LEGISLATION COVERING SEAWEED MANUFACTURING
Ministry of Environment and Food of Denmark sets the rules regarding the seaweed products in Denmark and this includes food safety, responsibility etc., and it is the same ministry that register the company and inspects that the companies complies with the rules, and advice and guide the companies/consumers. The company should 1) register at the ministry, and remember possible other approvals by other authorities regarding off shore facilities etc. (see other paragraph), and possibly the Nature Agency (Natura 2000 areas) under the Ministry of Environment and Food. The company need to 2) perform a risk evaluation with regards to activities to evaluate the water area where the seaweed are being harvested from the natural populations or cultivated, evaluate the species and composition, and how to handle the seaweed, and 3) the company has the responsibility to comply with the relevant rules. There is no demand for routinely sampling and analyses with regard to use seaweed for food, but the food products (or as supplements) should comply with the following rules.
The rules includes hygiene, chemical contamination, novel food, labelling, claims, organic, materials that comes in contact with the foods.
The food cannot be marketed if dangerous (article 14), the marketing cannot be misleading (article 16), and the food company has the responsibility to comply with the relevant regulations of food and do own-check (article 17). Furthermore, should the food company ensure traceability (article 18), and ensure withdrawal of possible dangerous foods (article 19). This is all described in Food regulation of EU (EF) 178/2002 of January 28, 2002. Within the decision about food to comprise dangerous for the health lies an evaluation based on the possible immediate and/or short or/and long term effect on health of people, that consume the food or the generations to come, the possible cumulative toxic effect, and the fact that a specific category of consumers can be extra sensitive with regard to health in foods that are specifically targeted this category of consumers. The food will also be evaluated if it is suited for consumption, due to contamination or e.g. decaying.
HYGIENE IN PRODUCTION
The regulation regarding cultivation and harvest of natural populations includes the protection against contamination, surveillance of zoonosis, that the environment (equipment etc.) and products should be kept clean, that drinking water or clean water should be used, issues on the employee’s health, securing against possible pests, how to handle waste, and keep records with reference to the regulation of hygiene of EU (EF) 852/2004 of April 29, 2004, declaration of hygiene (No. 788 of 24/07/2008 about food hygiene) and declaration of authorization (No. 1151 of December 12, 2011, and appendix 1).
HYGIENE IN FOOD PROCESSING
For the processing the regulation is found in the same declarations as mentioned above (plus appendix 2), and these regulations address the food stuff facilities (ground floor, toilets, sinks, ventilation, light, drain, employee facilities), the processing facility (floors, walls, ceilings, windows, doors, surfaces, sinks), transport, equipment, food waste, water supply, personal hygiene, food regulations (contaminations, pets, temperature), packaging and heat treatment.
Food and food ingredients need to have a safety evaluation and approval if they have not been consumed in notable amounts for consumption in EU before May 15 in year 1997. Species such as Saccharina latissima, Laminaria species such as L. japonica, L. digitata, L. longicruris, Chondrus crispus, Fucus vesiculosus and Porphyra purpirea are well known and does not need any further approval. However, in this register Palmaria palmata has a label on as “any other food uses of this product (than as food supplement) have to be authorized pursuant to the Novel Food Regulation”, since EU have not seen other use than as food supplement of this species. Among others, Mouritsen et al., (2013) have some proofs of this and this should be pursued and corrected.
Regulation of novel food of EU (EF) is number EU (EF) 258/97 about new foods and new food ingredients, and the list can be searched by species in the novel food catalogue (Novel food catalogue, 2016).
The chemical contamination could for seaweed be the specific compounds iodine, cadmium and arsenic (inorganic arsenic). This is not regulated for food or food supplement in EU (see paragraph above) except for cadmium that where a specific threshold is defined for food supplement in EU (Regulation (EF) 1881/2006 of December 19, 2006 about thresholds for certain contaminants in foods, changed by (EF) 420/2011). Read more on the website of The Ministry of Environment and Food of Denmark (Seaweed as food in DK, 2016) or in Holdt and Kraan (2011).
NATURAL TOXIC COMPOUNDS
The possible natural toxic compounds also need to be taken into account. This could e.g. be kainic acid in Palmaria palmata. The kainic acid is a neurotoxin similar to domeic acid accumulated in mussels and being responsible for the amnesic shellfish poisoning (Holdt and Kraan, 2011). Some studies have been made by Lüning (2008), Mouritsen et al. (2013), and by the Ministry of Environment and Food (2015) and others, data are missing to fully cover if there is a concern regarding this compound in P. palmata.
LABELLING AND CLAIM
A prepacked food is a food that has been packed in wrapping before sale, and this wrapping will usually be opened by the consumer. The prepacked food should be labelled with information regarding the product complying with the regulation about labelling (RFO nr. 1169/2011) including food information to the consumers. The company should apply if they want to claim. All statements, logos, pictures, symbols and trademarks that indicate nutritional or health properties about the given product or the effect on health are nutritional or health claims. The information of the food cannot impute a food to have properties regarding the prevention, treatment and healing of a human illness (Regulation of claims (EF number 1924/2006, and the regulation of labelling § 7, subsection 3).
MATERIALS THAT COMES IN CONTACT WITH FOOD
Generally the materials that are in contact with the food should not release compounds to the food in concentrations that can affect the health. Risks for release of different compounds depends of which food the material is in contact with and temperatures exposure (The regulation of the Parliament and Council (EF) number 1935/2004 by Oct 27, 2004 about materials and objects meant for contact with food and about cancellation of directive 80/590/EØF and 89/109/EØF; Regulation number 822 of June 26, 2013 about materials for food contact).
More details on seaweed as a food and regulations can be found online on the website of The Ministry of Environment and Food of Denmark (Seaweed as food in DK, 2016).
Seaweed in food in DK (2016). Regulation regarding seaweed as food and for the trade in Denmark, The Ministry of Environment and Food of Denmark – http://www.foedevarestyrelsen.dk/Leksikon/Sider/Tang-som-foedevare.aspx (in Danish; acccessed November 2016