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Truffle with aroma?

  • 11/04/2026
  • Posted by: Marta
  • Category: Questions and answers
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truffle slices in a jar

Dear Dongo Lawyer,

I am sending you the label of a jar of “dried truffle slices” which lists among the ingredients: “Dried summer truffles (Tuber aestivum Vit) 99%, flavor”. Is it possible to add artificial flavors to this type of product?

Thank you very much, [signed letter]

Regulation (EC) No. 1334/08, so-called Food Flavourings Regulation, defines in Article 4 the 'general conditions of use of aromas or food ingredients with flavoring properties':

  • 'may be used in or on foods only aromas or food ingredients with flavouring properties that meet the following condizioni:
    a) on the basis of available scientific data, do not present a risk to the health of consumers and
    b)     their use does not mislead the consumer'(art. 4).

The addition of artificial flavors to products'a basis of' truffle is formally permitted by European legislation, provided that the general principle of non-deception expected both from the Food Flavorings Regulation (EC Regulation No. 1334/08, Article 4.1.b), both from Food Information Regulation (EU Regulation No. 1169/11, Article 7).

In the specific case, however, the product raises serious critical issues which, in the opinion of the undersigned, compromise compliance with the aforementioned regulations, as well as with the Consumer Code (Legislative Decree 206/05 and subsequent amendments).

The discrepancy between denomination and actual composition

The product in question is presented under the name 'dried truffle slices' and lists the ingredients: 'Dried summer truffles (Summer tuber Vitt.) 99%, aroma'.

The name 'dried summer truffles' describes a food consisting of exclusively Made from truffles subjected to a drying process, without any added ingredients foreign to the product's natural matrix. Consumers reading this name expect to purchase an authentic, single-ingredient product, obtained by simply dehydrating the fungal biomass.

The presence of 1% of aroma artificial – in the absence of the specification 'natural' or 'natural truffle' – radically contradicts the sales denomination, since it configures a discrepancy between:

a) the declared nature of the product, 'dried truffle slices';

b) the true nature of the product, 'dried summer truffles' + artificial flavor.

The sales denomination

Regulation (EU) No 1169/11 establishes in Article 17 the criteria for the name of the food, prescribing that it be:

  • la legal name (when required by Union or national legislation);
  • in the absence of the latter, the usual denomination;
  • in the absence of a legal or usual name, a descriptive denomination.

The name 'dried summer truffles' is a descriptive denomination pursuant to Article 17.1.c of EU Regulation 1169/11. It describes the product as consisting of dried truffles, without any reference to additions, flavourings or modifications of the original matrix.

The insertion of artificial flavoring makes this denomination misleading and non-compliant in Article 17, since:

  • it is not precise enough to enable consumers to 'know the true nature of the food' (Article 17.1.c), omitting the fact that the product has been artificially flavoured;
  • misleads on the actual composition, suggesting that it is dried truffle pure, while the product contains an aroma that substantially modifies its sensory profile.

The ingredients list does not resolve the discrepancy

The presence of the word 'aroma' in the list of ingredients is not sufficient to resolve the discrepancy between the name and the actual composition, for the following reasons:

a) principle of information hierarchy: the name of the food constitutes theprimary information which guides consumer choice and is perceived as faithful description the nature of the product. The list of ingredients, while mandatory, has a secondary and detailed function, and is consulted by a smaller percentage of consumers. The name therefore prevails in shaping expectations and purchasing decisions;

b) perceptual asymmetry: the average consumer who reads 'dried summer truffles' expects a product natural and whole, without any additives. The presence of 'artificial flavoring' in the list of ingredients, printed in much smaller characters and relegated to a less visible position, does not correct the expectation created by the denomination, even more so since the consumer is not aware that the aroma – even if present in a minimal percentage – dominate the organoleptic perception of the product;

c) violation of the principle of non-deception: Article 7.1.a of Regulation (EU) No. 1169/11 prohibits food information from being misleading.as regards the characteristics of the food and, in particular, the nature, identity, properties, the compositionThe name 'dried truffle slices' leads consumers to believe that the product consists only of dried truffle, while in fact it has been artificially flavored. This discrepancy it cannot be healed by merely displaying the aroma in the ingredients list, since the name remains misleading.

Summer truffle and sensory manipulation

Il Summer tuber Vitt. (summer truffle or score zone) Is the least valuable truffle among the species admitted to trade in Italy (law n. 752/85). Characterised by a faint scent, often described as 'mushroomy' or 'herbaceous', the scorzone has significantly less intense aromatic notes than the prized black truffle (tuber melanosporum Vitt.) or white truffle (tuber magnatum Pico), whose prices can be ten or twenty times higher (Dongo, 2026a, 2026b; Dongo et al., 2023).

Addition of 1% artificial flavor has theobvious purpose of:

  • mask the organoleptic nature of the species used, giving the product an odor that does not belong to the Summer tuber;
  • simulate aromatic characteristics typical of more valuable truffles, leading the consumer to perceive the product as having a different quality than the real one;
  • compensate for the loss of volatile compounds due to drying, without resorting to higher quality raw materials or more environmentally friendly manufacturing processes;
  • confuse the consumer on the true identity of the truffle, exploiting the expectation that a product labelled as 'truffle' possesses the typical aroma of prized varieties.

It is, in essence, a sensory adulteration and counterfeit consumer perception of the variety and quality of the truffle used, violating the principles of transparency and commercial fairness.

Provisional conclusions

The name 'dried summer truffles' applied to a product containing artificial flavoring configures in the opinion of the writer a violation of Articles 7 and 17 of Regulation (EU) No. 1169/11. Without prejudice to the hypothesis – which cannot be ruled out – that the offence may constitute the crime of commercial fraud (Criminal Code, Article 515).

To ensure compliance in accordance with European legislation, the product should be presented with a descriptive name that is faithful to its actual nature and composition, such as for example 'Flavored dried summer truffles'.

It is worth adding that the name of the food must be shown in the same visual field as the quantity of the product (EU Regulation No. 1169/11, Article 13.5).

Dario Dongo

References

  • Regulation (EC) No 1334/2008 of the European Parliament and of the Council of 16 December 2008 on flavorings and certain food ingredients with flavoring properties for use in and on foods. Consolidated text: 02/16/2026. http://data.europa.eu/eli/reg/2008/1334/2026-02-16
readings: 821

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