Sulphites in dried fruit are residues of sulphur dioxide and its salts, coded E 220 to E 228 and counted as SO2. EU law caps them by fruit type, and any level above 10 mg/kg triggers an allergen declaration on the finished pack.

Sulphites in dried fruit sit under two separate EU rules

Two EU acts govern sulphites in dried fruit, and each answers a different question. Regulation (EC) No 1333/2008 sets how much may be used. Regulation (EU) No 1169/2011 sets when you must tell the buyer. Article 4 of the additives act allows only the additives listed in Annex II, under the conditions given there. Quality teams often merge the two rules into one figure, so the spec ends up wrong.

E 220 to E 228 covers eight substances. Sulphur dioxide holds the code E 220. The list then runs through sodium sulphite, sodium bisulphite, sodium metabisulphite, potassium metabisulphite, calcium sulphite, calcium bisulphite and potassium bisulphite. Every limit and every label rule counts them as one group, expressed as SO2. When a supplier reports metabisulphite at 800 mg/kg, ask what the figure counts, because a salt figure and an SO2 figure differ.

Article 3 defines an additive as a substance added for a technological purpose. Sulphur dioxide holds colour in the fruit and slows spoilage while it dries, so it fits that test. Food category 04.2.1 then covers dried fruit and vegetables as a block. The category decides the rule, and it takes in every drying route, air drying and freeze drying alike.

Permitted levels run from 50 mg/kg to 2 000 mg/kg

The 2022 EFSA follow-up lists the permitted levels that apply in category 04.2.1. Read each one as a ceiling for the dried product as sold, counted as SO2.

Dried product	Maximum level as SO2
Apricots, peaches, grapes, prunes, figs	2 000 mg/kg
Bananas	1 000 mg/kg
Apples and pears	600 mg/kg
Other dried fruit and nuts	500 mg/kg
White vegetables, dried	400 mg/kg
Tomatoes, dried	200 mg/kg
Ginger, dried	150 mg/kg
Mushrooms, dried	100 mg/kg
Coconut, dried	50 mg/kg

Prunes share the top row with apricots, grapes, peaches and figs. That row is the legal maximum, so treat it as a worst case rather than a target. A ceiling says nothing about the pallet in your warehouse, because it caps the whole category. Ask for the residual figure per batch when you fix the format on the dried plum raw material data sheet, and repeat the request for every new supplier lot.

US practice runs on the same order of size. A 2011 USDA technical report puts typical residues in dried fruits other than dark raisins and prunes below 100 ppm, and notes the 10 ppm point where US labelling duties start.

The 10 mg/kg label threshold and what it puts on the pack

Above 10 mg/kg, or 10 mg/l, sulphites turn into an allergen entry. The Food Safety Authority of Ireland states the threshold in those words and ties it to Annex II of the food information act. Article 9(1)(c) makes the entry mandatory. Article 21 then asks you to set the name apart in the ingredient list, by font, style or background colour.

Two practical duties follow. The label needs the substance name, so write preservative: sulphur dioxide, or sulphites. The threshold also applies to the food as sold, or as prepared per your instructions, which matters for soup mixes and bakery premixes that a cook dilutes.

Non-prepacked food carries the same duty. When a caterer buys your fruit filling, the allergen data has to travel with the delivery note. The EU rules on food information have applied since 13 December 2014, so no grace period remains.

Sulphites in dried fruit carry over into your compound food

Article 18 of the additives act sets the carry-over principle. An additive may be present in a compound food when it is permitted in one of the ingredients of that food. So a muesli with sulphured apricots stays legal, while the residue still travels into the finished mix.

Run the arithmetic before you sign artwork. Take 8 kg of dried apricots at 1 500 mg/kg in a 100 kg batch. Those apricots bring 12 g of SO2, which spreads to roughly 120 mg/kg across the batch. The result sits twelve times above the label threshold, so the allergen line stays.

Now reverse the sum. At 10 mg/kg in a 100 kg batch you may carry 1 g of SO2 in total, and that equals 0.67 kg of the same apricots. Dilution alone rarely brings a recipe under the threshold, so the raw material figure is where the change has to happen. Ask for a lower residual level, or switch to an untreated lot.

