Acrylamide reduction

Upcoming EU acrylamide legislation – webinar

Flemming Mark Christensen (moderator)

Hello, my name is Flemming Mark Christensen, and I’m very happy to welcome you to our webinar on the upcoming EU legislation on acrylamide. We’ll discuss the new legislation and some of the issues we think are very important for you to be aware of. In today’s program, we’ll talk about why we think this is an important issue to deal with right now. We’ll have a session on what the new acrylamide legislation will actually be about, and then some practical examples of how we use asparaginase in food applications to mitigate acrylamide content. Last but not least, we’ll have a Q&A session, and we strongly encourage you to post questions during the session so we can have some interesting discussions at the end.

Of course, I’m not doing this alone. I’m joined by two of my colleagues: Nadine Jimenez from our technical service and Søren Langkilde from regulatory affairs. But I will take the liberty of starting on the first topic: why the new acrylamide legislation is something you should care about.

The food industry faces a number of challenges these years. Probably one of the biggest is the informed consumer. Consumers are very well informed, via social media and the internet, about food, how it’s made and where the raw materials come from. That means there is a very big need for transparency – consumers want to know about their food. It has also led to increased interest from legislators in tightening regulation to make sure consumers get the food they want.

Another very important development in recent years is the understanding that food is closely linked to health. There is a much greater awareness that what you eat has a significant impact on how you feel, your health and how you look. As a result, the demand for documentation showing that food is healthy and safe is exploding.

That’s not a phenomenon only of Western Europe or North America – we see it across all regions. Here we have market data from a study asking consumers whether they agree with the statement: “I want to know everything that’s going into my food.” Across regions, agreement was very high, between 67% and 77%. So it’s relevant worldwide, not just in one small region.

Acrylamide is one of the issues that is very topical. The European Union already has legislation on it, passed a few years back. At that time, benchmark levels were introduced, and in principle food could be potentially non-compliant.

Food companies were encouraged to mitigate the acrylamide content of a number of food items. To support that, FoodDrinkEurope introduced what it calls the Acrylamide Toolbox, which sets out different technologies for dealing with acrylamide limits. Now things are changing.

A draft of new EU legislation is coming that could introduce maximum levels. That could mean foods above these maximum levels are non-compliant and cannot be sold – you would either have to withdraw them from the market or not put them on the market at all. We will hear much more about that in the second part of the webinar.

Acrylamide is increasingly getting out into the public already, even before the new legislation. Acrylamide content is becoming a regular part of consumer food tests. When consumer magazines test various foods, they very often test acrylamide content too. That means it is served right on a plate to consumers that this or that product contains this much acrylamide.

That of course raises awareness. Here we have examples from the UK and Norway, where acrylamide content in potato-based products has been in the public eye and food companies had to engage in dialogue on the topic. So it is out in the public.

But it’s not only out in the public – it’s also a topic for retailers. Increasingly, retailers are putting limits on the acrylamide content of products on their shelves. Here we have the current EU benchmark levels for a number of categories. One of the leading retailers in Europe, Lidl in Germany, has set its own limits and works with food producers to lower these values. Food producers who want their products on Lidl’s shelves must comply with these values.

Lidl is not the only retailer doing this; we know other retailers are too. So it’s not only about answering to consumers, but also about making sure you can get your products onto retailers’ shelves.

It’s also interesting to see that the public language around acrylamide has sharpened.

You may know Proposition 65 from California, introduced quite some years back, under which food producers had to warn consumers, with a label in shops, that a product contained acrylamide, which was said to be potentially dangerous and to cause birth defects and other reproductive harm. Now the language has sharpened: the warning must now state that acrylamide is known to the State of California to cause cancer, birth defects or other reproductive harm.

This is of course in the United States, but it shows that the public dialogue on acrylamide is getting more focused, more public, and the language a bit stronger.

That’s why we think the time to react is now. We know the legislation is coming – there’s no doubt about that. We don’t know exactly what it will be, but it is very likely to contain maximum limits above which you cannot sell your product.

Based on the values we’ve seen so far in the draft legislation, we estimate that up to 20–25% of all products could be in the danger zone. It’s also a question of having sufficient uniformity in your process, so that you are sure that not even one or two batches – let alone a large number – go above the limit, because then you would have to discard them.

