'Processing aids'

When is an additive not an additive? When it's a 'processing aid'.

Due to what the Real Bread Campaign considers to be a legal loophole, industrial dough fabricators in the UK (and some other territories) can add a range of substances to their products and choose not to declare them on ingredients lists.

As part of our Honest Crust Act proposals for updated and improved composition, labelling and marketing standards, we continue to lobby the UK government to close this loophole.

• The issues
• Clean label
• Which loaves are made using processing aids?
• Organic bread
• Examples of processing aids

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What is a processing aid?

Retained Regulation (EC) No 1333/2008 on food additives defines 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 be reasonably expected to result, in it or its by-products becoming directly or indirectly a component of such foods.'

The same regulation states that a:

'‘processing aid’ shall mean any substance which:

(i) is not consumed as a food by itself;
(ii) is intentionally used in the processing of raw materials, foods or their ingredients, to fulfil a certain technological purpose during treatment or processing; and
(iii) may result in the unintentional but technically unavoidable presence in the final product of residues of the substance or its derivatives provided they do not present any health risk and do not have any technological effect on the final product.'

Can you spot the difference, because we're struggling here. Both are non-food substances, added to perform a 'technological purpose' and their residues or by-products can be present in the finished product you eat.

The issues

The main concern is that the 'processing aid' loophole denies people freedom of choice. Many people want (and, in some cases, need) to know everything that goes into the food they buy and eat. Also:

• Unlike substances that are classified as additives, there is no list of 'processing aids' that have been tested and approved for use.
• Legislation allows residues of 'processing aids' and/or their by-products to remain in the finished product.
• At least one study has found residues of a processing aid (fungal alpha amylase - a known allergen) in the crusts of baked loaves.
• A manufacturer does not have to prove that each substance they deem to be a 'processing aid' does 'not have any technological effect on the final product.’

While it is true that some 'processing aids' are used to bend natural / minimally-processed ingredients to the unnatural demands of industrial loaf fabrication (e.g. a function of the enzyme hemicellulase is to ease mechanical handling) many are used specifically to have an effect on the end product, commonly to prolong crumb softness in simulation of a characteristic of freshly-made bread.

As for not presenting any health risk, as can be seen below, research has thrown the possible effects of certain baking enzymes into question.

Further to this, what research has been done into the longer term effects of the cocktail of additives and far-from natural ingredients found in industrial dough products and other ultra-processed foods (UPFs)?

The Federation of Bakers (a trade body that represents many wrapped sliced loaf manufacturers) has told us that processing aids aren't declared because they 'get used up' during manufacture. We have not seen the FoB provide proof - or even any evidence - that all of its members have tested every one of their products to ensure that they are free from all residues and by-products of every 'processing aid' they use.

Clean label

Because it's not mandatory to declare 'processing aids', they are referred to in the industry as 'label friendly' or 'clean label solutions'.

Their use might allow a manufacturer to choose to have a 'clean label' but do they result in a clean product?

What do the following quotes taken from the websites of certain producers and suppliers of 'label friendly' baking enzymes suggest to you?

“Baking Enzymes are used as flour additives and in dough conditioners to replace chemical ingredients and to perform other functions in a label-friendly way.” Lallemand, distributor of enzyme concentrate Novamyl.  Source: www.lallemand.com/

“…today’s modern baker looks to enzymes to effectively modify his dough with label-friendly enzymes rather than dough conditioners with long chemical names.” BIO-CAT, supplier of food enzymes.  Source: www.bio-cat.com/applicationDetails.php?application_id=5

“Bakels offer a range of ingredients which are clean label. They are free from emulsifiers and Hydrogenated fats, allowing bakers to produce quality products with as clean a label as possible.” Bakels, suppliers of ingredients to the baking industry. Source: http://www.britishbakels.co.uk/products.cfm?section=healthyeatingandcleanlabel

Which loaves are made without processing aids?

