Labeling advisories
The two notices that sit beside the preservative check without being part of it: polyols above 10% of the finished product, and colors with no E number.
What they are
On the Validation tab of the recipe editor, next to the Preservatives and market limits block, two further notices can appear: Labeling: polyols and Colors: not evaluable (the latter is headed Colors with an E number when every color record in the formula states its E number).
They look like the preservative check and they are not the same thing, and the difference matters:
| The preservative check | These two notices | |
|---|---|---|
| What it compares | a dose against a legal maximum | a proportion against a labeling threshold |
| Going over means | the product is not legal at that dose | you must write a sentence on the label |
| What to do | reformulate | label |
That is why they sit alongside the check, not inside it. Merging them would have suggested that exceeding 10% polyols is an infringement, and it is not: it is an information requirement.
Like the check, this is a deterministic calculation on your formula: no AI, no credits.
Polyols: the laxative statement
What the rule says
Regulation (EU) No 1169/2011, Annex III, point 2.4 requires that foods containing more than 10% added polyols carry on the label the statement:
‘excessive consumption may produce laxative effects’
That sentence is literal. It is the text that gets printed, not a summary of what has to be said.
Three words in that rule determine how the application does the math:
- "foods" — the threshold is measured on the product as sold: the finished bonbon, not the filling.
- "more than 10%" — the comparison is strict. Exactly 10.0% does not trigger it.
- "added" — only the polyol you add counts.
The 10% is a figure from the rule, unlike the 80% caution band in the preservative check, which is an AreaCacao product decision. When this notice cites 10%, it is citing the legislator.
What it is calculated on, and why not on the filling
The figure that counts is the one for the whole bonbon. The application also shows you the percentage of the phase, but only as context: it decides nothing.
The difference is large, and it errs toward a false alarm. A filling at 11.65% polyols, if it is 58.8% of a bonbon, sits at 6.85% of the finished product: below the threshold. Measuring it on the phase would have raised a notice that does not apply, and a notice that fires without cause stops being read.
When that mismatch happens (the phase exceeds 10% and the bonbon does not), the notice says so explicitly rather than leaving you with two contradictory figures.
The case of the cooked families
In caramel and pâte de fruit there is a nuance that changes the result, and the application does not skip it.
Polyols are solutes: cooking evaporates water and they stay, so their share rises. Working it out on the uncooked weight would give a figure lower than the real one.
| A 1,000 g pâte de fruit with 120 g sorbitol, cooked down to 750 g, making up 65% of the bonbon | Of the phase | Of the bonbon |
|---|---|---|
| If calculated on the uncooked weight | 12.0% | 7.8% — would look like no labeling needed |
| On the real weight after cooking | 16.0% | 10.4% — labeling required |
So in those two families the notice asks you for the final weight after cooking and withholds a verdict without it. It is the same figure you already enter for the water activity estimate, in the same place: type it once and it feeds both.
The other statement, which has no threshold
Polyols are authorized sweeteners. That triggers something else, regardless of the 10%: the name of the product must be accompanied by ‘with sweetener(s)’ or ‘with sugar(s) and sweetener(s)’ if it also contains added sugar.
That statement has no threshold: their presence is enough. A bonbon with 3% maltitol does not carry the laxative statement, but it does carry ‘with sweetener(s)’. The notice reminds you whenever it detects a polyol, including when the figure sits below 10%, precisely so that a "below" is not read as "nothing to write".
Authorization, which is a separate matter
Polyols have no numerical maximum as an additive, but in chocolate and in fillings they are only authorized where the product carries no added sugars or is of reduced energy value. A sugared filling with maltitol added to lower water activity does not meet that condition of use, whatever the percentage.
That is a different question from the 10% and the application does not assess it: it warns you so that "no ceiling" is not read as "I can use it anywhere".
When the notice withholds a verdict
This notice never says "below" when it does not know. The reason is the direction of the harm: if a polyol dropped out of the count, the percentage would fall and you could read that no labeling is needed when it is. So when in doubt it stays quiet and says why.
| What you see | Why | What unblocks it |
|---|---|---|
| We could not establish what share of the finished product they represent | The product type or the filling percentage is missing | Declare them in the preservatives block |
| It is cooked and the final weight is missing | On the uncooked weight the figure would come out lower than the real one | Enter the weight after cooking |
| We do not know how much polyol an ingredient contributes | The figure sits in a range and 10% falls inside it | Declare the content on that ingredient's record |
| It contains glycerol or polyglycitol syrup | They are not in Group IV of Regulation 1333/2008 and the rules do not settle whether they count | Check, or include the statement to be safe |
In the first three cases, when the range does not decide (10% is not crossed even at the maximum, or not undercut even at the minimum) the notice does give a verdict. Uncertainty only blocks when it is what decides.
