<<Disclaimer: Verify this information before applying it to your situation.>>

The following excerpt from the Food and Drug Administration's web site
explains the labeling requirements for "protein hydrolysates". If I
understand it correctly, manufacturers are required to identify the
source of the protein in natural flavorings and hydrolyzed vegetable
protein.

This changes the issue from one of regulation to one of enforcement.
Thus, when contacting manufacturers about the sources of ingredients in
their products, we can inform them that the 1990 Nutrition Labeling and
Education Act (NLEA) requires they disclose the protein source.

The excerpt comes from the FDA's web site
http://www.fda.gov/fdac/special/foodlabel/ingred.html . Please read it
and let me know if I am misinterpreting it. It seems pretty
straightforward, particularly the last paragraph.

"Protein Hydrolysates

Consumers will get more information about protein hydrolysates in their
food, too. Hydrolyzed proteins (proteins broken down by acid or enzymes
into amino acids) are added to foods to serve various functions. They
can be used as leavening agents, stabilizers (to impart body or improve
consistency, for example), thickeners, flavorings, flavor enhancers, and
as a nutrient (protein source), to name a few uses.

Since the law does not require flavors to be identified by their common
or usual names, some in industry have made a practice of declaring
protein hydrolysates as "flavorings" or "natural flavors" even when they
are used as flavor enhancers--a use not exempt from declaration. After
reviewing the data, FDA concluded that protein hydrolysates added to
foods as flavorings always function as flavor enhancers as well and, as
such, must be declared by their common or usual name.

The source of protein in hydrolysates used for flavor-related purposes
also must be identified. Previously the general terms "hydrolyzed
vegetable protein," "hydrolyzed animal protein," or simply "hydrolyzed
protein" were permitted, but the new regulation requires identification
of the specific protein source, such as "hydrolyzed corn protein" or
"hydrolyzed casein." There are two reasons for this.

First, the law requires that the common or usual name of a food should
adequately describe its basic nature or characterizing properties or
ingredients. FDA reasoned that the more general terms "animal" and
"vegetable" don't meet this requirement because protein hydrolysates
from different sources best serve different functions. Manufacturers
select protein hydrolysates from specific sources depending on how they
will be used in a product. Hydrolyzed casein is generally used in canned
tuna, for example, whereas hydrolyzed wheat protein is used in meat
flavors.

Second, the source of the additive is particularly important to
consumers who have special dietary requirements, whether for religious,
cultural or health reasons. If hydrolyzed casein is added to canned
tuna, for example, it must be identified as such, rather than simply as
"hydrolyzed protein" or "hydrolyzed milk protein."

Furthermore, after reviewing comments on the June 1991 proposal, the
agency concluded that to minimize confusion, the source of protein in
hydrolysates used for non-flavor-related purposes should also be
identified. Thus, the source of all protein hydrolysates--regardless of
use--will now have to be identified."

------------------------
Joel Elias
mailto:[log in to unmask]