So, Rosemary Extract has been added to the food standards as an approved additive! That’s great you say, but you have already been using it in your product so what changes?
There is a possibility you were adding Rosemary Extract for its antioxidant properties but declaring the extract as a flavour, however how can it be a flavour when it imparts no flavour? Now that it has been added as an approved additive, it can be declared as an antioxidant but only if it meets all of the criteria.
The maximum permitted levels must be conformed to, which is the confusing part. The additive list has been updated with Rosemary Extract 392, but does this mean for its use, flavour or antioxidant, its permitted level must be adhered to? I was surprised to see the permitted levels are very low compared to other additives at only 50ppm compared to something like 1,000ppm for Potassium Sorbate Preservative. Why is something that was supposed to be a natural antioxidant have such restrictions? Reading the fine print, Rosemary Extract is actually referring to the carnosic acid + carnosol acid in the Rosemary Extract, so in order to work out if you are within the permitted level, the amounts of carnosic acid + carnosol acid must be known. But this information was not available on the Rosemary Extract specification.
You will also need to verify with your supplier that the type of Rosemary Extract you are using meets the national standards criteria for Rosemary Extract 392, before you can label it.
If you are using Rosemary Extract to add rosemary flavour to your product, and indeed it adds rosemary flavour and meets the criteria for a flavouring, you can declare it as a flavour in your ingredient listing and add as much as you like. This is because a flavouring is not an additive. If you are using Rosemary Extract as an additive, for example an antioxidant, you must meet the permitted levels and verify the Rosemary Extract you are using meets the standard for what is Rosemary 392.
Are you using Rosemary Extract for its antioxidant properties?
Have you checked you are within the permitted levels and your ingredient listing conforms?
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