2 Apr 2017

Cascara Banned in the EU?

What is a novel food and why can we suddenly not drink cascara anymore?




A lot of people have read this article "Is cascara actually banned? Mixed messages in The EU" by Perfect Daily Grind the last couple of days, which was probably inspired by the video James Hoffmann of Square Mile posted recently.



The article is quite short, slightly confusing and arguably incomplete causing some misinterpretation of what is actually going on with cascara in the EU. As someone working in coffee as head of quality, which not only includes quality control of the products, but also the food safety aspect, I wanted to give some background and further information on the concept of novel food and how it is linked to the use of cascara.

what is a novel food?

The whole idea is to keep people safe and not bring anything to the food market that could be harmful or even deadly to humans, literally food safety. For the EU this is regulated through the European Commission. A novel food is a food  is a food that has:
"not been consumed to a significant degree by humans in the EU prior to 1997, when the first Regulation on novel food came into force" link
A novel food can be something that is newly developed, a food that is produced using new technologies or food that is traditionally eaten outside of the EU. 

Examples of novel foods that have recently been authorised for human consumption are chia seeds and stevia.

The EU has a Novel Food Catalogue. This lists products that are subject to the Novel Food Regulation and serves as a means to know whether a product needs authorisation from the EU to be used for human consumption. 

It is in this catalogue where we find the novel food status of cascara.

screenshot Novel Food Catalogue

So what does this statement mean?

The first time you read this statement you might think, so it's approved! However the paragraph at the bottom is crucial:

"The use of dried berries of Coffea sp in tea (coffee cherry tea) is novel. [...] It is also known as cascara [...]"
This last sentence means that cascara is not authorised to be used for human consumption. 
Although the product 'coffee' is approved, the new use of making tea out of the cherries, is novel and thus needs to be authorised.
To get authorised, companies must apply to an EU Member State, presenting scientific information and a safety assessment that shows that the product is safe. The authority then decides if an additional assessment by the European Food Safety Authority is necessary. 
The national authority can then allow the product if the European Commission and other EU countries do not object.

What does authorisation mean?

Applying for authorisation consists of scientific information and a safety assessment, which entails a product specification (levels of sugar, protein, salt, etc), a full toxin screening, a full microbiological screening, and a safety assessment where you have to try to prove that people who have consumed the product have not had any health problems due to this particular product. Not only is this very expensive, but the minimum trajectory of an application is 1.5 years. Yes, you read that correctly 1.5 years.

There is a simplified procedure called notification, where you have to establish that the novel food is very similar or has a "substantial equivalence" to an already authorised novel food. Why this is probably not enough for cascara is the fact that although it is also a coffee product, the use is completely different. Where roasting takes away a lot of risks -because of extended exposure to high heat-, the infusion of the dried cherry may not. Infusions especially under 100 degrees Celsius are tricky, food safety-wise, because it does not kill off certain risks. And there are probably different risks present when creating a syrup, or soda, or something different. New uses may require new authorisations or notifications. However it is something that is worth exploring.

So is cascara banned?

Perfect Daily Grind answers this question incorrectly:

"As the European Commission's website says, "it is recommended to check with the national competent authorities". But if they do claim that Novel Food Regulations are the issue, feel free to show them this and ask for further clarification. We'd all appreciate it!"

Now, why is this incorrect? 

As Perfect Daily Grind correctly states, even if cascara were to be approved as a novel food, national bodies might still ban it. This because EU Members still have the sovereignty to decide if a certain food should or should not be allowed. However, cascara as a whole is not authorised. An application for approval has not been submitted yet. And so there is no point to check with your national competent authorities. Cascara is currently not allowed to be used for human consumption. So if you are questioning if you should take if off of your menu? Yes, you should. 

So if it's banned, why have we been drinking it?

