BACKGROUND

An application has been made by a private group Apeel Sciences to FSANZ to use a glazing agent (E471 - Mono and di Glycerides of fatty acids) for a surface treatment of fresh fruits and vegetables, to form a thin, inert, physical barrier layer against moisture loss and oxidation to protect the nutritional quality and extend the shelf life. 

PROPOSED USE

The proposed use would address an increasing demand for year-round availability of fresh produce and reduce food waste.  This has been approved by other countries around the world where produce is imported from countries with a tropical climate that need to be protected during long transports.  

This product is available for conventional and organic produce. 

It is distributed to partners as a powder.  It is then mixed with water at packaging centre.  This can then be applied as a spray, dip or brushed on. 

WHICH COUNTRIES HAVE APPROVED THE USE OF THIS ADDITIVE AS A GLAZING AGENT ON FRUITS AND VEGETABLES?

Chile
China
European Union (certain fruits, but not vegetables.  The fruits that have been approved are those fruits with peels that are not usually consumed such as citrus fruit, melons, pineapples, bananas, papayas, mangoes, avocados and pomegranates)
Japan
Mexico
Peru
United States

FOOD LABELLING

Exemptions exist for labelling that applies for whole or cut fresh fruit or vegetables.  Mono and di-glycerides of fatty acids would NOT NEED to be declared as an ingredient. Unpackaged foods for retail sale is also not required to bear a label. 

CONCERNS TO BE ADDRESSED BY FSANZ

1. Australia is a leading food export nation 

Australia historically produces far more than we consume domestically.  We sell around 65% of farm production overseas, making Australia a leading food exporting nation.  We don't have the same concerns and considerations that other countries do in terms of long transport times, so therefore there is no need for this glazing agent to prolong shelf life?

2. Consumers should have the right to an informed choice

Consumers want to make informed decisions about what they are consuming on their fresh fruit and vegetables.  They believe that fresh fruits and vegetables should be unadulterated.  

If this additive is approved for use, Apeel Sciences have stated that it is possible to identify products that have used Apeel with an identifiable marker on the sticker of the fruit or vegetable.   We request FSANZ to require that this marker be used by all partners using this product in Australia.  This will ensure that the end consumer can make an informed decision and vote with their dollar.

3. Additive 471 cannot be removed from fresh fruit or vegetables

Apeel Sciences has stated that this product cannot be rubbed off a fresh fruit or vegetable without damaging the fruit or vegetable.  We request FSANZ to adopt a similar approach to the EU.  If this additive is approved for use on fresh fruits (not vegetables) it should only apply to fruits where the peels aren't typically consumed. In this way, it is not liable to have an effect on human health.

4. Further clarification on how this additive has been derived

It is our understanding that this additive can be derived in a number of ways.  It can be GMO, derived from animals or palm oil or other sources.  Apeel Sciences has declared that this is not a GMO product and is suitable for vegetarians.   We request clarification as to whether or not this product has been derived from palm oil specifically. 

5. This submission covers one supplier Apeel Sciences.  Will other suppliers be subject to the same submission process?

If other manufacturers want to apply a glazing agent to fresh fruits and vegetables, that may be derived from GMO sources or animal origins, will they be subject to the same submission process? How is the consumer able to differentiate the glazing agents for a plant source (palm oil or other), GMO or animal origins.  These distinctions are important to consumers. 

OUR POSITION

1. This processing aid is unnecessary in Australia. 

2. This processing aid is not for the benefit of the end consumer. 

3. We are seeking informed choice by an identifiable marker. 

4. We are seeking clarification of how this glazing agent has been derived (is it palm oil derived)?

5. If it is approved - we should adopt the EU position and apply only to fruits with hard peels that aren't consumed (ie citrus fruit, melons, pineapples, bananas, papayas, mangoes, avocados, pomegranates)  

6. If it is approved - any additional applications by manufacturers (that aren't Appel Sciences) to be put forth as a call for submission.  Each manufacturer and process is different (ie GMO and animal origins) and shouldn't receive blanket approval. 

MORE INFO ON CALLS FOR SUBMISSION OR TO MAKE YOUR OWN:

https://www.foodstandards.gov.au/media/Pages/call-for-comment-new-type-glazing-agent-fruit-vegetables.aspx

Please sign below if you are happy for Additive Free Kids to submit a submission on your behalf according to the information presented above.