It’s also clear that discussion of new legislation will push the topic much further into the public eye. That means consumers will start coming to you as a food company, via social media or other channels, and asking: what are you doing about this? Do you measure your acrylamide content? Do you do anything to reduce it? And that of course carries a very, very big risk for criticism in social media. And therefore our notion is that we don’t think you can wait. The time is now to start working on it and get your products in compliance with the new legislation. And talking about the new legislation, I’ll now hand the word to my colleague Søren from regulatory affairs who knows much more about the details of that. Søren, please.

Søren Langkilde

Thank you, Flemming. Following these introductory words on the importance of acrylamide, I’d like to dig a little deeper into the current EU regulation on acrylamide in food, and look at how it might develop in the future.

Back in 2002, acrylamide was identified as a potentially harmful compound formed in food.

From that discovery on, a number of scientific bodies – such as JECFA, the NTP in the US, EFSA and so on – looked further into this and issued guidelines on how to reduce acrylamide formation in different food categories. And eventually, as Flemming mentioned, in 2018 the EU Commission put into force a new EU regulation governing acrylamide content in specific food categories.

What we know now is that the EU Commission is looking at updating the regulation, or introducing a new one, with updated acrylamide levels. I’ll come back to this a bit later.

It’s not only in the EU that we’ve seen increased focus on acrylamide levels in food. In a number of other major regions, authorities have also increased their focus on acrylamide formation. They have initiated major surveys and analyses to establish better insight into whether acrylamide levels in different food categories are problematic, and authorities are introducing guidelines and measures on how to reduce them.

The current 2018 EU regulation, which harmonizes the regulation of acrylamide in food, has three key pillars. The first is that food business operators (FBOs) now need to sample and analyze relevant food products for acrylamide.

Having done that, they need to compare these results with the corresponding benchmark levels in the EU regulation – I’ll come back to these shortly. And if the acrylamide level in a product exceeds the corresponding benchmark level, the food business operator needs to initiate mitigation measures to reduce the level of acrylamide in that food.

These mitigation measures can cover different approaches to reducing acrylamide in your food. That could be changing raw materials, applying enzymes like asparaginase in the process to reduce acrylamide formation, and of course looking at your food processing – the heating processes and so on – which could be changed to reduce acrylamide formation.

So, as I said, we already have an EU regulation with benchmark levels for acrylamide in specific food categories. But we know the EU Commission is also looking to update it, or introduce a new regulation, in the near future. Back in October 2020, the EU Commission presented a draft to the European Parliament proposing a revised set of benchmark levels and introducing maximum levels, as Flemming mentioned at the beginning of this webinar.

This proposed regulation was rejected by the European Parliament. Parliament asked the Commission to go back and work further on a new draft. It wanted stricter benchmark and maximum levels, and it asked the Commission to broaden the scope of food categories covered by the regulation.

So the Commission went back and has been working with the member states on an updated draft. Last summer, a new draft was presented for a targeted stakeholder consultation, with revised benchmark and maximum levels compared with the original draft.

So let’s look in more detail at what benchmark levels – which we already have in the current regulation – and future maximum levels mean for the compliance of your food products. Foods with an acrylamide level higher than the corresponding benchmark level in the EU regulation would be potentially non-compliant.

As I said, the food business operator – the food manufacturer – then needs to mitigate acrylamide formation to bring the level down to, or below, the benchmark level. That could be by changing your processes, applying enzymes like asparaginase, or other approaches.

If you are able to reduce the acrylamide level to the benchmark level, you would be allowed to continue marketing the product, with everything evaluated case by case by the local competent authority within the EU. However, maximum levels – which we know the EU Commission intends to introduce with this new regulation – are different. A food containing acrylamide above a future maximum level would certainly be non-compliant. The food business operator would immediately need to stop marketing it, either withdrawing the product from the market or even carrying out a recall.

So there’s no doubt that introducing maximum levels has a much more severe impact on compliance for products that exceed the acceptable levels. Let’s take a short look at the proposed new levels compared with the current benchmark levels.

Comparing the proposed new benchmark levels in the Commission’s latest draft with the suggested maximum levels: for infant and baby food, as one example, the Commission suggests keeping the current benchmark level for some categories and introducing a maximum level slightly above it.

