Ingredients lists must be put together according to strict rules. Percentages may be given for some ingredients, typically those given importance by being mentioned in the legal name of the food. The ingredients list is also the vehicle for telling consumers which allergens have been used in the product.
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Ingredients list must be headed with the word ‘Ingredients’ or a phrase which includes the word.
2. Milk chocolate
Milk chocolate is the first ingredient, being that present in the highest proportion in the product. It is an important ingredient, mentioned in the name of the food and influencing consumer choice; its percentage occurrence is given.
Milk is a controlled allergen. Irrespective of any general exemptions from listing which might otherwise apply, the word ‘milk’ must, in nearly all cases, be included when it, or ingredients produced from it, have been used in the product, e.g. ‘skimmed milk’, ‘dried whey (milk)’. Additionally, the word must be emphasised every time, for instance, by being in bold text.
4. Raspberry flavour filling
This is a second compound ingredient name, after the milk chocolate, and, like the chocolate, followed by a list of its components. The components of compound ingredients can alternatively be listed without a preceding compound ingredient name and this is how the sponge ingredients have been listed, from ‘sugar, wheat flour’ to the end of the list.
5. Palm oil
All vegetable oils used in a product can be grouped together under a single declaration of ‘vegetable oils’ followed by a list of indications of specific vegetable origin.
6. Glucose syrup
This has been produced from the allergen wheat but is one of several specified exemptions from allergen labelling. It can be declared without reference to ‘wheat’ and without special emphasis.
The declarations of the ‘milk chocolate’ and ‘filling’ are now complete. The third element of the product is the sponge. Although mentioned in the name of the food, the sponge is not quantified as the amount is not directly of consequence for consumer choice.
8. Fat-reduced cocoa
This is the source of chocolate flavour for the sponge. In the UK it has long been accepted practice, formerly backed up by specific legislation, that products flavoured with sufficient non-fat cocoa solids can be described adjectively as 'chocolate'. So, as long as the non-fat cocoa solids are sufficient to give the sponge a proper 'chocolatey' flavour, the sponge can be described as 'chocolate flavoured'.
9. Raising agents
Additives are listed by permitted function name, followed by either the E number or the specific name of the additive.
10. Calcium carbonate
The calcium carbonate, iron powder, niacin and thiamin are legally-required additions to the wheat flour used for the sponge. They can either be declared immediately after the wheat flour if the flour is treated as a compound ingredient or, on the basis that they are ingredients present at less than 2% in the product, be declared separately in any order after the ingredients present at 2% or more.
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