The edge band
If your formula lands within a tenth of a point of the threshold, the notice tells you: a workshop scale is less precise than that margin. Either move away from the edge, or include the statement and stop depending on the scale.
Where the figure comes from
From each ingredient's record, with nothing for you to declare. A polyol is a carbohydrate and is declared as such on the European label, so the content comes from the carbohydrates on the record: crystalline sorbitol (0% water, 100% carbohydrate) counts at 100%, and liquid sorbitol (30% water, 70% carbohydrate) counts at 70%.
What the application does not do is infer it from the name. A "raw cacao with erythritol" contains erythritol and is not a polyol record: we do not know its content, and counting it whole would invent an obligation that may not exist.
Colors
When your formula contains a color a second notice appears, in three parts. None of them compares your dose against a maximum, and it is worth understanding why before reading them.
The mandatory statement, which does not depend on the dose
Six colors require a specific sentence on the label of the finished product, under Article 24 of Regulation (EC) 1333/2008 and its Annex V:
E 102 (Tartrazine) · E 104 (Quinoline Yellow) · E 110 (Sunset Yellow FCF/Orange Yellow S) · E 122 (Azorubine, Carmoisine) · E 124 (Ponceau 4R, Cochineal Red A) · E 129 (Allura Red AC)
The sentence is:
‘name or E number of the colour(s)’: may have an adverse effect on activity and attention in children.
This statement does not depend on the dose: the color merely has to be present. A color comfortably under its maximum still needs it. That is why the notice sits in its own block and not inside any limit comparison.
The notice has three states, and the one you will see today is the third:
| State | When | What it does |
|---|---|---|
| It contains one of the six | a record states its E number and it is on the list | names them and gives you the exact text |
| It contains none | every record states an E number and none is on the list | the statement box does not appear; the colors notice stays, headed Colors with an E number |
| Cannot be ruled out | an E number is missing from some record | names the six and asks you to check the packaging |
The third is not a "no". The fact that we don't know which color yours is does not mean it is not one of the six. Today none of the color records in the catalog states an E number, so every formula with a color lands here. An E number we cannot read — a typo, or the one belonging to another additive in the preparation — also counts as absent, never as ruled out.
A bonbon is two different categories
The chocolate shell and the filling are not governed by the same color rules:
| Chocolate · category 05.1 | Decorations, coatings and fillings · category 05.4 | |
|---|---|---|
| Colors authorized without a figure | none | yes, a whole group |
| Group with a combined ceiling | not listed | 500 mg/kg |
| Colors with their own maximum | none as a color | nine |
In chocolate products the additive list is closed and no color enters it as such. Coloring the shell and coloring the filling are not the same decision, and the application tells you so without claiming which of the two categories applies to your formula, because the formula does not declare it.
Why we do not compare your color against any maximum
This is the part worth reading slowly, because it is not what it looks like.
It is not that we lack the table of limits. It is that the maximums in the rules are expressed on the pigment, while what you weigh out is the commercial preparation, which is mostly carrier, usually a fat. The ingredient record does not say what share of that preparation is pigment.
Measured across the application's real recipes: a typical color comes out between 734 and 2,882 mg/kg of preparation, with the pigment one or two orders of magnitude below. Comparing that figure against a 500 mg/kg ceiling would give a false alarm; correcting it by eye would give a false pass. Two different ways of lying about the same thing, and we would rather do neither.
On top of that, the additive is never inferred from the color: a "red fat-soluble pigment" could be half a dozen substances, each with its own limit and its own list of markets.
Three things would be needed to compare, and the first is the one that decides: the pigment concentration in your preparation, the E number, and knowing which line of the formula goes in the shell and which in the filling. Without the first there is no numerator to compare.
What these notices do NOT do
- They are not a dose limit. Exceeding 10% polyols is not an infringement: it is an obligation to write a sentence.
- They do not check the condition of use. That polyols are only authorized in products with no added sugars or of reduced energy value sits outside the calculation.
- They do not compare colors against any maximum, not even with the E number declared: what is missing is the pigment concentration of your preparation, which is what makes the figure comparable.
- They do not count polyol arriving inside another ingredient if its record does not declare it. Where that could change the result, the notice withholds a verdict rather than counting it as zero.
- They do not draft your label. They tell you which statements are mandatory on what we could calculate; the rest of the labeling (ingredient list, allergens, nutrition declaration) is out of scope.
Related
Using the preservative check
A walkthrough of the “Preservatives and market limits” block: choosing the market and product type, reading the verdict and the contributions table, and resolving a “Cannot be assessed” by declaring what your label says.
Chocolate formulator
Design your chocolate (dark, milk, white, vegan milk, or vegan white) scene by scene (type, sweetening, and parameters) and get the formula to the gram, which saves itself as a recipe.