TRPR (TPD) Update CAS numbers and Compliant RTV

If you require CAS details in order to notify your products, FlavourArt Italy have a well established process in place. A Non Disclosure Agreement is put in place to ensure confidentiality, then the relevant CAS numbers will be provided. Please email us first and we will arrange for FA Italy to make direct with you and/or any Laboratory you might be using for notification. All communication will then between you and FA Italy; we do not have access to any information that might be exchanged.

Not all CAS numbers are required, it depends on the percentage of the individual ingredient. Please read the paragraph below for the MHRA's explanation.

The MHRA no longer require CAS numbers or ingredient details if an individual ingredient represents less than 0.1% of the final formulation. The relevant portion of the MHRA email update is below.

Commission Implementing Decision (EU) 2015/2183 states that ingredients present at a level below 0.1% of the final product formulation may be deemed confidential or a trade secret. Below that level, we will allow ingredients to be considered as confidential in the notification. As such, ingredients present at a level below 0.1% of the final formulation can now be described collectively in the notification by an umbrella term such as ‘strawberry flavouring’.   
In these cases, the notifier must gain the following from the ingredient supplier:
(i) adequate assurance of quality and safety to allow the notifier to accept full responsibility for the product under s31(3)(g) of the TRPR and
(ii) an assurance that the ingredient supplier would disclose the composition to the competent authority (MHRA) in confidence the event of a safety problem with the product.  
Notifiers must satisfy themselves as to the safety and quality of their product but may wish to seek assurances that:
a) the ingredient complies with applicable EU food flavouring legislation (Regulation EC 1334/2008).  
b) the flavouring substances contained within the flavour are listed in the EU list of flavouring substances as defined by Regulation EU 872/2012.
c) The ingredient formulation does not include any substance banned under Article 7 of the Tobacco Products Directive. 

FlavourArt Italy have issued a statement that addresses points (i), (ii), a), b), c). The statement satisfies MHRA requirements and enables Notifiers to submit without the need for CAS numbers.

Please click the link below to download a copy of the statement.

MHRA Statement from FlavourArt Italy.

 
 
FlavourArt UK