The Future of Halal Industry Conformity

Food with animal risk or Hidden Food and Alcohol:

REGULATION (EU) No 1169/2011 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 25 October 2011

The regulation establishes the general principles, requirements, and responsibilities governing food information, particularly food labeling. It lays down the means to guarantee the right of consumers to information and procedures for the provision of food information, taking into account the need to provide sufficient flexibility to respond to future developments and new information requirements.

 Article 20
 Omission of constituents of food from the list of ingredients

 Without prejudice to Article 21, the following constituents of food shall not be required to be included in the list of ingredients:
(a) the constituents of an ingredient that have been temporarily separated during the manufacturing process and later reintroduced but not in excess of their original proportions;
(b) food additives and food enzymes:
(i) whose presence in a given food is solely due to the fact that they were contained in one or more ingredients of that food, in accordance with the carry-over principle referred  to in points (a) and (b) of Article 18(1) of Regulation (EC) No 1333/2008, provided that they serve no technological function in the finished product; or
(ii) which are used as processing aids; 
(c) carriers and substances which are not food additives but are used in the same way and with the same purpose as carriers, and which are used in the quantities strictly necessary; (alcohol used in food for extraction and carrier is part of processing aid)
(d) substances which are not food additives but are used in the same way and with the same purpose as processing aids and are still present in the finished product, even if in an altered form;

Alcohol:

Article 9
List of mandatory particulars

A. Prepacked foods
For the labeling of prepacked foods, the Regulation sets out a list of mandatory particulars that are required to be provided to the final consumer (Article 9, par. 1):

• • • • • Name of the food;
        • List of ingredients;
        • Any ingredient or processing aid listed in Annex II or derived from a substance or product listed in Annex II causing allergies or intolerances used in the manufacture or preparation of a food and still present in the finished product, even if in an altered form;
        • Quantity of certain ingredients or categories of ingredients;
        • Net quantity of the food;
        • Date of minimum durability (‘best before’ date) or the ‘use by’ date;
        • Any special storage conditions and/or conditions of use;
        • Name or business name and address of the food business operator referred to in Article 8, par.1;
        • Country of origin or place of provenance where provided for in Article 26;
        • Instructions for use where it would be difficult to make appropriate use of the food in the absence of such instructions;
        • With respect to beverages containing more than 1,2 % by volume of alcohol, the actual alcoholic strength by volume;
        • Nutrition declaration.

Author’s commentary:

Animal derivatives are commonly not permitted unless they are Halal certified.

Therefore, the current approach that is considered authoritative is through laboratory analysis. An analysis protocol that must be accredited with accreditations such as ISO 17025 (General requirements for the competence of testing and calibration laboratories). This type of verification should also help other dietary needs, e.g., for vegetarians and other ethnicities who treat land animals as critical. This technique is also synonymously with the Halal certification validation process.

To detect animal traces, the selection of a laboratory must:

• • Be accredited for DNA (deoxyribonucleic acid or nucleic acid) analysis protocol, such as PCR (Polymerase chain reaction). The leading accredited laboratories are such as Halvec, Eurofinn (i.e. France and Germany), SGS, Mérieux Nutrascience,  etc.
  • The method-specific limit of detection (mLOD) is <0.01% for 3 animal species (Sus scrofa-porcine, Bos Taurus-cattle and Oval ovaries-sheep) in making Halal integrity is completely verified.
  • Find the accredited laboratories here.

When it comes to alcohol, 1.2% in EU standards (to be declared) is too high for an alcohol level for Halal standards.

• • • Accredited or not, ethanol analysis is quite basic in the industry, such as the Gas Chromatography System (GCS).
    • The parameter must be below 0.1% (LoQ) or less for detection.
    • In some sects of the Islamic view, ethanol is permitted depending on the purpose. It is allowed if it is used for cleaning, hand swabs, medical procedures and killing bacteria. Also, in a raw state, some ingredients require ethanol as a carrier agent and a form of anti-microbe growth. However, the source of ethanol must not come from khamr production, such as a consumer-alcoholic plant. There is an approved source of ethanol that is produced by food, medical or pharmaceutical producers. The manufacturer needs to make sure all consumable product ethanol does not exceed 0.1%, according to an international fatwa (Malaysia, JAKIM). A fatwa is an Islamic legal pronouncement issued by an expert in religious law (mufti). | Related article.