 (as amended) has a list (known as Schedule 1) of all additives permitted in UK food production.

“Bread prepared solely with the following ingredients: wheat-flour, water, yeast or leaven, salt” is one of a number of basic foods that has its own, more limited list (Schedule 7) of additives from Schedule 1 that can be used.

The Food Standards Agency’s Food Additives Legislation Guidance Notes, however, point out that “most bread or cheeses in the UK do not fall within the categories of specialist products listed in this Schedule and will therefore not be restricted to using only the limited number of Schedule 1 additives listed.”

i.e any loaf that contains ingredients other than wheat flour, water, yeast and salt could also legally contain any additive on Schedule 1.

The list below is of additives on Schedule 7, with a few extras from Schedule 1, as noted.

Sources:

Unless otherwise stated, all information on the source of additives is taken from Acceptability of UK permitted food additives for special and religious diets by Megan Gibbons and Fiona Angus, Leatherhead Food International (2005)

Other information taken from:

Federation of Bakers, The (FoB) – Factsheet no. 14, Additives in bread (January 2002, accessed January 2010)
Food Intolerance Network - Factsheet: The bread preservative   (2006, accessed January 2010)
Food Standards Agency, The (FSA ) – The Bread and Flour Regulations 1998 (as amended) Guidance Notes,  version 1 (1 June 2008, accessed 19 November 2009)
Food Standards Agency, The - Food Additives Legislation Guidance Notes (February 2003, accessed January 2010)
The Colours in Food Regulations 1995

Hanssen, Maurice - E for additives, Thorsons (1984)
Lawrence, Felicity (ed.) - Additives your complete survival guide, Century (1986)
Smith, Jim (ed.) - Technology of reduced additive foods, Blackwell (2004)

The University of Reading has a page on EU and UK food additive regulations (including amendments) and all additives permitted in the EU

The format used below is:

E number (if designated), name
Class/category of function

Source of the additive and other notes

The list

E150 (a-d) Caramel
Colouring (only permitted in malt bread)

This is not the same as the caramel obtained from heated sugars, which is classified as an ingredient and therefore can be used in any bread.

“The term caramel relates to products of a more or less intense brown colour which are intended for colouring. It does not correspond to the sugary aromatic product obtained from heating sugars and which is used for flavouring food” The Colours in Food Regulations 1995

E260 Acetic acid
Preservative

Though The Federation of Bakers notes that “Vinegar is a natural ingredient and is not regarded as a food additive,” acetic acid may also be produced from the pyroligneous acid generated in the distillation of wood alcohol; the oxidation of acetaldehyde and of butane; or by the reaction of methanol and carbon monoxide.

Due to the lack of time for dough ripening and natural flavour development in the production of factory loaves, acetic acid can also act as a flavour enhancer.

E261 Potassium acetate   
Preservative   

Produced by the reaction of acetic acid (see above) and potassium carbonate       

Potassium salts should be avoided by people with impaired kidneys (Hanssen)   

E262 Sodium acetates   
Preservative   

E263     Calcium acetate   
Preservative   

May be produced by the neutralisation of acetic acid (see above) by calcium hydroxide

E270     Lactic acid   
Preservative   

"E270 can be obtained by the lactic fermentation of beet/sugar cane or glucose, or prepared synthetically by the formation of lactonitrile from acetaldehyde and hydrogen cyanide and subsequent hydrolysis to lactic acid. Although fermentation of sugars is the most common method of manufacturing E270, it cannot be guaranteed to not come from a milk source."
           
E280    Propionic acid   
Preservative (permitted in pre-packed breads)

Can be produced lactic acid by Propionibacterium and also by various methods involving the oxidation of propionaldehyde, a by-product in fuel synthesis and wood distillation
           
E281    Sodium propionate
E282    Calcium propionate   
E283    Potassium propionate
Preservatives   

Inhibits the growth of mould. Manufactured by the reaction of propionic acid and carbonates of the relevant metal’s hydroxides   

Propionates can lead to a risk of migraine or eczema and calcium propionate is reported to cause “…skin irritations in bakery workers.” (Lawrence)

The Food Intolerance Network claims of propionates that: “Reactions can be anything from the usual range of food intolerance symptoms: migraine and headaches; gastro-intestinal symptoms including stomach aches, irritable bowel, diarrhoea, urinary urgency, bedwetting; eczema and other itchy skin rashes; nasal congestion (stuffy or runny nose); depression, unexplained tiredness, impairment of memory and concentration, speech delay; tachycardia (fast heart beat); growing pains, loud voice (no volume control); irritability, restlessness, inattention, difficulty settling to sleep, night waking and night terrors.”  FoodReactions.org makes similar statements.

