Current legislation in the UK and elsewhere allows manufacturers to decide an additive is a 'processing aid' and then not declare it, even on the label of a wrapped loaf.

What is a processing aid?

According to The Food Labelling Regulations 1996, a processing aid:

‘…means 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]

Spot the difference

 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…”

The issues

  • Current legislation allows residues of 'processing aids' and/or their by-products to remain in the finished product.
  • Increased heat stability is used by some manufacturers and dealers as a selling point of certain processing aids.
  • At least one study has found residues of a processing aid (fungal alpha amylase - a known allergen) in the crusts of baked loaves.
  • Are manufacturers abel to prove each addtive they have decided is a processing aid does 'not have any technological effect on the finished product’?

Whilst it is true that some are used to bend natural products to the unnatural demands of induistrial loaf fabrication (e.g. one 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 an artificial simulation of a characteristic of fresh 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, although each additive is tested in isolation in short-term studies before being passed as safe, there has been little study into the effects on humans of food enzymes in the longer term or the effects of additives used in combination.

The Federation of Bakers (which represents wrapped sliced loaf manufacturers) has told us processing aids aren't declared because they 'get used up' during manufacture. Is the FoB able to give people in the UK an assurance that all of its members have tested every one of their products to ensure that no trace of any processing aids or their residues remain? 

Clean label

What do the following quotes taken from the websites of certain producers and suppliers of 'label friendly' baking enzymes suggest to you? They might result in a 'clean label' but do they result in a clean product?

“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:

“…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:

“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:

Which loaves are made without processing aids?

It seems unlikely that British industrial loaf manufacturers (or high street 'craft' bakers) knowingly use 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 bakers

Bakers participating in The Real Bread Loaf Mark scheme 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 loaf products are made using processing aids, let alone which might have been used for any given loaf 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 load manufacturers) for an assurance that none of their members use any processing aids.  You can find their 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 make around 15-17% of the UK bread market) including the use of processing aids.  Click here for the report.

Craft and artisan bakeries

There is no legal defintion of 'craft' or 'artisan' bakery or bread. While some bakeries/bakers that use these terms make Real Bread, others use so-called processing aids and other additives. You'll just have to ask in-store to find out.

Organic bread

The Soil Association does permit the use of enzymatic 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 loaf fabricators.

Due to labelling law, it is not possible to know which of these are and are not being used in any given product or even generally. See the section above for all we know about which bakers are and aren't using processing aids. 

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

The Real Bread Campaign belives that it unlikely that any industrial loaf 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
‘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
‘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
‘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

Name: L-cysteine
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 []
Food Navigator 7 March 2002 []

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

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

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,  [,
‘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  []
Neogen material safety data sheet []

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[]

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 []
‘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 []

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