Art 2
Contrary to EU regulation 1333/2008 (additives allowed in bread and baked goods)
Art 4
the list of ingredients cannot be considered exhaustive. For example the addition of seeds for
"special breads”. The list of enzymes cannot be considered exhaustive either. Limiting the use of
enzymes to those naturally present in flours precludes the possibility of using enzymes that could
contribute to improving the quality and healthiness of bread. An example is the enzyme
asparaginase, which is not present in flour, but which can be used to reduce the formation of
acrylamide (a toxic molecule, potentially carcinogenic, which forms in starchy foods during the
cooking process). It is therefore suggested to replace the phrase "alpha and beta amylase and
other enzymes naturally present in the flours used" with "alpha and beta amylase and other
enzymes capable of satisfying targeted technological requirements".
art 8
Limiting the use of lactic acid bacteria in sourdough starter to only cultures without supports (where
“supports” are understood to be technological adjuvants of natural origin, totally safe for the
consumer, neutral on a sensorial and nutritional level and having as their only function the
protection and stabilization of microbial cells), compromises all the principles of social, economic,
productive, environmental and cultural sustainability that the law intends to protect.
In the absence of such supports, lactic acid bacteria, if not stored frozen or refrigerated, quickly
lose their vitality and consequently their functionality.
The use of supports, on the other hand, allows them to be stored at room temperature, making the
technology accessible, efficient and replicable even for small operators, as well as ensuring
significant energy savings thanks to the elimination of the need for refrigeration equipment.
Furthermore, it is possible to make stable and usable even those strains/species of native lactic
acid bacteria, particularly fragile, that can typically be present in sourdough starter. Giving up these
strains would mean losing a unique microbiological heritage, the result of local traditions and a long
natural selection, and depriving Italian bread of its typicality and its identity linked to the territory.
Prohibiting their use would mean hindering the natural evolution of the sourdough starter, betraying
the very spirit of the law, which aims to enhance fresh Italian bread as a living and sustainable
heritage.
The proposal is therefore to replace the sentence "The use of starter cultures consisting of lactic
bacteria, without support material and free from contaminants is also permitted" with "The use of
starter cultures consisting of live lactic bacteria and free from contaminants is also permitted", thus
also placing the emphasis on their vitality, in the absence of which they could never carry out their
role of starting and guiding the fermentation processes.
Sourdough is a dough and not a yeast which is an equally natural microorganism. The definition is
wrong and misleading. In particular, dough is made by flour that could be a possible health issue
for celiac consumers.
It is not clear how long the minimum time corresponds to define a fermentation as "long".
Art 13
The regulatory reference is wrong and the obligations on origin are not clear