For other categories, such as biscuits and rusks for infants, the Commission proposes reducing the current benchmark level and again introducing a corresponding maximum level. For biscuits, wafers and crackers, the proposal makes clear that the acrylamide levels accepted in products for infants and babies are significantly lower than those accepted for the same product categories aimed at the rest of the population. That obviously makes sense, as infants and babies are the most sensitive consumer group.

Looking at potato products, for French fries, as one example, the Commission proposes keeping the current benchmark level and introducing a new maximum level: a benchmark level of 500 micrograms per kilo and a maximum level somewhat above it, in this case 850 micrograms per kilo. For potato crisps made from fresh potatoes and from potato dough, the Commission proposes slightly lowering the current benchmark level and again introducing a maximum level.

For breakfast cereals, some benchmark levels are proposed to stay the same, while others will be reduced. And as you can see on the right-hand side, the Commission proposes introducing strict maximum levels for all of these categories.

As I said at the beginning, the Commission has also proposed broadening the scope of food categories covered by the EU acrylamide regulation. With this new draft, the Commission proposes extending the list to include products like rösti, black olives, onions, cocoa powder and so on.

The Commission not only proposes extending the list of food categories, but also puts forward proposed benchmark levels for them, and links each new category, such as cocoa powder, to one of the mitigation recommendations in the current regulation. That way, food business operators at least have a starting point for mitigating acrylamide levels that are too high.

Finally, where are we now, and when can we expect the new EU regulation to be in place? As I said, the first EU regulation came into force in 2018.

A number of drafts have been presented for stakeholder comment, and we expect the Commission and the member states to go through several more iterations before they are ready to present a final draft, first to the EU Standing Committee for approval, and then to the European Parliament. So it’s difficult to give a solid estimate of the timing, but the best guess right now is that a new regulation will be in place sometime in 2023,

possibly with a transition period for food business operators to adapt to the new levels. With that, I’ll hand over to my colleague Nadine, who will explain in more detail how you can work with enzymes to mitigate acrylamide formation in food.

Nadine Jimenez

Thank you very much. After the regulatory framework, I’ll talk about what you as a food manufacturer can actually do in practice to reduce your acrylamide levels. The contaminant acrylamide is formed naturally in many food products as a by-product of the Maillard reaction. Acrylamide levels are highest at very low moisture content and high temperatures, as you can see on this graph. Starchy foods like potato-based products and baked goods are especially affected, but so are other foods, like coffee and much more.

If you are a food producer and don’t know where to start, the Acrylamide Toolbox published by FoodDrinkEurope – first in 2005 and continually updated since – gives very good guidance. For each product category, it shows ways to reduce acrylamide through raw material, recipe or process changes.

However, if you want to implement any of these changes, you also have to make sure the product is still safe from a chemical and microbiological standpoint, that it keeps its nutritional attributes and, last but not least, that the texture, taste and appearance of your product are unaffected, because changes there might affect consumer acceptance.

For all these reasons, we believe the enzyme asparaginase has all the answers when it comes to acrylamide mitigation. Applying asparaginase will not change any of the organoleptic properties of your product, and therefore helps maintain your product quality.

Let’s take a closer look at how acrylamide is formed. As I said, acrylamide formation is part of the Maillard reaction, which gives your food its typical browning, flavor and appearance. In the presence of reducing sugars such as glucose, which you find a lot in starchy foods, and the amino acid asparagine, in an environment of low moisture and high temperature, acrylamide is formed through a cascade of reactions.

If you want to mitigate acrylamide, you can add our enzyme, Acrylaway®, before your heating or roasting step. The enzyme converts the amino acid asparagine into another amino acid, aspartic acid, which will then react during heat treatment. This means the Maillard reaction itself won’t be affected during food production, and you will still get the same taste, appearance and flavor in your product. The enzyme works very efficiently and can achieve a significant acrylamide reduction of up to 90%.

Let’s look at a few examples where we have successfully applied our enzymes in different food applications to mitigate acrylamide. We have done trials on processed potatoes, for example. By only adding our enzyme to the potato dough, with no process modifications, you can achieve around 90–95% reduction of acrylamide in the final product. In this case, we reduced acrylamide in potato snack pellets expanded in frying oil.