It seems unlikely that any supermarket or other industrial dough fabricator (or high street 'craft' baker) knowingly uses any processing aid of animal origin in their products. To be certain about a particular product, however, you would need to contact its manufacture. The same goes for an assurance that a product is free of any so-called processing aids of any type or origin. 

Real Bread

The Real Bread Loaf Mark licensees sign an agreement that they will only use it in relation to loaves that are made without the use of processing aids.

Bakers also confirm that all loaves they add to our Real Bread Map are made without the use of processing aids.

Factory loaves

Due to the labelling regulations outlined above, we (and you) just don’t know which industrial dough products are manufactured using processing aids, let alone which might have been used for any given product and what the sources of any processing aids in that loaf were. 

in 2009, we asked The Federation of Bakers (which represents a number of industrial dough fabricators) for an assurance that none of their members use any processing aids. You can find the FoB's response here.

Supermarket in-store bakeries

Between June 2009 and February 2010, we made attempts to find out information from six major British supermarket chains about their in-store bakeries, which reportedly accounted for around 15-17% of the UK 'bread' market at the time.  Click here for the report from our investigations.

Craft and artisan bakeries

There is no legal definition of 'craft' or 'artisan' bakery or bread, and not all bakeries/bakers that use these terms make what we call Real Bread. The only way to be sure is to ask in-store.

Organic bread

The Soil Association does permit the use of enzymic processing aids in certified organic food.

According to the Soil Association organic standards for processors 2009 (section 40.8.18):

To make organic products you may use micro-organisms and enzymes which:

• are normally used as processing aids
• are not genetically modified
• in the case of enzymes, are not made by GMOs, and
• do not contain detectable GM DNA from the substrates used to grow the micro-organisms.

Examples of processing aids

The following information was published in 2010. The processing aids available may have changed since.

Here are just some of the so-called processing aids available to industrial dough fabricators. As there is no list of approved 'processing aids', there might be more.

Food labelling regulations allow manufacturers to choose not to declare these on their labels. 

Name: Phospholipase A2
Function: Increase volume and prolong softness
Issue: Can be of porcine (pig) or transgenic (GM) origin
References: Application A1004 phospholipase A2 as a processing aid (enzyme) approval report, Food Standards Australia New Zealand, 25 February 2009
http://www.foodstandards.gov.au/_srcfiles/A1004%20Phospholipase%20as%20a%20PA%20AppR%20FINAL.pdf

The Real Bread Campaign believes that it unlikely that any industrial dough fabricator would knowingly use an additive of animal original.

Name: Fungal a-amylase
Function: Increase volume, give darker crust and prolong softness
Issue: A known allergen by inhalation, evidence of persistence in crust after baking and causing allergic response by ingestion.  Up to 20% still present after baking.
References:  ‘Allergic reaction after eating a-amylase (Asp o 2)-containing bread’  Allergy, Volume 50 Issue 1, pp 85 -87, X. Baur, A. B. Czuppon, January 1995
http://www3.interscience.wiley.com/journal/119243078/abstract?CRETRY=1&SRETRY=0
‘Bread eating induced oral angioedema due to a amylase allergy’ Journal of Investigational Allergology and Clinical Immunology 2004, Volume 14 Issue 4 pp 346-347, Á. Moreno-Ancillo, C. Domínguez-Noche, A. C. Gil-Adrados, P. M. Cosmes http://www.jiaci.org/issues/vol14issue04/346-347.pdf
‘Is fungal a-amylase in bread an allergen?’ Clinical & Experimental Allergy, Volume 30 Issue 4, Pages 560 – 565, April 2000, Sander, Raulf-Heimsoth, Van Kampen & Baur http://www3.interscience.wiley.com/journal/119046999/abstract
‘Heating inactivates the enzymatic activity and partially inactivates the allergenie activity of Asp o 2’ Clinical & Experimental Allergy , Volume 26 Issue 2, Pages 232 – 234, February 1996, X. BAUR , A. B. CZUPPON  I. SANDER  http://www3.interscience.wiley.com/journal/119220873/abstract

