Sulfites go on the label in two situations. If you add a sulfiting agent to do a job in your food, such as keeping a color or stopping browning, it's an ingredient and it's declared, like any other. If a sulfite comes in with an ingredient, sulfured dried apricots and golden raisins are common examples, and does no job in your finished food, it can stay off the label only if there's less than 10 parts per million of it in the finished food; at 10 ppm or more, it's declared. That line catches small makers by surprise, because a little sulfured fruit carries a lot: an apricot with 2,000 ppm, at 8% of a granola, puts 160 ppm in the bag. Sulfites aren't one of the nine major food allergens in the United States, but people who react to them read for them. Sulfiting agents such as sodium metabisulfite also have limits on where they can be used: not in meat, not in foods that are a source of vitamin B1, and not on fruits or vegetables sold or served raw. In the example below, a New Jersey granola maker works out whether its new apricot granola needs the word.
The short version
- A sulfiting agent added to do a job in your food is an ingredient: declare it.
- Sulfites carried in by an ingredient, doing nothing in your food, are declared at 10 ppm or more.
- Sulfured dried fruit carries enough to cross the line in small amounts.
- Work it out: share of the finished weight × the ingredient's sulfite level, added up.
- Sulfiting agents aren't used in meat, in foods that are a source of vitamin B1, or on fresh produce.
- Unsulfured fruit avoids the question, at the cost of a darker color.
- TaroStack keeps each ingredient's supplier and lot, so a change of supplier or lot traces to the batches it went into. More below.
When sulfites go on the label
| Situation | On the label? |
|---|---|
| You add a sulfiting agent to do a job in the food | Yes, as an ingredient |
| An ingredient brings sulfites, and they do no job in your food: 10 ppm or more in the finished food | Yes |
| An ingredient brings sulfites, and they do no job in your food: under 10 ppm | No |
| Meat, foods that are a source of vitamin B1, fresh fruit and vegetables | Sulfiting agents aren't used |
How ingredients and sub-ingredients are listed is in ingredient list order, and the major allergens in food allergen labeling requirements.
The rules
| Rule | Where |
|---|---|
| Incidental additives | Additives with no technical effect, present at insignificant levels, are exempt from declaration (21 CFR 101.100(a)(3)) |
| Sulfites | A sulfiting agent with no technical effect in the food is insignificant only if not detectable; 10 ppm or more in the finished food is detectable (101.100(a)(4)) |
| Where they're used | Generally recognized as safe under good manufacturing practice, except in meats, foods that are a source of vitamin B1, and fruits or vegetables served or sold raw or presented as fresh (21 CFR 182.3766) |
This is general information, not legal advice.
An example: an apricot almond granola
Pine Barrens Pantry, the made-up granola, jam and hot sauce maker in Hammonton, New Jersey, I use in these examples, added an apricot almond granola. The apricots and golden raisins it buys are sulfured, and their spec sheets give the sulfite level:
| Ingredient | Share of finished weight | Sulfite on the spec sheet | Carried into the granola |
|---|---|---|---|
| Rolled oats, almonds, honey, oil, salt and vanilla | 86% | 0 ppm | 0 ppm |
| Dried apricots, sulfured | 8% | 2,000 ppm | 160 ppm |
| Golden raisins | 6% | 1,500 ppm | 90 ppm |
| Total | 100% | 250 ppm |
At an estimated 250 ppm, far over 10, the sulfites go on the label: the ingredient list reads "dried apricots (apricots, sulfur dioxide)" and "golden raisins (raisins, sulfur dioxide)". Baking may drive some off, but the Pantry declared them rather than pay for a lab test to show a drop from 250 to under 10. It's testing an unsulfured apricot for a second version, which would carry nothing and need no declaration, but is brown instead of orange. The base granola's numbers are in granola business plan.
Get the calculator
Download the sulfite calculator. One sheet: each ingredient's share of the finished weight and the sulfite level on its spec sheet; what each carries into the finished food, the total, and whether it reaches the 10 ppm line. It's an ordinary Excel file with no macros, and it works in Google Sheets, LibreOffice and Numbers.
Where this stops working
The calculator is right for the apricots on today's spec sheet. When the supplier changes, or a lot comes in sulfured when the last one wasn't, the label and the bag stop matching, and only the receiving record would show it.
How TaroStack does it
TaroStack keeps each ingredient's supplier and lot, so a change of supplier or lot traces to the batches it went into.
Receiving by supplier and lot. Each delivery of apricots is received from its supplier with its lot and date, and an ingredient can come from more than one supplier.
Batches by lot. Each batch of granola records which apricot and raisin lots it used, so a question about one bag leads to the lots and their suppliers.
Recalls. If a lot turns out mislabeled, one report shows every customer who got granola made from it.
| The job | Spreadsheet | In TaroStack |
|---|---|---|
| Which apricot lot went into a batch | Not recorded | Batches by lot |
| A new supplier for apricots | Noticed later | Each delivery by supplier |
| Who got a batch | Invoices | One recall report |
Receiving, batches and recalls are on every plan, from $49 a month. The first 30 days are free, with no credit card. If you'd like a hand setting up, ask, and we'll do it with you.