On the right-hand side, you see another example: using our enzyme in the production of breakfast cereals – in this case, extruded wheat and bran flakes – where we could reduce acrylamide levels by 75%.

And last but not least, potato-based baby puree, where our enzyme worked efficiently and reduced acrylamide levels by 80%.

To sum up, Acrylaway® can be applied across a broad range of applications, pH and temperature ranges, and you can target different reduction levels depending on the food category. Applying the enzyme will ensure you are well within compliance by significantly reducing acrylamide formation. And using Acrylaway® does not affect final product quality – taste and texture are maintained. That allows you to meet the demands of health-conscious consumers and retailers.

We are expanding our knowledge and looking into all the food categories now new on the EU list, such as cocoa, fruit and vegetable chips, rösti and croquettes, and processed onions. We will investigate how the enzyme can be used in those manufacturing processes and how far acrylamide can be reduced. For this, we are always looking for industry partners who bring the required expertise.

Now I want to introduce a new tool we have just launched. It’s an easy-to-use digital calculator to check whether your products comply with the existing legislation, and also to check your compliance against the new EU proposed benchmark and maximum levels. Simply click on this link and you are directed to our website, where you find the tool. Click on “Check now” and you are asked to select your industry. Let’s say you work in the infant food industry: you click on “Infant food” and then “Continue”.

Then you are asked to select your product category. Let’s assume you are a baby puree manufacturer, so you select the first row, “Baby foods”, and click “Continue”. Now you are asked to enter the current acrylamide level in this product. If you don’t know your current acrylamide level, or don’t know where and how to measure it, you can always ask us and we will help. Let’s assume you have 100 ppb: you enter 100 and click “See your compliance”.

Now the tool gives your compliance score against the current benchmark levels and against the proposed benchmark and maximum limits. In this case, you would be above the maximum limit, and therefore at high risk of having to stop selling the product.

If you scroll a bit further down, you can order a free sample of one of our products. Here you can see three products suggested for this category: the standard granulate version, Acrylaway®; the liquid version, Acrylaway® L; and a HighT L version that works at higher temperatures. If, for example, you want to select Acrylaway® liquid, you go to “View ordering options”, click on the button, and you get a description of the product and guidance on how to use it. You can then click “Order a free sample” to try it,

and add it to your shopping cart. If you don’t know which product to choose, or need further guidance for your specific process conditions, you can always book a meeting with us directly on our website by selecting a date and time that works for you. Now let’s get back to our presentation. You will find all the free service tools I just showed you under this link. That’s all from my side. If you have more technical questions, please add them in the question box. Now I hand back to Flemming.

Flemming Mark Christensen

Thank you, and very interesting points from your side. We would now like to make a short conclusion: new acrylamide legislation is coming in the EU, and it will also cover foods imported into the EU. We don’t yet know exactly what the legislation will look like, but it is very likely that maximum levels will be introduced, above which you cannot sell your product. In that context, it is very important that you can control your levels and the variability of your process and raw materials.

So in our view, it is time to look at this now – you cannot wait – and we strongly encourage you to start working on getting your products compliant with the new legislation. Thank you for your attention to this webinar. We are now ready to move to probably the most exciting part: the questions you have posted during the webinar.

You have posted a lot of very interesting questions during the webinar. I encourage you to keep posting questions during the remaining 20 minutes or so. We can’t guarantee we will get through all of them today, but we can guarantee that we’ll come back to you with an answer afterwards if we don’t have the chance today.

I’ll go through some of the questions and distribute them to my colleagues. There are quite a few questions about the legislation and its impact – in terms of how the benchmark values were arrived at, and how it will influence labelling. Is that something you can talk a little about, Søren?

Søren Langkilde

Yes, Flemming, I can. When we talk about applying asparaginase in the process to reduce acrylamide formation, the enzyme is categorized as a processing aid – it has its intended technological effect during processing of the food. As such, not only in the EU but globally, the enzyme as a processing aid would be exempt from labelling on the final food. So the ingredient list of the final food would not change due to the use of asparaginase.

Flemming Mark Christensen

Maybe just one more point: I guess the benchmark values have also been set based on an evaluation of consumption patterns for the various product types, and who consumes them?

Søren Langkilde

Yes, that’s correct. As we saw in the presentation, benchmark values vary quite a bit between categories, and the benchmark levels are chosen on the basis of a general safety evaluation. One example is that acceptable acrylamide levels in foods for infants or babies are much lower than in the corresponding categories of food marketed to adults.

