Cochineal dye in the Ferragni designer pandoro. The lawyer Dario Dongo responds

Dear Dongo lawyer,

the Ferragni brand Balocco pandoro came under investigation for false correlations between the purchase of the product and charity, but nothing was said about its ingredients. The presence of cochineal coloring (E120) in the sugar-based dusting and artificial flavors in this traditional Christmas dessert seems anomalous to me. What do you think?

Thank you, Monica


The lawyer Dario Dongo, Ph.D. in international food law, answers

Dear Monica,

the baked confectionery products characteristic of the occasions (panettone, pandoro, colomba) and others that belong to the Italian tradition (amaretti and ladyfingers) are subject to specific regulations, as we have seen (1,2).

The decree of 22.7.05 of the then Ministry of Economic Development in fact restricted the use of the aforementioned names - on labels and advertising - only to products that meet specific composition and processing requirements.

1) Pandoro, production requirements

'The name «pandoro» is reserved for the soft baked confectionery product, obtained by natural fermentation from sourdough in the shape of a truncated cone with an octagonal star section and a non-crusted external surface, a soft and silky structure with minute and uniform alveolation and a characteristic aroma of butter and vanilla'. (3)

1.1) Mandatory ingredients

The dough del pandoro must contain the following ingredients:

  • 'wheat flour
  • cup sugar
  • Category 'A' chicken eggs or egg yolk derived from Category A chicken eggs, or both, in quantities ensuring not less than 4% yolk
  • butter obtained directly and exclusively from cow's milk cream with a contribution of butyric fat in quantities of no less than 20%
  • natural yeast made from sourdough
  • vanilla or vanillin flavourings
  • salt, including iodized salt'. (3)

1.2) Optional ingredients

'It is the manufacturer's discretion also add the following ingredients:

  • milk and derivatives
  • malt
  • cocoa butter
  • sugar
  • yeast, up to the limit of 1%
  • impalpable sugar
  • natural flavors [and natural identical] (4)
  • emulsifiers
  • sorbic acid preservative
  • preservative potassium sorbate'. (3)

1.3) 'Gluten-free' ingredients

An exception the composition of pandoro and other products mentioned in the introduction was introduced by ministerial decree 19.6.17, which modifies the previous one to:

– allow the use of the aforementioned names also for productssspecifically formulated for people intolerant to gluten, in compliance with the requirements set out in the reg. (EU) 828/14

– provided that the modifications to the research are limited to the use of only 'technologically necessary ingredients' to replace 'gluten-providing' ones. (5)

1.4) Process requirements

´The technological process The manufacturing of pandoro involves the following processing phases, which can also be combined:

– preparation of sourdough
– fermentation
– dough preparation with dosing of ingredients and kneading
– portioning
– pirling with deposition of the dough in the baking mold
– leavening
– cooking
- cooling down
– surface sugaring (optional)
– packaging'. (6)

2) Pandoro Balocco designed by Ferragni

The ingredients list of the 'designer' Balocco pandoro Ferragni reveals the presence of a 'pink dusting preparation in a 6,7% sachet (sugar, wheat starch, flavourings, colouring: E ​​120)' which is not at all compatible with the composition requirements indicated above , under different profiles:

– the cochineal coloring additive, E 120, is absolutely prohibited in the pandoro recipe and among other things makes it unsuitable for vegetarians, since its basic matrix is ​​literally 'chopped ladybugs' (6)

– the aromas should be exclusively natural, as the (deceptive) category of 'natural-identical' aromas has disappeared (4)

– starch in turn is not included among the ingredients of pandoro.

Cordially

Dario

Footnotes

(1) Salty panettone or brioche? The lawyer Dario Dongo answers. DO (Food and Agriculture Requirements).

(2) Panettone with extra virgin olive oil? The lawyer Dario Dongo answers. DO (Food and Agriculture Requirements).

(3) Decree of the Ministry of Economic Development of 22 July 2022, Regulations on the production and sale of certain baked confectionery products, article 2

(4) The category of 'natural-identical' flavors (i.e., synthetic flavors with a molecular structure identical to natural ones) was finally eliminated in the reform introduced with the Food Flavorings Regulation (EC) No 1334/08

(5) Gluten-free panettone? The lawyer Dario Dongo responds. DO (Food and Agriculture Requirements).

(6) Ministerial Decree 22.7.05, Annex II, point 2

(7) Cochineal, E 120. A coloring additive suitable for vegetarians and vegans? The lawyer Dario Dongo answers. DO (Food and Agriculture Requirements).



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