Pangoccioli, food denomination. The lawyer Dario Dongo answers

Dear Dongo Lawyer,
I have read some of his articles on food naming, I ask you if there are legal limits to the use of the name "bread" on bread-making products with a complex recipe, as in the case of Mulino Bianco's "Pangoccioli".

thank you

Ludovica

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

Dear Ludovica,

bread-making products are governed, in Italy, by law 580/1967 and the subsequent DPR 187/2001. In addition to being subject to the general requirements of reg. EU 1169/11. The aforementioned national regulations contemplate the possibility of naming bread referring to the flour used - eg. 'bread of type 0', 00, 'wholemeal bread' - or alternatively, using the words 'Special bread with…'.

In the case of using additional and / or different ingredients compared to the basic ones - flour, water, yeast and salt (1) - the name of the food must be integrated by citing the characterizing ingredient (eg. 'milk bread',' oil bread ').

The quantity of the characterizing ingredient it must also be specified, in the ingredients list - or alternatively, next to its name in the denomination of the food - on the label of the prepacked bread. (2) It is also necessary to specify any peculiarities of the composition that distinguish the product from the basic recipe (eg 'type 0 bread without salt', or 'without yeast'). In addition to having to indicate in the denomination the use of different flours (eg 'spelled bread', oats, etc.).

A baked confectionery product - in the humble opinion of the writer - it can be designated as 'bread' only on condition of substantial compliance with the basic formula (water, flour, salt, yeast). In other words, the possible addition of a limited number of additional ingredients cannot distort the characteristics of the 'bread'. Otherwise, a descriptive name must be used, such as 'baked confectionary product'. (3)

The label of Mulino Bianco's 'Pangoccioli' it is therefore problematic. Given that the 'bread' is referred to both in the commercial name and in the denomination ('type 0 bread with chocolate chips, eggs, sunflower oil and sugar'). The variety and quantity of the ingredients used, however, obviously cannot reconcile with the name used.

'Pangoccioli' - Type "0" bread with chocolate chips, eggs, sunflower oil and sugar
Type "0" soft wheat flour, water, chocolate 13,2% (sugar, cocoa mass, cocoa butter, flavoring, emulsifier: sunflower lecithin), fresh eggs 8,9%, glucose-fructose syrup, oil sunflower seeds 5,8%, sugar 4,5%, mother yeast 2,5% (water, fermented wheat flour), wheat gluten, flavorings, mono- and diglyceride emulsifiers of fatty acids, yeast, salt.

Law 580/1967 expressly prohibits from 'use flours with characteristics other than those established by this law for bread making, pasta making or other food uses'. Also forbidding to 'add foreign ingredients'. (4) While 'the use of ingredients other than those indicated in this article must be authorized by decree of the Minister for Health, in agreement with the Ministers for Agriculture and Forests and for Industry, Commerce and Crafts; the decree establishes the rules and procedures for the use and, if necessary, for the production and trade of the authorized ingredients. ' (5)

Cordially

Dario

Footnotes

(1) See law 580/1967, article 14
(2) See reg. EU 1169/11, art. 22. This rule does not apply in the case of pre-wrapped bread, pursuant to Presidential Decree 502/1998. Although recommendable, with a view to transparency and fair information practices
(3) When a usual denomination is not applicable, such as 'brioche' or 'sponge cake'
(4) See law 580/67, articles 12, 18
(5) However, it appears that no further new ingredients have been authorized than those already peacefully admitted