Flemming Mark Christensen

Right, thank you. There is also a question about labelling: will we need to label treatment with asparaginase on a food product?

Søren Langkilde

Again, as I said, asparaginase treatment is a processing aid use, and processing aids are typically exempt from labelling on the final food.

Flemming Mark Christensen

Okay. Nadine, maybe you have a few things to add, because I guess it also depends on the specific product and process conditions.

Nadine Jimenez

Can you repeat the question? On labelling – whether treatment with asparaginase has to be labelled – maybe I can also comment from the technical angle. I see the same question also asks whether it affects the sensory characteristics. That one I can answer for sure: no. The benefit of the enzyme technology is that it has absolutely no effect on any quality parameters, so neither taste, texture nor appearance are affected. There are also other solutions for mitigating acrylamide, summarized in the toolbox I mentioned,

and you can also use a combination of them. But be careful, because other technologies might affect sensory or quality parameters – baking at lower temperatures, for example.

Flemming Mark Christensen

And that is of course one of the big advantages of asparaginase treatment: you don’t affect the texture and taste of the product, so the consumer won’t notice that you’re doing something to it. There is also a question about legislation outside the European Union.

Søren, maybe you can comment on that, and also touch on what it means for food producers outside Europe who export food to the EU.

Søren Langkilde

Yes. Addressing the last part first: the current EU regulation not only harmonizes acrylamide levels in foods produced within the EU, but also regulates acrylamide content in foods imported from third countries. So food business operators importing foods into the EU for marketing there also need to comply with the acrylamide regulation.

On the other question – how acrylamide legislation is developing in the rest of the world – it’s very clear that the focus on acrylamide, and the safety concerns about acrylamide in food, have grown over the last couple of years. I think the EU regulation was the first major regulation on acrylamide. It came on the basis of a number of surveys and investigations conducted by EU member states’ national authorities in the years before its introduction. So the regulation was based on safety evaluations and on building data and knowledge on the actual content of foods marketed in the EU. We see the same in a number of other countries – the US, Southeast Asia, China and so on – where authorities are focusing on building the same knowledge, carrying out a lot of surveys and analyses to establish a basis for potential future regulation. A number of authorities have also already published guidance in different areas, so that local food business operators can address their levels and take measures to reduce them. One example is the recently published guidance from Indonesia on processed coffee. We see these trends in a number of major markets globally.

Flemming Mark Christensen

Okay, thank you. We also have quite a few questions about baby food applications.

In which baby food applications do we believe asparaginase can be used? Nadine, can you speak a bit about that?

Nadine Jimenez

Yes, sure. First of all, Acrylaway® can be applied in any process that has a mixing step before heat treatment, which gives the enzyme time to do its job. Obviously, the temperature and pH should also be right for the enzyme to work efficiently.

I would always advise measuring certain analytical parameters – the amino acids asparagine and aspartic acid, or acrylamide itself – to see whether the enzyme has worked in the specific application. For infant food, we know the enzyme is already used in baby puree, baby biscuits, rusks and cereals, for example. But it can certainly be applied in other processes too, such as infant formula, which we know can be very high in acrylamide, especially hydrolyzed infant formula.

For infant formula, you will need to use the granulate version of our product, without glycerol, because glycerol is not allowed in infant food.

Flemming Mark Christensen

Okay, thank you. We also have quite a few questions about potential applications in coffee. Does the enzyme work in coffee too?

Nadine Jimenez

Yes, we have seen some remarkable results in reducing acrylamide in coffee, and it does work. You can get a reduction of up to 60% in coffee. To make the enzyme work, though, you need some sort of steam treatment in the process, and a water blending step. The steam treatment is necessary to crack open the coffee bean cells so the enzyme can penetrate. We know this process is used for decaffeinated coffee, for example, and also to reduce off-flavors in Robusta coffee. So if you already have a steam treatment in place, it’s easier to incorporate the enzyme – or else you could outsource the step to a decaffeinator, for example, who already has it in place. But you can always reach out for further details.

Flemming Mark Christensen

Okay, thank you. There are also a few questions about the optimal working conditions – the optimal temperature for the enzyme. Can you elaborate on that too, Nadine?

