EU-Organic Regulation (EC) 2018/848 Annex II Part IV 1.1
In addition to the general production rules laid down in Articles 9, 11 and 16, the rules laid down in this part shall apply to the organic production of processed food.
1. General requirements for the production of processed food
1.1. Food additives, processing aids and other substances and ingredients used for processing food and any processing practice applied, such as smoking, shall comply with the principles of good manufacturing practice (1)
(1) Good manufacturing practices (GMPs) as defined in Article 3 (a) of Commission Regulation (EC) No 2023/2006 of 22 December 2006 on good manufacturing practice for materials and articles intended to come into contact with food (OJ L 384, December 29, 2006, p. 75).
Instead an introduction:
To state it in one sentence – viewing to the CleanSmoke smoking process: CleanSmoke smoking is approved by EFSA for smoking food, but today conventional smoking processes would never be approved by EFSA.
Below an overview of the legal regulations is shown how smoking with pre-purified smoke fully complies with the EU requirement for “Good Manufacturing Practice” within the CleanSmoke Food Safety Management System.
Summarized in 4 charts:
These are the essential legal bases and certification steps for smoke flavors (pre-purified primary smoke products)
- Smoke flavorings (pre-purified primary smoke products) are approved by the EU Regulation (EU) No. 1321/2013
- The smoke flavors are produced in certified (Food Safety Management System) companies
- The smoke flavors are supplied to food manufacturers by certified companies in Europe
- Red Arrow Handels-GmbH is about to issue the certificate in accordance with FSSC 22000
- Manufacturers and distributors comply with the following EU regulations
- Flavor Regulation (EG) No. 1334/2008 (approval, labeling, etc.)
- Smoke Flavor Regulation (EG) No. 2065/2003
- Implementing regulation on smoke flavoring regulation (EU) No. 1321/2013
- The smoking process is approved by the EU and recognized as such ((EU) No. 1321/2013 and BAT in the FDM-BREF document)
- The food manufacturers are IFS certified (attached example “Die Räucherei” by Jochen Kunkel in seperate PDF „Good Manufacturing Practice – purified Smoke“)
For the manufacturers of food, the CleanSmoke smoking process offers easier options to comply with "Good Manufacturing Practice":
- certified smoke generator, certified smoke material
- Batch-related certificate of analysis of the smoke aroma used (often/mostly not available for smoke chips)
- Measurability of the amount of smoke used (exact determination of consumption)
- Controlled, known composition of the smoke (certificate of analysis, amount of smoke, no environmental influences (smoking in a closed system – no weather influences))
- Controlled, known exposure of the smoke product to PAHs and 3-MCPD (both at the technically possible lowest level)
Controlled shelf life of the end product (known smoke composition, known amount of smoke, constant smoking conditions (in a closed system – no weather influences)
- Controlled, known sensory quality of the smoked food
minimized environmental impact (BAT) and optimized resource protection (energy, wood, water)
If GMP is to be used or complied with, the certificates for a functioning food safety management system must be available from the manufacturer of the pre-purified primary smoke product to the manufacturer of the smoked food. The Food Safety Management System is about ensuring food safety and thus protecting the consumer.
The following points therefore play an important role:
- Approval of the pre-purified primary smoke product by the EU (positive list (EU) No. 1321/2013)
minimized pollution of the finished smoked food (“recital 2065/2003”)
- sufficient shelf life of the smoked food
- Compliance with food hygiene regulations (no chips, no ashes, no tar, no smoke resin remover)
Traceability of the manufacturing process (batch number, batch analysis certificate, quantity and composition of the smoke known (measurable))
Better for the consumer because it is less polluting