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New Zealand Food Safety
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Thank you for the opportunity to comment on this application. This submission does not represent a New Zealand Government position, which will be a matter for the New Zealand Government should notification be made by the FSANZ Board to the Food Ministers’ Meeting.
New Zealand Food Safety (NZFS) agrees with FSANZ’s assessment that based on the available evidence there are no safety concerns from the proposed uses of the fermented preparation of Lentinula edodes (shiitake mushroom) mycelia at GMP levels, and its use is technologically justified in the production of fermented pea and rice protein (FPRP).
We note the action of enzymes secreted by the shiitake mycelia during the main fermentation step is suggested to improve the organoleptic qualities of FPRP and could be viewed as having a processing aid function. However, NZFS questions the need to regulate the fermented preparation as a processing aid noting:
-microorganisms used for the purpose of fermentation are usually considered as general food ingredients;
-the enzyme identification via RNAseq analysis was performed only for the main fermentation, so it is unclear whether the fermented preparation also contains enzymes that perform technological functions; and
-no other national regulatory agency has regulated the fermented preparation as a processing aid.
In our view, the regulation of the fermented preparation as a processing aid may have implications for present and future permissions to use fermentation organisms, which may also produce enzymes and other substances that have technological effects during a fermentation process.
Please contact us if you wish to discuss any of the comments.
New Zealand Food Safety (NZFS) agrees with FSANZ’s assessment that based on the available evidence there are no safety concerns from the proposed uses of the fermented preparation of Lentinula edodes (shiitake mushroom) mycelia at GMP levels, and its use is technologically justified in the production of fermented pea and rice protein (FPRP).
We note the action of enzymes secreted by the shiitake mycelia during the main fermentation step is suggested to improve the organoleptic qualities of FPRP and could be viewed as having a processing aid function. However, NZFS questions the need to regulate the fermented preparation as a processing aid noting:
-microorganisms used for the purpose of fermentation are usually considered as general food ingredients;
-the enzyme identification via RNAseq analysis was performed only for the main fermentation, so it is unclear whether the fermented preparation also contains enzymes that perform technological functions; and
-no other national regulatory agency has regulated the fermented preparation as a processing aid.
In our view, the regulation of the fermented preparation as a processing aid may have implications for present and future permissions to use fermentation organisms, which may also produce enzymes and other substances that have technological effects during a fermentation process.
Please contact us if you wish to discuss any of the comments.