COMPLIANCE POLICY GUIDE (CPG)
CPG Sec 562.100 Acetic Acid - Use in Foods - Labeling of Foods in Which Used February 1989
Acetic acid, if of suitable purity and used in accord with good manufacturing practices, is generally recognized as safe for use in foods. It should not, however, be used under conditions which result in consumer deception, such as may result from substitution of dilute acetic acid for vinegar in "pickled" foods.
Food Inspection Decision l40, issued February 27, l9l2, included the following:
"Acetic acid diluted - The product made by diluting acetic acid is not vinegar and when intended for food purposes must be free from harmful impurities and sold under its own name."
On April 23, l952, an information letter sent to State officials advised them that:
"This Administration, in the enforcement of the Federal Food, Drug, and Cosmetic Act, has maintained the position that diluted acetic acid is not a vinegar of any kind and has advised against its use in food products customarily expected to contain vinegar.
"Where an acid of established purity used in a process of manufacture such as you describe, labeling would be required to avoid misconception on the part of the consumer. The labeling should avoid any references to pickling or description of process that would imply that the product had been prepared by the use of vinegar***."
In April l968, members of our Bureau of Science reviewed the literature to determine whether there are present in vinegars prepared from distilled alcohol components not present in acetic acid solutions. In a study by L. W. Aurand, et al, and reported in JAOAC (l965), eleven components were identified from five samples of distilled vinegar. The volatile components consisted of aldehydes, ketones, esters, and alcohols. Acetaldehyde, acetone, ethyl acetate, and ethyl alcohol were present in all samples of vinegar analyzed.
A GLC comparison was made in an FDA laboratory of distilled vinegar and five percent dilute acetic glacial acetic acid. This showed that distilled vinegar contains a number of volatile materials not present in dilute acetic acid.
Organoleptic triangulation findings using distilled vinegar and five percent acetic acid samples showed that distilled vinegar is readily distinguishable from dilute acetic acid.
These findings support our position that diluted acetic acid is not vinegar.
Acetic acid is generally recognized as safe for use in foods if it is of "food-grade" and is used in accord with good manufacturing processes.
Acetic acid is considered "food-grade" if it complies with the specifications in Food Chemicals Codex.
Diluted acetic acid is not vinegar. When used as an ingredient in food, it should be declared by its name, "acetic acid" or "diluted acetic acid".
The labeling of a food in which acetic acid is used is considered misleading if it implies or suggests that the article contains or was prepared with vinegar. Acetic acid should not be substituted for vinegar in pickled products which consumers customarily expect to be prepared with vinegar.
Reissued: 12/3/73, 10/1/80
Submit comments on this guidance document electronically via docket ID: FDA-2013-S-0610 - Specific Electronic Submissions Intended For FDA's Dockets Management Staff (i.e., Citizen Petitions, Draft Proposed Guidance Documents, Variances, and other administrative record submissions)
If unable to submit comments online, please mail written comments to:
Food and Drug Administration
5630 Fishers Lane, Rm 1061
Rockville, MD 20852
All comments should be identified with the title of the guidance.