<<Disclaimer: Verify this information before applying it to your situation.>>
Vance was gracious, as always, in his apology about his post on annatto.
But it was completely unnecessary. His post about annatto was right on
target.
The Code of Federal Regulations (CFR) contains the laws for product
labeling in the United States. A copy of the current CFR may be read
and searched online at http://www.access.gpo.gov/cgi-
bin/cfrassemble.cgi?title 0021 Using the CFR and previous posts to the
Celiac List, I would like to try to demonstrate the following points
about annatto :
1. Annatto color, annatto extract and annatto all have the same meaning on
a product label statement of ingredients.
2. Annatto color is a gluten-free additive.
3. Annatto color cannot contain undeclared caramel color.
_______________
1. Annatto color, annatto extract and annatto all have the same meaning on
a product label statement of ingredients.
21 CFR Sec. 73.30, which contains the definition for Annatto Extract,
states, "Labels shall bear information showing that the color is derived
from annatto seed."
21 CFR Sec. 73.2030, which contains the definition for Annatto, states, "The
color additive annatto shall conform in identify and specification to the
requirements for annatto extract in Sec. 73.30."
2. Annatto color is a gluten-free additive.
21 CFR Sec 73.30 allows for annatto to be extracted using distilled
alcohols as well as by the use of edible fats and oils and other means.
Distilled alcohol does not contain gluten and so would not be a problem
if it were used. However, according to a post titled, "Report on
Annatto" by Barbara Mason on May 27, 1997, fats and oils, not alcohol is
used to extract annatto color in the US. You can read this post from
the Celiac List archives on the following page:
http://maelstrom.stjohns.edu/CGI/wa.exe?A2=ind9705D&Liliac&D=0&P,,12&F=P
3. Annatto color cannot contain undeclared caramel color.
There is nothing in the definition of Annatto that allows for caramel color
to be added without being listed separately.
Since Ener-G foods did not list a source for its statement that annatto may
contain caramel color, I can only speculate where they might have come up
with this idea. It is a weekend so I cannot call them and ask about it.
Both annatto and caramel are listed in CFR Sec 73 as colors exempt from
certification. This means, according to 21 CFR Sec. 101.22(k)(2), that they
can be grouped under the term 'artificial color' on a label's statement of
ingredients, rather than being listed by their individual names. But
uncertified colors cannot be hidden in other ingredients unless they are
included in that ingredient's definition in the CFR, and caramel is not
included in the definition of annatto in the CFR.
Ener-G produces foods for countries other than the US, such as Canada, and
perhaps they are confused about the differences in regulations between
countries. I believe that in Canada, caramel color is allowed on the gf
diet, because in Canada caramel color is not manufactured using barley. In
fact, according to a post by Janet Rinehart on Nov 18, 1997, barley may not
be used to make caramel color in the US either. You can read her post at
http://maelstrom.stjohns.edu/CGI/wa.exe?A2=ind9711C&Liliac&D=0&PP50&F=P
Or perhaps their statement is an old one that dates back before the new
labeling codes that were put into place in 1992.
I apologize for being so long and rambling on. If anyone would like a copy
of the entire definition of annatto from the CFR and have difficulty finding
it on-line, feel free to send me an e-mail.
Amber Lee
AF, Utah, USA
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