One double blind crossover study into the effects of propionates on children's behaviour found that the behavouir of 52% of children studied deteriorated after eating bread treated with propionates, as opposed to 19% whose behaviour imporved. "Controlled trial of cumulative behavioural effects of a common bread preservative," S. Dengate and A. Ruben, Journal of Paediatrics and Child Health, Vol. 38, No. 4, August 2002, 373-6

E300     Ascorbic acid   
Antioxidant   

As a flour treatment agent, ascorbic acid is “used to ensure good loaf volume and improve the crumb structure, softness and colour.”  Federation of Bakers

Can be extracted from various fruit or vegetable sources or synthesised from glucose: “Firstly, D-glucose is hydrogenated to D-sorbitol, followed by oxidation of the diacetone derivative of L-sorbose. The resulting diacetone-2-keto-l-gluconic acid is converted to L-ascorbic acid by heating with hydrochloric acid,"  or from glucose, sorbitol, sorbose, and 2-keto-gulonic acid by oxidation with hypochlorous acid in the presence of hydrous cobalt oxide catalyst.

Also known as vitamin C, though as it is destroyed by heat, it has no nutritional value in baked goods.

See also our page on ascorbic acid.

E301     Sodium ascorbate   
Antioxidant   
       
E302     Calcium ascorbate   
Antioxidant   
       
E304(ii and ii) Fatty acid esters of ascorbic acid   
Antioxidant   

The ester of L-ascorbic acid and palmitic (i) or stearic (ii) fatty acid. The source of fatty acids can be animal or vegetable.   
       
E322     Lecithins   
Emulsifiers, stabilisers, thickeners etc   

Commonly produced from soya, safflower or corn oils but egg can also be used as a source. Alcohol is used in the separation of lecithin.         

Is the manufacturer able to tell you which of the above is the source of their lecithin and whether or not genetically modified corn or soya was used?

E325     Sodium lactate   
E326     Potassium lactate   
E327     Calcium lactate
Emulsifiers, stabilisers, thickeners etc   

Produced from lactic acid (see above) and therefore could be of milk origin

Young children have difficulty of metabolising; risk of liver disease (Lawrence).

May exacerbate digestive problems in those with lactose intolerance.    

E452 Polyphosphates (sodium, potassium, calcium and sodium calcium) Permitted in flour (Schedule 3)

E471    Mono and diglycerides of fatty acids       
Emulsifiers, stabilisers, thickeners etc           

E472a     Acetic acid esters of mono and diglycerides of fatty acids   
E472d     Tartaric acid esters of mono and diglycerides of fatty acids (TARTREM)
E472e     Mono and diacetyl tartaric acid esters of mono and diglycerides of fatty acids (DATEM)
E472f     Mixed acetic and tartaric acid esters of mono and diglycerides of fatty acids (MATREM)
Emulsifiers, stabilisers, thickeners etc   

“These are used to provide dough stability and tolerance in addition to improving loaf volume and crumb structure and in maintaining softness.” Federation of Bakers

The fatty acids on which these are based could be of animal origin.       

‘…such complex novel compounds are likely to have complex, unpredictable effects and need much more thorough testing.' (Lawrence)   

E481    Sodium stearoyl-2-lactylate    
Emulsifiers, stabilisers, thickeners etc (permitted in bread types not listed in Schedule 7)

The stearic acid and/or the lactic acid from which Sodium stearoyl-2-lactylate is produced could be of animal origin.

E920    L-cysteine hydrochloride   
Improvers and bleaching agents (may only be used as a flour treatment agent The Miscellaneous Food Additives (Amendment) Regulations 1999)   
Can also be used as a processing aid and therefore not declared on the label.

"Industrially, E920 is obtained from chicken or duck feathers or pig bristle”

Some manufacturers in China also use human hair as a source – e.g. CBH Qingdao ‘….All products are derived from human hair or duck feather…’

L-cysteine hydrochloride derived from human hair is not permitted for use in the EU.

Our work on this issue leads us to believe it is unlikely that any UK company is knowingly using (or markeint products containing) L-cysteine of animal or human origin but see the entry on our processing aids page for more about possible uncertainty of determining its source.


Additives legally required in UK produced flour

Click here for the substances that must be added to UK produced flour but do not have to be declared on the label.

Additives not permitted in UK bread/flour production

At one point, some of these additives and ‘improvers’ were permitted in the UK and their safety defended by government and industry.

