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

On my query about whether just plain "vinegar" is always made from apples:

Several people wrote to tell me all the things vinegar can be made from,
including apples. Thanks for the help, but that's not what I wanted.

As you can imagine, a few wrote to tell me that all distilled vinegar is safe
and a few wrote to say that distilled vinegar is not necessarily safe. I
believe distilled vinegar is GF but that's not what I was asking.

A couple of people wrote to tell me I was looking in the wrong place and this
is what I wanted to see.

>"Here's a link:
>
>http://www.fda.gov/ora/compliance_ref/cpg/cpgfod/cpg525-825.html
>
>Note that the first category listed is for VINEGAR, CIDER VINEGAR,
>APPLE> VINEGAR and says, in effect, that an ingredient listed as any of
>those> three must be "made by the alcoholic and subsequent acetous
>fermentations> of the juice of apples".
>

This is indeed what I wanted to see and would seem to indicate that "vinegar"
must indeed be made from apples. Yet numerous people have told me that they
called about the source of "vinegar" and frequently have been told that theirs
comes from corn. Lea & Perrins, for instance, told somebody their "vinegar"
comes from corn.

Then comes this from a person who knows somebody with the FDA and who wrote
and talked to that person:

>"Ok, here's what I found out. My contact at the FDA called back and we
>discussed the link that Richard listed (CPG 525.825 "vinegar= from apples).
>The CPG stands for "compliance policy guide" and is used by inspectors in the
>field. It is NOT law or the food standard and in fact may refer to only one
>case (the above reference is from 1995)."

And this:

>"I did find a copy of the Compliance Policy Guide that you were referring to.
>Mine is the most current issue, August 2000. The web reference that you
>received is lacking in some of the information contained in the CPG. I am not
>sure if it is due to revisions, or the fact that the information you are
>receiving via the internet is redacted by our FOI office (freedom of
>information act). By law, many things have to be available for public
>information, but those things that are not considered to be part of the
>Freedom of Information act, are taken out.
>
>The current version I have, states:
>
>No standards of identity for vinegar have been established under the Federal
>Food, Drug, and Cosmetic Act. Historically, definitions have been developed
>for different types or combinations of types of vinegars. These remain

current >Agency Policy for labeling purposes. (CPG Aug. 2002 ch: 5 sec.
525.825)

>The information that you have about the acidity of the vinegar is correct,

The >current CPG states ...each of the varieties of vinegar listed below
should >contain 4 grams of acetic acid per 100 mL (@20 degrees Celsius).

>Your friend is incorrect in assuming that the CPG is the law, As I
>explained in our telephone conversation, the CPG is a guidance for
>investigators, that's all. The law is the Food, Drug and Cosmetic act (FD& C
>act) as well as 21 CFR. If a firm is cited for adulteration or misbranding,
>this is where the citations come from.

I personally searched the CFR and was unable to find anything ruling what
"vinegar" must be made from.

It honestly doesn't matter all that much to me but it would appear from all I
have in hand that the CPG is not "law" and that "vinegar" is indeed made from
things other than apples.

cheers
richard