Nadine Jimenez

Yes, sure. We have actually developed two different products: one has its optimal temperature at around 60°C, and the other works best at 90°C.

There’s always a range in which the enzyme works, and if you are outside the optimal temperature, you need to adjust the process time or the enzyme dosage.

Flemming Mark Christensen

Okay, thank you. Whatever material you’re working with, you’ll always be keen to track how the enzyme treatment is progressing. Can you speak a bit about that, Nadine?

Nadine Jimenez

You mean the analytical part? To track the process, I would advise measuring the content of the precursors – the amino acid asparagine – and aspartic acid, by HPLC.

Unfortunately, there is no rapid analytical method you can use online. The best approach is to analyze the amino acids, or of course acrylamide itself – but for that, I guess you would work with an external laboratory that has established the method. The current benchmark method for measuring acrylamide is LC-MS/MS.

I also want to say that the main analytical challenge is the high variability of the food products themselves, which is influenced by natural variability in asparagine levels in the raw material, and by process conditions such as heat exposure. So you often see high variability in acrylamide results, even within the same batch and on the same production line.

Flemming Mark Christensen

Okay, thank you. We also have a question that I think is very interesting, and one we get quite often: the GMO status of the enzyme. Does Acrylaway® contain GMOs, and is it produced from GMO material?

The answer is no, because an enzyme is not a GMO. GMO means genetically modified organism, and we’re talking here about an enzyme – a protein used in the process, in most cases as a processing aid that requires no labelling. It is true that Acrylaway® is produced with modern biotechnology, but you will find no traces of the microorganisms, or of microorganism material, in the final product. So we can safely say that the product is GMO-free. It’s a question we hear quite often, so I think it’s an important one to touch on. There was also a question on using the enzyme in biscuits – how do you use the enzyme in biscuits? Nadine, can you comment on that?

Nadine Jimenez

I was muted. For biscuits, I would suggest that our baking expert reaches out to the person who asked this question, because I’m more familiar with the other processes.

But I see there’s also a question on the benchmark levels for biscuits, so maybe Søren could answer that?

Søren Langkilde

Yes, I can certainly do that. On benchmark levels, we need to observe the current benchmark levels in the EU regulation.

Those are the levels we have now, but we also have suggested revised benchmark levels in the future regulation, and potentially maximum levels. For biscuits, there’s a category called biscuits and wafers, with a current benchmark level of 350 micrograms per kilo. As of now, the proposed new benchmark level for this category is 300, and the suggested maximum level is 500 micrograms per kilo.

Flemming Mark Christensen

Thank you. There are also a couple of interesting questions on one of the new areas coming up in the legislation: chocolate and cocoa powder. The question is whether we have any experience with it. I dare say we don’t have a lot of experience – we have only touched on it briefly.

It’s certainly something we would like to dive further into. We’ve done a few preliminary trials indicating that we could reduce acrylamide by around 30–40%, but it’s an area we haven’t worked much in yet. It definitely deserves a closer look to see if more can be done, and I’m pretty sure more can be done in that area. We have a few other questions – just hang on a second.

Sorry, I got a bit lost – hang on a second. There is a question on organic labelling. Søren, is that something you could elaborate on?

Søren Langkilde

Yes, I can certainly do that. Using the asparaginases marketed by Novozymes in the production of various food categories unfortunately restricts the use of organic labelling on the final food. Again, as we discussed, this is because the enzymes are produced by microorganisms that have been modified using modern biotechnology, which is not accepted within the organic framework in the EU, or in most other major markets.

Flemming Mark Christensen

Okay, we are slowly coming to the end of our webinar. We have one minute left, and I’ll use it to summarize. The conclusion is that new legislation on acrylamide is definitely coming in Europe. At this point it’s a little uncertain exactly what it will be, except that it will be tougher than the current legislation. And the risk of running into major problems in your consumer communication is very high if you don’t do anything about it. So we think the time is ripe to start acting, and we think asparaginase is a very good tool for doing that. Thank you for your attention throughout the webinar. There are still quite a few questions we didn’t have time to answer, but I can assure you we will come back to each of them and answer you personally. I would also like to thank Nadine and Søren for their preparation and work on the webinar. With that, thank you once more, and have a good rest of the day. Goodbye.