Good question. As coffee husks are not banned from trading -because of low, low grade coffee, which often contains some husks or dried cherries- we have been able to buy and sell cascara without national or international authorities stepping in. However, more recently there has been an increase of interest from these authorities for coffee roasters and cascara. This is probably due to the fact that coffee has become increasingly popular. Additionally, as stated in James' video, a Panamese company has been contacting national authorities about cascara, which might have set off the interest of this product in the market. 

When can we drink cascara again? A bright light in the distance?

Who knows? Fact is, an application for authorisation has not been made yet. It is extremely costly and takes a lot of time to get a product through the bureaucratic mill. There are not a lot of companies that catch enough revenue out of cascara to make this investment. The good news is that it might get a little easier in 2018, when we switch from the regulation EC 258/97 to EC 2015/2283. 
Under this new legislation other country traditional foods have a slightly more lenient regulation, where full reports and scopes are not necessary. All that is needed -and this is still hard- is proof that this food has been used in this way for a long time in an other country, and nobody experienced any health problems due to this product.
As the popularity of cascara increases, hopefully there are companies out there that will jump through this hoop for all the consumers and other companies out there.

In the mean time, we might have to be careful with what we serve. Also with the coffee flower infusions that have been popping up everywhere.

5 comments:

  1. Some random thoughts:
    Why could we be off the hook / under the radar for that long?
    How about the very common, exact similar use in Bolivia (sultana) or Yemen (qishr)? This should give a good example/ proof that this food has been used in this way for a long time, without health risks.
    Coffee Flour, and all (many!) others making products out of cascara are in trouble too? (Already arranged that a colleague brings over some flour from London while being at LCF this week)
    Could we just play dumb and act very surprised if authorities would warn and/or fine... "Oh, we thought it was all about cascara sagrada!" (The plant based laxative) ;)

    Norman

    ReplyDelete
    Replies
    1. Not sure why we were under the radar for so long. Probably due to the fact that it is difficult to be on top of everything being sold in the EU and cascara not being quite big enough to make a splash (until now).
      As for similar use in other countries, yes! This could be enough under new legislation in 2018. But for the rest of 2017 we would have to have a full report or prove common use within the EU.
      All cascara products would be unauthorised for use, including flour, soda, syrups...

      We can play dumb, but they might confiscate at that time. So might be money thrown away to buy it. :( Good thing for you and me, we can request samples anytime I guess :)

      Delete
    2. Ooo yeah!
      We'll be "traficantes de cascara" ;)
      From now on I'll be keeping my Nic, Pan & Bol stash hidden under the sample room's counter..
      As well as the inbound flour next week..
      And the two bottles of Cascara Sparkling from Gaffel cannot be drunk out in the open at my own garden terrace..

      Without the joking, there are quite a lot of companies/products from/with the forbidden fruit nowadays... Such a pity!

      Delete
  2. be honest, not you or Hoffman knows anything about this law. This is simply how you(bunch)interpret the E.U regulations.Till last week,video apparition of your Messias, nobody even question Cascara legality.
    Tell me any places in Austria or Germany that have been supposedly "ravaged" by authorities searching for Cascara ?
    And regarding coffee blossom:the only illegal activity is the way how you hipster/baristas are attempting to infuse it using your fancy / expensive / useless Hario glasses.
    Stick to coffee and keep searching for his terroir, finding some haselnut or berries ? or is it cardamom spicy ? Cmon go on and cupp it again, dont forget to whistle during it

    ReplyDelete
    Replies
    1. Hi, sorry you feel this way. Actually food safety is part of my job for a big coffee sourcer and importer. So part of my job is sensory evaluation and an other part is these types of regulations. I agree with you that the whole discussion exploded after James'Hoffmann's video. And this blog is a reaction to that, in a sense that I wanted to take some time to explain what the regulation actually means.
      The regulation does not mean that cascara (or coffee blossom) is illegal, only that it is not legal for human consumption (yet), because the EU does not know what potential health risks are yet.
      Which means that if a national authority checks your shop, the product might be confiscated and they will tell you to not sell it anymore.

      Delete

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