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Undeclared flour additive
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Update January 2022
Marriage's confirmed that they were still adding fungal alpha amylase to most their flours. The exceptions had, however, gone from one to two, both in their business to business range (ie 16kg sacks): Chelmer white and Manitoba. They advised that none of the flours in their retail range (1.5kg bags) was additive-free. The other change was that, following pressure from the Real Bread Campaign and guidance from local authorities they now declare everything they add to their flours.
We again urged them to remove this, and any other, additive they use as they are totally unnecessary, and any product made using flour containing a non-mandatory additive is not Real Bread. They declined.
In 2016, it came to the Real Bread Campaign’s attention that a UK flour mill was adding an enzyme to most of its flour but not declaring it.
Essex-based Marriage's confirmed that the company added fungal alpha amylase to all of of its bread flours (with the exception of Chelmer White) but didn't list it on its packaging, website or any other labelling. The company's defence was that it believed the enzyme could be classed as a processing aid and so didn't have to be declared.
By the Campaign's definition, a loaf made from flour or mix containing an added enzyme, so-called 'processing aid' or other non-mandatory additive is not Real Bread.
The law
While fungal amylase might perform a function in industrial loaf fabrication, it does not perform one before the baking stage and so cannot be deemed a processing aid in flour. If a miller puts it into flour, it is classed as an additive, which MUST be declared on the label.
In April 2016, we contacted the Food Standards Authority (FSA), which confirmed:
“…if an enzyme is used as a processing aid in the treatment or processing of a food and it has performed this role before the food is supplied, information about its use does not have to be passed on. If, however, an enzyme is added to a food as a processing aid but it is still working in the food or will not perform this role until the food is processed further down the chain, information as to its presence as an ingredient would have to be passed on until the point the enzyme has performed its role as a processing aid.”
Additive free flours
List last updated 23 June 2016
The following independent mills have advised the Campaign that none of their flours contain any artificial additives, other than mandatory ‘fortificants’ added as required by provision 4 of the Bread and Flour Regulations 1998:
- Bacheldre Watermill
- Fosters Mill
- Gilchester Organics
- Heage Windmill
- Heatherslaw Corn Mill
- Laxey Glen Mills*
- Mungoswells Malt & Milling
- Shipton Mill
- NR Stoate & Sons
*Located on the Isle of Man, exempt from the UK 'fortification' regulations and do not add anything to their flours.
Other mills
- Doves Farm Foods - does not add amylase, however some flours contain additives, which are declared on the label
- FWP Matthews - Adds E300, α-amylase and xylanase to its own-label T55 flour
We await responses from the following independent mills we emailed to ask whether or not their flours are free of added enzymes and other non-mandatory artificial additives:
- Carr's
- Heygates
- Wessex Mill
- Wright's
We invite all mills to let us know whether or not they include non-mandatory addtives in their flours and will amend this page accordingly the next time we do an update.
Our email address is: realbread [at] sustainweb.org
In the meantime, if you want to know whether or not any other mill is adding anything to its flour that it does not declare on its label, you will need to contact its owner/operator.
If they are, and you believe this is in breach of food labelling regulations, you might want to consider submitting a complaint to your local authority’s trading standards department/officer.
See also
- Food Information for Consumers (Regulation 1169/2011) which covers labelling rules for ingredients, food additives and processing aids.
- European Commission guidance on when an enzyme can be classed as an (undeclared) processing aid, rather than a (declared) additive.
- General information and links to the food enzyme legislation
Real Bread Campaign: The Real Bread Campaign finds and shares ways to make bread better for us, better for our communities and better for the planet. Whether your interest is local food, community-focussed small enterprises, honest labelling, therapeutic baking, or simply tasty toast, everyone is invited to become a Campaign supporter.
