Buffered vinegar has become a go-to "clean-label" solution in meat and poultry for its antimicrobial and shelf-life extending properties.
However, regulatory guidance on how to declare it on ingredient labels has recently evolved (post-2020) in some region. Here's a breakdown of the current best practices and key differences from earlier standards, using USA and EU as examples.
In USA, buffered vinegar labelling remains consistent in meat and poultry products regulated by USDA:
Dried (buffered) vinegar to be added to trace lean pork trimmings intended for incorporation into fresh sausage is approved for use as a processing aid when used at the amounts listed in FSIS Directive 7120.1, “Safe and Suitable Ingredients Used in the Production of Meat and Poultry Products”. Therefore, when used according to FSIS Directive 7120.1, dried vinegar does not need to be declared on the label. Buffered vinegar used in other applications must be declared on the label. Buffered vinegar can be labeled as vinegar without declaring the individual buffering agents used (e.g., sodium bicarbonate), because those buffering agents are considered as processing aids. Comparing to EU regulations, USA labelling regulation is less transparent.
In EU prior to 2023, buffered vinegar was not explicitly approved as a food additive, but it was still able to be used. Buffered vinegar, if used, could be labeled as "acidity regulator" or "acetic acid" (e.g., E260 for acetic acid), without clear indication of the buffering agents or the vinegar origin. This was often accepted under broader E-number declarations.
Under new EU FIC Regulation, food business operators must declare buffered vinegar with both the acid and the buffering agent, and in many cases, its technological function (e.g., preservative or acidity regulator) must be disclosed. If used primarily as a preservative, the function must be declared. A recommended labeling looks like: "buffered vinegar (acidity regulator: vinegar, potassium acetate)" or "buffered vinegar (preservative: vinegar, potassium bicarbonate)”.
