Background
In particular, the maximum amounts that may be added to foods were reduced to keep the level of nitrosamines potentially formed due to that use as low as possible while ensuring microbiological safety. Furthermore, for each provision of a maximum added amount, a maximum residual level from all sources was established to monitor better the overall exposure to nitrites in relation to the Acceptable Daily Intake (ADI).
For traditionally cured meat products, the approach of regulating only maximum residual levels was maintained as it was not considered practicable to determine amounts of nitrites added to such products. The revised maximum levels and new residual maximum levels of nitrites are expressed as nitrite ion in line with the ADI established by EFSA. The current maximum levels are expressed as sodium nitrite or sodium nitrate. The conversion factors between sodium nitrite and nitrite ion is 0,67 and between sodium nitrate and nitrate ion is 0,73.
Some examples
In accordance with Regulation (EU) 2023/2108, the revised maximum added amount of nitrites is 80 mg/kg for meat products in general and 55 mg/kg for sterilised meat products. This corresponds to 120 mg/kg and 82 mg/ kg respectively when expressed as sodium nitrite, i.e. expressed on the same basis as the maximum levels in Annex II to Regulation (EC) No 1333/2008 applicable until 9 October 2025 and the national provisions notified by Denmark.
For a few specified cured meat products made traditionally, the maximum added amount of nitrites is 100 or 105 mg/kg, corresponding to 150 or 157 mg/kg when expressed as sodium nitrite.
The residual levels newly established are 25, 45 or 50 mg/ kg. The revised maximum residual levels for traditionally cured products for which no maximum added amount is set out are 30, 65 or 105 mg/kg applying to different groups of traditionally cured products.
Especially for Denmark
In Denmark they still have their own national provisions regarding maximum added amount of nitrites which are contained in Order No 474 of 9 May 2023. The order provides that nitrites in meat products may only be used in accordance with the conditions laid down in Annex 3 thereto. The Danish maximum values also apply to products imported and sold in DK. The default maximum added amount of 60 mg/kg applies in DK to many types of meat products, whereas the corresponding maximum levels, expressed as sodium nitrite, set out in Reg. (EC) No 1333/2008 are 100 mg/kg and 150 mg/kg until 9 Oct. 2025 and will be 82 mg/kg and 120 mg/kg after that date.
The maximum added amount of nitrites for entirely preserved or semi-preserved heat-treated meat products in DK is 150 mg/kg, while the revised maximum added amounts of nitrites set out in Reg. (EC) No 1333/2008, applicable from 9 Oct. 2025, are lower, permitting, expressed as sodium nitrite, only 82 mg/ kg for sterilised heat-treated meat products and 120 mg/kg for non-sterilised heat-treated meat products. The Danish national provisions do not set any maximum residual levels to be applied in parallel with the maximum added amounts of nitrites and thus do not control the exposure to nitrites in relation to the ADI, unlike the maximum residual levels related to the maximum added amounts set out in Reg. (EC) No 1333/2008.
Danish national regulation with national provisions of nitrite etc.