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

I though I sent this sumamry last night. If things are just slow and
you end up getting this twice, please forgive me.


I wanted to know if "vinegar" (not "cider vinegar" or "distilled
vinegar") as an ingredient HAD to be made from apples. I noted that I
could not find the relevant passage in in the CFR, which is where
CSA/USA said it was. As I said before, I don't fear vinegar as a gluten
source, but I was curious because I started hearing from people who
said manufacturers we trust were telling them their "vinegar" was made
from corn.


A couple of people quickly told me that the passage was found in the
CPG (compliance policy guide), not in the CFR (Code of Federal
Regulations). Here is what the site with the passage says:


POLICY:


FDA considers the following to be satisfactory guidelines for the
labeling of <bold><italic>vinegars</italic></bold>:


Natural <bold><italic>vinegars</italic> </bold>as they come from the
generators normally contain in excess of 4 grams of acetic acid per 100
mL. When <bold><italic>vinegar</italic></bold> is diluted with water,
the label must bear a statement such as "diluted with water to _______
percent acid strength", with the blank filled with the actual percent of
acetic acid - in no case should it be less than 4 percent. Each of the
<bold><italic>varieties of vinegar</italic></bold> listed below should
contain 4 grams of acetic acid per 100 mL.(20oC).


<italic>VINEGARS:</italic>


1. VINEGAR, CIDER VINEGAR, APPLE VINEGAR. The product made by the
alcoholic and subsequent acetous fermentations of the juice of apples.


2. WINE VINEGAR, GRAPE VINEGAR. The product made by the alcoholic and
subsequent acetous fermentations of the juice of grapes.


3. MALT VINEGAR. The product made by the alcoholic and subsequent
acetous fermentations, without distillation, of an infusion of barley
malt or cereals whose starch has been converted by malt.


4. SUGAR VINEGAR. The product made by the alcoholic and subsequent
acetous fermentations of sugar sirup, molasses, or refiner's sirup.


5. GLUCOSE VINEGAR. The product made by the alcoholic and subsequent
acetous fermentations of a solution of glucose. It is dextrorotatory.


6. SPIRIT VINEGAR, DISTILLED VINEGAR, GRAIN VINEGAR. The product made
by the acetous fermentation of dilute distilled alcohol.


7. Vinegar, made from a mixture of spirit vinegar and cider vinegar.
The product should be labeled as a blend of the products with the
product names in order of predominance. This labeling is applicable to
a similar product made by acetous fermentation of a mixture of alcohol
and cider stock.


8. VINEGAR MADE FROM DRIED APPLES, APPLE CORES OR APPLE PEELS. Vinegar
made from dried apples, apple cores or apple peels should be labeled as
"vinegar made from ______," where the blank is filled in with the name
of the apple product(s) used as the source of fermented material.


OK, seems like maybe "vinegar" must be made from apples. But then
somebody else who knows someone at the FDA contacted that person and in
2 e-mails, here's what that FDA person said:


"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). He did not want to state
definitively, but given that he could find no food standard for the
content of "vinegar" only the required acidity, he believes we should
assume that vinegar can be made from anything."


And later...

"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."


SOOOOO...Sounds like to me that "vinegar" (NOT "cider vinegar" or
"distilled vinegar") can be made from something other than apples, and
it certainly sounds like companies are doing that.


cheers

richard