Which regulations to use when making mayonnaise?

Is the legislation relating to preservatives and antioxidants still applicable?

R1425 does not mention R965, yet the preservative limits for mayonnaise differ in the 2 documents. Which regulations must mayonnaise comply with?


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Bridget Day - 1 year ago

Hi Shoné

We have had the following feedback from the DOH:

The definition of miscellaneous additives in R.1425 does not cover preservatives & anti-oxidants. You must therefore refer to R. 965 for a list of permitted preservatives & anti-oxidants and the levels thereof.

Note: JECFA ( http://www.fao.org/fao-who-codexalimentarius/scientific-basis/jecfa/en/) also provides a list of preservatives & usage levels thereof for mayonnaise in the Codex GSFA, you must refer to that of R.965 and not that of Codex.

We hope this provides definitive guidance on this issue.

Food Focus

Bridget Day - 1 year ago

Hi Shoné,
According to Section 3 of R1425 the regulations concerning preservatives have not been repealed. This means R965 is still in force regarding preservatives and anti-oxidants. However R1425 clearly indicates that you need to refer to the Codex General Standard for Miscellaneous Food Additives (Codex STAN 192-1995).

If you compare both Codex and R965 you will see that they do not contradict each other when it comes to the issue of preservatives in mayonnaise, so you should apply both Codex and R965 requirements in your process.

We have contacted the DOH to confirm this, and we will provide their feedback as soon as they have responded. But if you wish to discuss this further, please feel free to email info@foodfocus.co.za to discuss in more detail.

Hope this clarifies the matter!

Shoné White - 1 year ago

Hi Bridget

So do we ignore the CODEX standard if SA legislation exists which is not specifically repealed (mentioned) by this regulation (R1425)?

Bridget Day - 1 year ago

We can see how confusing this issue is, but in this case both pieces of legislation apply.

R1425 does NOT deal with preservatives but what is known as miscellaneous additives.
R965 addresses preservatives and anti-oxidants, and is currently still in force.

4. (1) These Regulations R1425 come into operation 12 months after the date of publication hereof. (2) Subject the provisions of sub -regulation (1), foodstuffs manufactured on or before the date of commencement of this Regulations shall be exempted from the requirements of these regulations.

This means that R1425 will only be enforceable from November 2017.