Eurocode 2 Discussion Note N004

Substitute and analogue food products

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ContentsIntroductionComments by:29 Oct 99
Eurocode 2 version 93/1 treatment
Types of substitute and analogue food
Related questions
Request for comments and suggestions


Substitute and analogue food products involve a partial or complete replacement of the major constituent with an alternative. Significant reasons for doing this include the preparation of vegetarian (or vegan) foods, replacement of animal fats and the utilisation of vegetable protein. The types, number and consumption of substitutes and analogues can be expected to increase and thus an effective policy for handling them within a food classification needs to be developed.

The main overall policy alternatives are to classify either on the basis of the actual source organism or according to the product type. For example, Soya milk could be classified as a product of the pulse, soya bean, or as a milk-type product. Unfortunately each of these approaches has a major disadvantage. Classifying by source creates major anomalies if the source is unknown, unspecified or incorrectly reported; the food may then be coded to the wrong main group. With product-type classification the problem arises from the arbitrary nature of the decision whether a food is a substitute or a food in its own right; the perception of a substitute may change according to time, place, culture, etc. This decision will determine the main group for a food where the main constituent is classified by the source organism. For example, Nut cutlet might be considered to be a meat-substitute product and coded in the Meats group or simply to be a nut product.

The document is intended to collect together information relevant to deciding a policy on how substitute foods should be classified and when a food should be considered a substitute that comes within that policy.

Eurocode 2 version 93/1 treatment

Eurocode 2 version 93/1 generally codes foods according to their biological source, amending the code where necessary to indicate that the coded item is a mixed product derived from the basic food. There are major exceptions to this policy where foods are classified according to product type, either with source acknowledged in further subdivision (e.g. Soup, vegetable base) or not at all (as in the Milk and milk products group).

These differences in the basis for classification, together with the limitation to two levels of subgroup, results in composite categories for substitute foods, particularly for soya products. All soya products such as soya milk, soya yogurt, textured vegetable protein, tofu and tempeh are assigned to a single category in the Pulse group (code 7X.1.8, although it is not clear that these are necessarily mixed foods). However there are categories in other main groups for Soya bean oil, soya sauce (Sauce, vegetable base) and Cheese substitutes which presumably include soya cheese. Soy flour presumably is also assigned to code 7X.1.8. The proposed extra hierarchical level within the revised classification will provide a possible solution to the problem of composite categories but a clear underlying policy is required to allow consistent categories to be defined and to identify the appropriate category during coding.

Types of substitute and analogue food

A policy for assigning substitute and analogue foods to classification categories needs to take account of the various types of food for which the question may arise. It is a primary objective of this discussion note to identify types of food which might be considered substitutes or analogues so that appropriate policies can be defined.

Types to be considered include:

The Milk and milk products group is categorised on the basis of product type which can be considered to include the characteristic use of the food item. Thus if a product is used as a substitute for cows' milk, it should be categorised as a milk. On this basis, soya milk and cocolait (coconut milk processed for use instead of cows' milk) would be classified in the Milks group as milk substitutes whereas coconut milk itself would be considered a vegetable product.
A Cheese substitutes category is present in the version 93/1 Milk group although its coverage is not documented. The Langual documentation for Cheese product analog includes products made from skim milk and vegetable oil. Soya cheese should be considered a cheese substitute on the basis of its use.
Cream substitutes include imitation creams used instead of dairy creams and non-dairy creamers for use with coffee or tea. On the basis of use, these would be classified within the Milk group. For some products such as pudding toppings, it may be difficult to decide if they are used as a cream substitute.
Other milk products
Other substitutes for milk products such as soya yogurt can be classified in the Milk group on the basis of usage. However problems can be envisaged where non-dairy products have a broadly similar usage but are given distinctive properties. It might be unclear whether they should be considered substitutes or products in their own right.
Meat products
Meat substitution can include the replacement of one meat source for another (e.g. Turkey ham) as well as replacement with vegetable products. Where the intention is the provision of vegetarian alternatives, the substitution will normally be easily recognised but this may not be the case where meat substitutes are used for other reasons. Meat substitutes might be classified as belonging to the Meat group on the grounds of product type or on the basis of their source, for example as a Pulse for soya bean products.
Flours and starches
Flours milled from grain form a major part of the Grains and grain products group but alternative flours and starches are produced from other sources such as vegetable tubers. The version 99/1 classification places these in a Substitute flours and starches subgroup (which might be better named Non-cereal flours and starches). This is probably the logical placement but there is a potential problem with the classification of further products based on these intermediates, should they appear with the flour or in the group reflecting the source organism?
Fats and oils
It is usual to give priority to the product-type aspect in classifying fats and oils, forming them into a single main group. Therefore there is no question that, for example, Soya bean oil appears in that main group rather than as a Pulse product. Substitution does occur as the partial or complete replacement of animal fats by alternatives with a vegetable origin and an effective categorisation is required within the Fats and oils group to record mixed fats and oils.
A Sugar substitutes subgroup is included in the Sugars main group for sweeteners. Products incorporating sweeteners are coded with the appropriate Component added descriptor.

Related questions

The classification of substitute and analogue foods depends on developing policies to decide when this should be done on a product-type basis and when on the basis of the source organism. These two determinants, plus aspects relating to the use of the food, are also significant for other questions of classification. These include:
Restructured/reformed products
In each of the Meat and Fish main groups there is a subgroup for restructured products separate from the species-based main classification of the groups. Where the source organism is unspecified, e.g. for Crab sticks constituted of minced fish, this is appropriate and indeed necessary. On the other hand, products such as reformed chicken might classified within the Chicken subgroup on the basis of its source.
Dietetic and vegetarian use
In Eurocode 2 version 93/1, each main group has a "... products for dietetic use" subgroup. The use of these loses all detail of the food below the main-group level and the Core Classification 98/1 proposals suggested that instead a 'Use context' descriptor is used to indicate special use. Modifications to minor constituents would be indicated through Component added or Component removed descriptors, with replacement of the major constituent handled through 'substitute' subgroups as discussed above. A Vegetarian use descriptor might also be useful.
Low-alcohol beverages
These and their alcohol-free equivalents are assigned to the alcoholic beverages subgroups of the Beverages (non-milk) main group on the groups that they are most closely related to their alcohol-containing analogues. The use of low-alcohol categories (e.g. <1% alcohol) could be combined with an Alcohol removed descriptor to indicate alcohol-free products.

Request for comments and suggestions

Comments on the above notes, together with any further information about specific substitute and analogue food products or the subject in general, would be very welcome. Please return your comments using the project feedback form, if possible by 29 October 1999.



Ian Unwin
Updated:  4 October 1999