Rework raises the same sum. When you return 5 % of a sulphured mix into the next batch, the residue carries over, so log it in the mass balance. Shared dosing lines open a second path. A dust extraction fault on a mixing line can move fine apricot particles into a neighbouring recipe, and the receiving product then needs a check of its own. Treat the residue as an allergen for cleaning validation, and swab against a numeric limit rather than a visual pass.

EFSA withdrew the temporary ADI in 2022

EFSA set a temporary group ADI of 0.7 mg SO2 equivalents per kg body weight per day in its 2016 re-evaluation. Exposure estimates already sat above that value for all population groups. The follow-up adopted on 28 September 2022 withdrew the temporary ADI, because the toxicity data requested from business operators never arrived.

FoodNavigator reported the outcome on 16 December 2022. Margins of exposure fell below 80 for high consumers in every population group except adolescents, which the panel treated as a safety concern.

The Commission runs the additive re-evaluation programme under Regulation (EU) No 257/2010, and it called for data on E 220 to E 228 back in 2016. A stakeholder consultation on those authorisations followed in 2023. Lower maximum levels are under review, so build margin into the spec now rather than after a change lands.

Plan the commercial answer while the review runs. A lower ceiling for category 04.2.1 would hit the top row hardest, since prunes, apricots and figs carry the largest headroom today. Two moves cover most cases. Move one is a tighter contractual maximum, set below the current ceiling, so a later change costs nothing. Move two is a second approved source with an untreated grade, qualified in parallel. Both take months of trials and audits, so a start date this quarter avoids a rushed change later.

Test methods decide whether you can prove 10 mg/kg

Method choice decides what a certificate of analysis is worth. New Food Magazine puts the limit of detection of the classic Monier-Williams distillation near 10 ppm. That value sits on the legal threshold, so a not detected result from that method carries little weight.

The faster PAS route runs a six minute distillation, then separates the sulphate ion by ion chromatography with conductivity detection. It reaches 2 ppm and drops the titration endpoint error. Ask for that finish when a customer wants a low claim, and record the method plus the limit of detection on the spec.

What the certificate of analysis has to show

Four fields turn a certificate into evidence. The batch code has to match the delivery note. Sampling date and the number of incremental samples behind the composite come next. Method reference and its limit of detection follow. A numeric result closes the set, since a less than entry with an unstated detection limit proves little. When any field is missing, ask for a corrected document before the goods clear quarantine.

Sampling matters as much as chemistry. A residual figure can move between dispatch and the end of shelf life, so one result rarely covers the whole period. Fix the sampling point in the contract, and say whether the figure applies at dispatch or at a stated storage age.

Sulphites in dried fruit: what to write in the raw material spec

Six lines cover most audit questions. Copy them into the specification and ask the supplier to sign against each one., State the parameter as total SO2, expressed as SO2, with a numeric maximum in mg/kg., Name the method and its limit of detection, such as ion chromatography at 2 ppm., Ask for a batch result on every certificate of analysis, rather than a type value., Record whether sulphites are added during processing, and at which step., Fix the sampling point, either at dispatch or at a stated storage age., Add a change control clause, so a switch to a treated lot reaches you before delivery.

Use numbers in place of adjectives. A clause reading low sulphur leaves room for debate at the goods inwards desk. A clause reading total SO2 maximum 10 mg/kg, measured by ion chromatography, sets a duty that a laboratory can test.

Auditors read the allergen matrix next. When your matrix marks a raw material as sulphite free, the file behind it has to hold a supplier statement plus a batch result. Schemes such as BRCGS and ISO 22000 work on verified records, so pair every claim with a document that names a batch.

Freeze-dried fruit and untreated plums need the same file

Freeze-dried fruit falls inside category 04.2.1, so the additive stays legally available for it. Treat freeze-dried as a process description, and treat the absence of sulphites as a claim that needs evidence. The freeze-dried fruit range supplied in bulk to food plants is specified the same way as any dried item, with the residual figure written into the document set.

Untreated dried plums behave differently in the plant. The Commission consultation material describes sulphites as holding appearance, extending shelf life and slowing microbial growth, so dropping them touches all three. Plan for a shorter effective life, and set the storage temperature in the contract. Browse the index of dried and freeze-dried raw materials when you need a substitute with a comparable colour profile.

SALESWAVE confirms sulphite figures and the matching analysis reports for the specific batch, once the documentation scope is agreed at specification stage.

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