Name: L-cysteine hydrochloride
Function: To delay staling effects
Issue: Issue: One source of the amino acid l-cysteine is human hair. Although l-cysteine of human origin is banned in the EU, Ajinomoto, which produces l-cysteine by a chemical process, has claimed that High Performance Liquid Chromatography tests have shown that some unscrupulous suppliers could be mislabelling human l-cysteine as coming from legal sources. Another source of l-cysteine is chicken feathers.
References:  CBH Qingdao [http://www.cbhcn.com/product-ny.asp?id=47]
Food Navigator 7 March 2002 [http://www.foodnavigator.com/Science-Nutrition/New-technology-for-cysteine-food-ingredient]

The Real Bread Campaign believes it is unlikely that any industrial dough fabricator would knowingly use an additive of animal original.

Note: L-cysteine is classified as an additive, so should be listed on a label by name or the code E920.

Name: Maltogenic amylase
Function: Helps to prolong crumb softness and elasticity.
Issue: Can be of transgenic (GM) origin.
References:  Transgenic plant expressing maltogenic alpha-amylase, United States Patent 7348470 http://www.freepatentsonline.com/7348470.html

Name: Hemicellulase
Function: Increases loaf volume, prolongs crumb softness and eases mechanical handling.
Issue: Can be of fungal, soil bacteria or transgenic (GM) origin. Fungal allergens can be expressed in enzymes of fungal origin.  Possibly not entirely destroyed by high temperatures.
References:  Hemicellulase active at PH and temperature extremes, United States Patent 5476775,  [http://www.freepatentsonline.com/5476775.html%5D,
‘Molecular biology and immunology of fungal allergens’ Indian Journal of Clinical Biochemistry, Volume 15, Supplement 1 / August, 2000, pp 31-42, Viswanath P. Kurup, Banani Banerjee, Kevin J. Kelly and Jordan N. Fink  [http://www.springerlink.com/content/b2g658478tt6t7h6/fulltext.pdf]
Neogen material safety data sheet [http://www.neogen.com/FoodSafety/pdf/msds/6854E_MSDS.pdf]

Name: Transglutaminase
Function: Increases elasticity of dough, reducing energy required for mixing, increasing strength of crumb structure and absorption of water.
Issue: Linked to triggering the coeliac response
References:  ‘Microbial transglutaminases generate T cell stimulatory epitopes involved in celiac disease’ Journal of Cereal Science Volume 47, Issue 2, March 2008, Pages 339-346 E.H.A. Dekking, P.A. Van Veelen, A. de Ru, E.M.C. Kooy-Winkelaar, T. Gröneveld, W.F. Nieuwenhuizen, and F. Koning [ doi:10.1016/j.jcs.2007.05.004]  
‘Addition of transglutaminase to cereal products may generate the epitope responsible for coeliac disease’ Trends in Food Science & Technology Volume 16, Issue 11, November 2005, Pages 510-512 , J.A. Gerrard and K.H. Sutton[http://www.agronavigator.cz/attachments/Trends_11-2005_510%E2%80%93512.pdf]

Name: Xylanase
Function: Makes dough more flexible, improving its machinability and giving better ovenspring during baking, which results in a greater volume.
Issue: Shown to be an allergen
References:  ‘Allergy to Aspergillus-derived enzymes in the baking industry: identification of beta-xylosidase from Aspergillus niger as a new allergen (Asp n 14)’ The Journal of allergy and clinical immunology 1998 Aug;102(2):256-64, Sander I, Raulf-Heimsoth M, Siethoff C, Lohaus C, Meyer HE, Baur X [http://www.ncbi.nlm.nih.gov/pubmed/9723670]
‘Prevalence of sensitisation to cellulase and xylanase in bakery workers’ Occupational and Environmental Medicine 2003; 0:802-804; J Elms, D Fishwick, J Walker, R Rawbone, P Jeffrey, P Griffin, M Gibson and A D Curran [http://oem.bmj.com/cgi/content/abstract/60/10/802]