Union list of novel foods: thirteen corrigenda in two days to the conditions of use

If the technical data sheet for one of your ingredients carries the category of use copied from the Union list of novel foods, go back and read how it is worded. For a dozen entries that line, as of Monday, no longer says the words you transcribed — and in some cases the category you had read was not the one the authorisation meant.

Thirteen corrigenda in two days

On 28 and 29 September 2026 the Official Journal of the European Union published thirteen corrigenda to implementing regulations on novel foods: six on the 28th, seven on the 29th. The acts corrected run from Implementing Regulation (EU) 2018/1023 to (EU) 2026/397 — eight years of authorisations reopened in forty-eight hours.

Twelve of the thirteen cite Implementing Regulation (EU) 2017/2470, “establishing the Union list of novel foods”, and act on Table 1 (“Authorised novel foods”) of its annex. The thirteenth, on Reg. 2025/1549, likewise concerns the conditions of use of novel foods and touches the table annexed to Reg. 2023/2210.

We read all thirteen in full. They contain 34 «anziché»/«leggasi» pairs — for and read — 22 in the annex, the table people actually consult, and 12 in the recitals. None touches a maximum level, a specification or a limit: not one figure appears in the 34 points.

Two categories that Italian had merged into one

Every point does the same thing: it changes the name of the food category in which the ingredient may be used. Under the entry for the sodium salt of 6’-sialyllactose, second column (“Specified food category”), for «Prodotti non aromatizzati pastorizzati e non aromatizzati sterilizzati, a base di latte (compreso il trattamento UHT)» read «Prodotti lattieri non aromatizzati pastorizzati e non aromatizzati sterilizzati (compreso il trattamento UHT)» — milk-based products becomes dairy products.

It looks like a shade of translation. It is not, and the English text proves it: English distinguishes “milk products” from “milk-based products”, two different categories, while Italian had rendered both as a base di latte. The corrigenda restore the difference — milk products becomes «prodotti lattieri», milk-based products stays «prodotti a base di latte».

That they are two distinct things is clearest where both sit in one cell. For N-acetyl-D-neuraminic acid the English reads “Unflavoured fermented milk-based products, heat treated after fermentation, flavoured fermented milk products including heat-treated products”: the first half is milk-based, the second is dairy. The corrigendum to Reg. 2018/1023 corrects only the second — «prodotti aromatizzati a base di latte fermentato» becomes «prodotti lattieri fermentati aromatizzati» — and leaves the first untouched. One cell, two categories, only one of them wrong.

Nor does it always run the same way. For Cyperus esculentus (tiger nut) oil the Italian said «Prodotti lattiero-caseari» where the English says “Milk-based products”: the corrigendum to Reg. 2025/1528 takes it back to «Prodotti a base di latte», and with it the footnote: used in milk-based products, the oil “may not replace in whole or in part any milk constituent”. Which category is the right one is settled entry by entry: there is no rule that covers them all.

Why the category name binds

Regulation (EU) 2015/2283 on novel foods, in Article 6(2), leaves no room: “Only novel foods authorised and included in the Union list may be placed on the market within the Union as such, or used in or on foods, in accordance with the conditions of use and the labelling requirements specified therein.” The conditions of use are that column. If the category name changes, so does the text against which you check whether a product falls inside it or outside.

This has to be said plainly: a corrigendum corrects the published text, and nothing here means a product on the market today is unlawful. What effect it has over time — whether the corrected text holds from the outset or from publication — is not something we can settle. The practical point is a different one, and does not require settling that: the line in your files and the line published today no longer match.

Italian only, and the counter misleads

All thirteen exist in a single language version: Italian. We verified this in the Cellar repository, expression by expression. This is not the legislator changing its mind, it is a translation brought into line — as already happened to the definition of producer in the packaging regulation.

The number in brackets in the CELEX code counts the corrigenda registered against the act, not the Italian ones. The R(05) on Reg. 2018/1023 is the fifth for that act, but the earlier ones concerned Spanish, French, Croatian, Slovak, Estonian, Latvian and Slovenian: the Italian text had been touched once, by R(02). On Reg. 2025/1528 the R(03) follows a Spanish and a French one, and is the first in Italian. Counting brackets to estimate how often the text you read has changed sends you the wrong way — as it does for every European act, of which there are twenty-four official texts.

The consolidated text does not have them yet

Reg. 2017/2470 has 59 consolidated versions, the first dated 11 April 2018: the list is a ring binder whose pages get swapped. The most recent carries the date 10 August 2026, earlier than the late-September corrigenda, which therefore do not appear in it. Anyone consulting the consolidated text — the normal way to read a table amended 59 times — is reading the categories in their previous form. It is the same question as for the dual-use list: not which list you used, but which version.

What we do not know

We do not give legal advice: whether one of your recipes falls under «prodotti lattieri» or «prodotti a base di latte» is decided on the product, not in an article. We do not know when the consolidated text will take up the corrigenda, nor whether more are in preparation for untouched entries. We have not compared the other twenty-two language versions entry by entry. A corrigendum published but not yet indexed in Cellar we would not have seen.

The two axes, applied

Comply. The control that earns its place here holds together three things that usually sit in three places: the recipe book with its ingredients and dosages, the category of use declared for each, and the version of the Union list against which that category was checked, with the date of consultation. At an inspection the proof is not that you were right: it is when you read and what the list said that day. The control runs on your documents, flags the entries whose category has changed since the last check, and leaves the trace with date, subject and outcome.

Decide. The same system holds recipe books, technical data sheets, supplier specifications, labels and the regulatory archive together in a single operating model, on which AI agents execute decisions with a human operator in command — for large enterprises, government, defence and healthcare. At the next round of corrigenda the question which products does this touch is answered across the catalogue in an afternoon, instead of reopening folders one by one. Always on-premise, on self-contained machines needing no deep integration into your network, or in a dedicated cloud with a dedicated VPN and a data centre in Italy, and always with shared management: you need no in-house model administrators.

The first session, at no cost, produces the dated list of your authorised ingredients with, for each, the category of use and the version of the Union list it was checked against. It stays with you whether or not we go on. Talk to one of our engineers.