Others are still in use outside the UK and whilst not permitted for use here, could quite legally find their way into the country in flour or loaves imported from an EU or EEA member state.

E339 Sodium phosphate
E340 Potassium phosphate
E341 Calcium phosphate

Listed under Annex IV of Directive 95/2/EC, are authorised for use in "Flour" to a maximum permissible level of 2.5 g/kg
(email from Richard Wood, Food Standards Agency, Standards Authenticity and Food Law Policy Branch, Labelling, Standards and Allergy Division)

925 and 926 Chlorine and chlorine dioxide
Improvers and bleaching agents           

Chlorine dioxide is mutagenic [i.e. is capable of causing mutations and possibly, but not necessarily,  act as a carcinogen]; toxological studies on its effects on flour are awaited (Smith and Hong-Shum)   

Although banned in the UK, bleached flour could be imported from/via EU and EEA member states       

Agene (nitrogen trichloride)
Improvers and bleaching agents                   

Following studies linking the use of agene to neurological disorders in dogs, in 1950 a committee led by Chief Medical officer of the Ministry of Health, Sir William Jamieson, stated "…in view of the deleterious effects on certain animals, the committee has felt that the use of agene should be discontinued."

"Did consumption of flour bleached by the agene process contribute to the incidence of neurological disease?" Medical Hypotheses, Volume 51, Issue 6, Pages 477-481C.Shaw, J.Bains
See also Canadian Journal Of Comparative Medicine, April 1950, vol XIV No 4

Banned in the EU and USA

Azodicarbonomide               
Improvers and bleaching agents

‘Evidence for respiratory sensitisation has been found in bronchial challenge studies and workplace health evaluations.' May cause gastrointestinal tract irritation with hypermotility and diarrhea. Prolonged or repeated ingestion may affect the kidneys, and endocrine system (thyroid hypofunction)    "Methods for the Determination of Hazardous Substances 92 Azodicarbonamide in air", HSE, November 1998

Banned in Europe, Australia and Singapore but legal in the USA.

Benzoyl peroxide                           
Improvers and bleaching agents

Banned in UK in 1997

924 Potassium bromate               
Improvers and bleaching agents

Could cause stomach pains, nausea and diarrhoea. May reduce vitamin E in flour. (Food adulteration and how to beat it, London Food Comission (1988)  

'Potassium bromate is possibly carcinogenic to humans (Group 2B).'    IARC Monographs on the Evaluation of Carcinogenic Risks to Humans. Volume 73, International Agency for Research on Cancer (1999)

Banned in UK in 1990  but could still be present in loaves or flour imported from/via EU and EEA member states.

Not entirely natural ingredients

Artificial trans fats

These are found in partially hydrogenated fats, e.g. in some margarine, shortening and stuff labelled as vegetable fat.

According to an invitation from the Associate Parliamentary Food & Health Forum to an October 2010 debate on the subject:

"Trans fats (or trans fatty acids) have a similar effect on blood cholesterol as saturated fats – they raise the type of cholesterol in the blood that increases the risk of heart disease.

In 2007 the Food Standards Agency (FSA) carried out a review of trans fats at the request of the Secretary of State for Health. This review looked at the health impacts of current intakes of trans fats, voluntary activities by the UK food industry to reduce levels of artificial trans fats in food and legislative action already taken in other places, such as Denmark and New York. According to the FSA, the average intakes of trans fats in the UK are half the 2% maximum recommended intake of our total food energy and therefore “not a cause for concern”.  A position statement published by Scientific Advisory Committee on Nutrition (SACN) in December 2007 endorsed the 1994 COMA recommendation , “that the average trans fatty acid intake should not exceed 2% of food energy, since there is currently no firm scientific basis for its revision.”

However, since 2007 a number of health organisations and food campaigners have expressed concern about the impact on health of artificial trans fats in processed food. They are classified as toxic by the World Health Organisation, while the National Institute for Clinical Excellence and the UK Faculty of Public Health have both called for a ban on their use in the UK.  The use of trans fats has already been banned in Austria, Denmark, Switzerland, California and New York."

See also:

Dried gluten.

How do industrial loaf additives work?

The Royal Society of Chemistry published this article in the October 2009 issue of Chemistry World magazine, which looks at the chemistry of Real Bread making, and how the natural process is altered by some of the artificial additives used in industrial loaf manufacture.

More information

Dr David Jukes of the Department of Food and Nutritional Sciences at the University of Reading maintains a highly detailed page on Food Additives in the European Union