As a binder and flavor enhancer for dishes, eggs in breaded shrimp are classified by the EU as an allergen and must be fully declared.

In the habits and tastes of consumers in many markets, when processing breaded shrimp, manufacturers often add eggs to create an adhesive layer. Eggs help the flour layer stick to the shrimp more firmly, avoiding the flour falling off when frying. Eggs also help the breadcrumbs or tempura flour have a crispier texture. The light fatty taste of eggs helps the flour layer to be less bland, creating a delicious feeling.

In addition, egg yolks help the flour have a more beautiful yellow color, while also keeping the flour layer moist, avoiding the phenomenon of the product becoming dry and hard.

Many food manufacturers, including Vietnam and many other countries, use eggs in the breaded shrimp recipe. However, according to Article 21 of Regulation (EU) No. 1169/2011, eggs are in the group of allergenic products and must be declared on the product label.

Substances or products that cause allergies or intolerance are strictly regulated by the EU. Some common substances in food include: cereals containing gluten, crustaceans, eggs, fish, peanuts, soy, milk, nuts, celery, mustard, sesame seeds, lupins, shellfish, etc.

All products containing the above ingredients must be clearly stated in the ingredient list on the product label. Otherwise, the European Union's Rapid Alert System for Food and Feed Safety (RASFF) will issue a warning to the exporting country, along with necessary measures.

Failure to declare or inaccurate declaration of allergens can lead to product recalls or bans on imports into the EU. In the past, there have been many cases of frozen breaded shrimp not declaring egg in the breading, leading to product recalls in Europe.

Not only businesses suffer economic losses, but the entire industry can also be affected if the violation is repeated. Depending on the severity, the EU will take measures such as: increasing the frequency of inspections at the border gate, requiring a certificate from the competent authority to accompany the shipment, or more seriously, banning exports.

Eggs are a common allergen, often appearing in many frozen exported products such as fish cakes, squid cakes, sausages, etc. In addition, eggs are also a product of animal origin, when present in a composite product exported to the European market, they must comply with Regulation (EU) 2022/2292, effective from December 15, 2022.

Ms. Sylvie Coulon, senior expert of DG SANTE, said that according to the new EU regulations, breaded shrimp is classified as a composite product. Photo: Bao Thang.

Composite products are products that include both plant-based ingredients and processed animal-based ingredients, in which the plant-based ingredients have changed the basic properties of the animal ingredients.

Some examples of composite products are cookies made from eggs, milk, meat, fat; instant noodles with processed meat... Breaded shrimp is also a composite product, because it contains flour (of plant origin) and has changed the properties of shrimp (of animal origin).

Currently, the EU only allows approved third-country egg products to be exported to the EU (such as the United States, Japan, Brazil, etc.). Vietnam wants to export egg-based breaded shrimp products to the EU, it must use eggs originating from the above countries.

EU regulations on food safety and animal and plant quarantine are constantly changing. Therefore, the Vietnam SPS Office recommends that businesses carefully study EU regulations, especially those related to food safety, labeling, Regulation (EU) 1169/2011 on providing food information to consumers, as well as the very new Regulation (EU) 2022/2292 on composite products.

Before packaging for export, businesses must label fully and accurately, ensuring that all allergens contained in the product are clearly listed, helping consumers to identify and avoid them.

At the same time, strictly control quality by establishing a quality control process to ensure that there is no cross-contamination or omission in the declaration of allergens.

“Strict compliance with regulations on allergen declaration, as well as origin requirements for synthetic products, not only helps businesses avoid legal risks but also enhances their reputation and ensures consumer safety,” emphasized Dr. Ngo Xuan Nam, Deputy Director of the Vietnam SPS Office.

According to Mr. Nam, Europe regularly amends and supplements regulations and requirements on the import of agricultural, aquatic and food products. Recently, this market announced that it will apply inorganic arsenic residue levels in fish and some aquatic products for the first time. Therefore, exporting enterprises need to proactively monitor and update information about the EU market, thereby having appropriate adaptation plans and production adjustments.

Along with pangasius, shrimp is Vietnam's main seafood export product. In 2024, shrimp will bring in nearly 4 billion USD in exports, an increase of about 14% compared to 2023. This figure is forecast to continue to grow in 2025.

Source: VASEP