Following the changes in the interpretation of the legislation surrounding the nomenclature of food additives, food producers have to change their ways. This task is necessary, but not easy. Annemieke Tops, guest speaker at IFFI’s upcoming event the 20th of May will update food industry employees on how to best adapt to the updated legislation.

The text of the legislation surrounding food additives has not changed much since 2008. However, the NVWA (Nederlandse Voedsel en Waren Autoriteit) and the European Commission regularly update the interpretation of the legislation and the annexes. ‘This happens so frequently,’ says Annemieke, ‘that it is difficult for food industries to keep updated.’ Adding to that, the European Commission and the NVWA have become much more strict with time. This puts a lot of pressure on the food industry, according to Annemieke, who will tell us all about it.


With a track record of 33 years in food legislation, Annemieke is an expert in the field. She has taken on several positions throughout Europe for companies including Unilever and Mead Johnson. From 2016 to 2020she was director Regulatory Affairs and Nutrition Sciences Asia for Mead Johnson in Singapore. Currently, she is a self-employed food regulatory professional who advises food producers on food legislation matters. 

Update legislation 

So what is the most recent update to the legislation? Most recently, The Standing Committee on Plants, Animals, Food and Feed (PAFF) has decided that many natural plant extracts that can work like e.g. antioxidants and preservatives, present in so-called ‘Clean Label’ products need to be registered as ‘additives’. Over the past 20 years the industry has invested in reducing the amount of additives in its products by using ingredients that make addition of E-numbers unnecessary. Instead of using E-numbers, Clean Label products contain ingredients that can naturally be found in food, like acerola extract or citrus extract. There is a growing trend amongst customers to prefer fresh and natural products over products which contain additives. Clean Label provided just what the customer wanted. 


The PAFF considers it misleading to the customer to claim that a product is ‘clean’ when it contains preservatives, anti-oxidants or other ingredients having a technological purpose, however natural these may be. ¨They esteem that natural antioxidants and preservatives like acerola extract or spinach extract have to be labelled as additives on the product. In order to do that, the natural ingredient used needs to be present on the list of existing legal additives and get an E-number¨, explains Annemieke. “Yet, many natural alternatives are not in this list, precisely because they are complex/variable ingredients  taken from foods.” The process of adding these natural ingredients (that have a technological function) to the list of legalized additives is time consuming,cost-intensive and might not even be possible.

IFFI event

During the event, Annemieke will dive into the ins and outs of the legislation and guide you through the steps on how to manage the situation in the most efficient way.  


We are looking forward to meeting you there and providing support to our fellow colleagues. 

You can still sign up for the event by clicking on this link.

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