Sulphur dioxide and the sulphite salts are the reason a dried apricot can be orange instead of brown. They are also the most common regulatory and labelling problem in the dried fruit category, and the one most likely to be discovered at a buyer’s intake rather than at the supplier’s dispatch.
What sulphites do
Sulphur dioxide and sulphites act on dried fruit in three ways at once.
- **Colour preservation.** They inhibit enzymatic browning and slow non-enzymatic browning, keeping light-coloured fruit light.
- **Antimicrobial effect.** They suppress moulds and yeasts during and after drying, which matters most where drying is slow.
- **Antioxidant effect.** They slow oxidative degradation, which helps retain some vitamins and aroma compounds.
Treatment is usually by burning sulphur to fumigate the fruit before drying, or by dipping in a sulphite solution. The residual level in the finished product declines over time and with processing, which is why a level measured at production and a level measured six months later are not the same number.
How the EU regulates them
Two separate pieces of legislation apply, and confusing them causes most of the errors.
**Additive authorisation and maximum levels.** Sulphur dioxide and sulphites are authorised food additives with E numbers in the E220 to E228 range. The conditions of use and the maximum levels for each food category are set out in Regulation (EC) No 1333/2008 and its annexes. The permitted level differs by commodity: dried apricots, dried apples, raisins, dried figs and so on are not treated identically, and the annex has been amended more than once.
Do not take a maximum level from a supplier’s datasheet, from a competitor’s specification or from a general article, including this one. Read the current consolidated version of the annex for the exact food category, or have your regulatory contact do it and record the answer with the date.
**Allergen-style labelling.** Independently of the additive rules, sulphur dioxide and sulphites at concentrations above a threshold expressed as total sulphur dioxide must be declared in the list of substances causing allergies or intolerances under Regulation (EU) No 1169/2011 and its Annex II. The threshold applies to the product as sold or as reconstituted according to the manufacturer’s instructions. This obligation exists even where the level is well within the additive maximum.
The practical consequence is that a product can be entirely legal on the additive side and still be mislabelled if the declaration is missing.
What a buyer should check
Ask for these, in writing, before the first order:
- **Is the product sulphited at all?** Yes or no, for each item on the offer. An offer that answers this per company rather than per product has not answered it.
- **What is the target residual level and the specification maximum?** As total sulphur dioxide, with the analytical method named.
- **What is the measured level at dispatch, per lot?** With the certificate of analysis.
- **How does the level behave over shelf life?** Sulphite levels fall over time, which matters if the specification has a minimum as well as a maximum.
- **How is it declared on the pack?** Both in the ingredients list, where applicable, and in the allergen declaration.
- **For organic product, what is the position?** Sulphite use in organic production is restricted, and the permitted uses under Regulation (EU) 2018/848 and its implementing acts are narrower than in conventional. Confirm the specific position for the commodity with the control body rather than assuming.
The analytical side
Total sulphur dioxide is usually determined by an optimised distillation method or by an equivalent validated technique. Two points matter commercially.
- **Method matters.** Different methods can give different results on the same sample, particularly at low levels. Name the method in the specification.
- **Low-level claims are hard.** A claim that a product is below the labelling threshold needs a method with adequate sensitivity and a sampling plan that reflects lot heterogeneity, because sulphite distribution within a lot is not uniform.
Unsulphited product and the alternatives
Demand for unsulphited dried fruit is real and growing, particularly in organic and clean-label ranges. It is not simply the same product without a step.
- **Colour.** Unsulphited light fruit browns. A brown dried apricot is the normal appearance of an untreated dried apricot, and the buyer’s own customer has to be prepared for it.
- **Shelf life and microbiological risk.** Without the antimicrobial effect, the drying process and the final water activity have to do all the work, and the packaging has to hold it.
- **Process alternatives.** Faster and gentler drying, blanching, acidification with permitted acidulants, ascorbic acid treatment, modified atmosphere packaging and lower final water activity all contribute. None of them is a drop-in replacement on its own.
