The Food Safety Authority of Ireland (FSAI) published a guidance note Good Manufacturing Practices for the Production of Ready-to-eat Unpasteurised Fermented Plant-based Products to assist producers to produce safe products. The guidance was developed in light of a survey carried out by the FSAI on unpasteurised plant-based fermented beverages (such as kombucha, kefir and ginger soda). The survey results identified a problem with the alcohol content of some beverages. Under EU labelling rules, the alcohol content of food products containing more than 1.2% alcohol by volume must be declared in order to inform consumer choice. Failure to comply with these declaration requirements means that such products can pose a risk to vulnerable consumers such as pregnant or breastfeeding women or people with underlying health conditions who unwittingly consume alcohol. People’s livelihoods may also be affected where even low levels of alcohol are not permitted, for example drivers with learner permits, operators of heavy machinery and airline pilots, among others. The new guidance will inform the industry about how best to comply with EU and Irish food law, and enable the safe and consistent production, storage, handling and display of plant-based fermented products.

The FSAI states that in Ireland and other countries there has been an increase in the popularity of unpasteurised plant-based products over recent years. Manufacturers, whether artisanal or larger commercial entities use a variety of production methods and ingredients, which means that product content and quality may be inconsistent. The process of fermentation is not new to food production, but a basic understanding of the biological process involved with fermentation is required to ensure that the final product is safe to consume. Unpasteurised fermented beverages in particular carry more risk because under certain conditions, fermentation can continue during handling and storage which can lead to an accumulation of alcohol to significant levels.

The FSAI’s survey examined a representative sample of 32 plant-based fermented beverages on the Irish market and sought to determine the level of compliance with EU and Irish food labelling and health claims legislation. Of the 32 samples analysed:

• 13% (4) had undeclared alcohol at concentrations above the labelling threshold of 1.2% alcohol by volume. Undeclared alcohol was at 1.5 - 3.9%.
• 91% (29) had unauthorised nutrition and/or health claims. Such as ‘full of goodness’; ‘contains live cultures’.
• 75% (24) were missing mandatory labelling information such address of producer, list of ingredients and best-before or use-by date.

According to Dr Pamela Byrne, Chief Executive, FSAI the new guidance will assist those producing unpasteurised fermented plant-based products to produce safe and legally compliant products. “The methods used in producing unpasteursied fermented plant-based products can be difficult to manage. Fermentation can continue during handling and storage, which can lead to an accumulation of alcohol. The inadvertent consumption of alcohol (up to 3.9% according to the survey) could pose adverse health issues for vulnerable consumers like pregnant or breastfeeding women. There are obvious consequences too for those employed in professions where there are restricted levels of alcohol permitted such as certain categories of licensed vehicle drivers, machine operators and airline pilots.”

“The guidance will help producers to achieve consistent production methods, safe storage, safe handling and safe transportation of fermented beverages. It also provides guidance about the labelling requirements for prepacked fermented products. Food labels provide consumers with key information on the properties, ingredients, nature and characteristics of prepacked food to enable them to make informed food purchasing decisions.”