Foodlaw-Reading
Dr David Jukes, The University of Reading, UK
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FSA Enforcement Letter (ENF/E/15/009), 18 May 2015
We would like to bring to your attention the unauthorised use of the carrier IPA in edible inks for cake decoration etc. In addition, we are requesting that Local Authorities take appropriate action to withdraw any non-compliant products from sale.
Background
IPA is not a permitted additive under EU food additives legislation (Regulation 1333/2008) and its use in any food for an additive function is not authorised.
IPA used in colours in edible marker pens is considered a carrier or carrier solvent. Carriers used in colours are subject to the provisions of Annex III of Regulation 1333/2008 (Commission Regulation No 1130/2011 refers) – only the additives listed can be used and as IPA is not listed as a permitted additive its use in colours is not authorised.
EU Member States all agreed that IPA in edible markers for cake decorations should be classified as a non-authorised carrier at a food additives Working Group meeting in Brussels. Recently the issue re-emerged following a notification from Spain regarding IPA being used in food colouring pens sold in Spain, marketed by a UK company,
Enforcement action to be taken where non-compliant products are found on sale.
Food colouring inks and pens containing IPA may be found on internet sales sites or at retail premises such as independent outlets supplying cake decorating materials. Officers are advised to check the labelling of the pens to see if IPA is used as an ingredient and, if so, where possible advise that they are withdrawn from sale. Where appropriate, manufacturers should be advised to reformulate their products.
For internet sales Local Authorities, in liaison with the FSA, should notify the Home or Primary Authority.
Officers may also wish to inform suppliers of cake decorating materials within their area of the non-permitted use of IPA.