- **Cost.** Unsulphited product generally costs more, has a shorter practical shelf life and needs better packaging.
Where sulphite problems actually surface
Very few sulphite problems are discovered by a regulator. They are discovered by a buyer, usually in one of five ways.
- **An intake test above the specification maximum.** Often a homogeneity problem rather than an overdose: fumigation is not perfectly even, and a sample from a heavily treated part of a lot reads high.
- **A declaration missing from the label.** The level was legal, the allergen declaration was not applied, and the pack has been printed. This is the expensive one.
- **A level that has fallen below a contractual minimum.** Where a buyer relies on the antimicrobial effect for shelf life, a decaying residual can breach a minimum they set for that reason.
- **An organic lot treated as if it were conventional.** The permitted uses in organic production are narrower, and a treatment that is routine on the conventional line is a certification incident on the organic one.
- **A downstream customer with a stricter internal limit than the law.** Several retailers operate internal sulphite policies below the legal maximum, or exclude sulphites from specific ranges entirely. This is a buyer requirement, not a legal one, and it will not appear in any regulation you read.
The preventive controls are unglamorous: treat evenly and record it, test per lot with an adequately sensitive method, keep organic and conventional physically and documentarily separate, and confirm the declaration text with the buyer before artwork is approved rather than after.
Declaring it correctly on the finished product
The allergen declaration is where most of the commercial risk sits, and it is
worth being precise about who owns it.
Under the EU food information rules, sulphur dioxide and sulphites have to be
declared as an allergen when they are present at more than ten milligrams per
kilogram or ten milligrams per litre in the product as sold, expressed as total
sulphur dioxide. Two things about that threshold catch people out.
The first is that it applies to the finished product, not to the ingredient. If a
sulphited apricot is one ingredient among many in a muesli, what matters is the
concentration in the muesli. Dilution can take a compliant ingredient below the
threshold in the finished pack, and it can also fail to, if the inclusion rate is
high. Somebody has to do that arithmetic, and it should be written down, because
it is the kind of calculation that gets done once and then never revisited when
the recipe changes.
The second is that residual sulphur dioxide falls over time. A batch that leaves
the drying plant well above the threshold can sit in a warehouse for a year and
arrive close to it. That is good news for labelling and bad news for
specification writing, because a test at intake and a test at end of shelf life
can land on opposite sides of the line. If a product is anywhere near ten
milligrams per kilogram, declare it. The cost of an unnecessary declaration is a
line on a label. The cost of a missing one is a withdrawal.
What to ask for in the supplier file
Keep four things per supplier and per product, and review them when the label
changes or the recipe changes:
A statement of whether sulphites are used at all, and if so at which step. Dipping
before drying, gassing in a chamber and a post-drying treatment behave differently
over shelf life, and the answer tells you what to expect from a retest.
Certificates of analysis with the actual figure, the method and the accredited
laboratory, batch by batch rather than a generic annual statement. A typical
figure on a specification sheet is not a result.
A statement of how the supplier controls carry-over on shared lines, if unsulphited
and sulphited product run in the same plant. Cross-contact at a level above the
declaration threshold is a real finding on audits, and the control is usually
sequencing plus a validated clean.
The label wording the supplier expects you to use, and confirmation that it matches
what you actually print. This sounds trivial. It is the item that most often does
not match.
A short specification template
For each dried fruit line, the specification should state:
- Sulphited or unsulphited, explicitly.
- If sulphited: the maximum total sulphur dioxide as a number, the analytical method, and a statement that the level complies with the current maximum permitted for that food category under Regulation (EC) No 1333/2008.
- The declaration text to appear in the ingredients list and in the allergen declaration under Regulation (EU) No 1169/2011.
- For organic: the certification position on sulphite use, confirmed with the control body.
- The certificate of analysis requirement per lot.
Nothing on this page is legal advice, and every level referred to here has to be read from the current legislative text before it is used in a contract or on a label.