Sweetener Supply has received numerous questions regarding the use and limits of anti-caking agents which may be applied to shredded and grated cheese.
The use of anti-caking agents in grated cheese is specified in the Code of Federal Regulations, 21 CFR 133.146. Part (c) (2) allows the use of anti-caking agents in grated and shredded cheese. No direct limitation on maximum use is given, other than they must safe and suitable.
Although no direct limits are given, indirect limits are built into 21 CFR 133.146. In (b) (2), the code states that the milkfat content of the grated cheese cannot be more than 1% lower than the minimum prescribed by the standard of identity for that cheese. Part (b)(3), describes the use of the arithmetical average milkfat content if more than one variety of cheese is used with the additional requirement that in no case shall the milkfat content be less than 31%.
Using parmesan cheese as an example, the standard of identity for parmesan cheese is contained in 21 CFR 133.165. The minimum milkfat content of parmesan cheese listed in part (a) is 32% milkfat in solids basis. The method to determine the milkfat % in solids is listed in 21 CFR 133.5.
As a reference example, the USDA Nutrient Database is applied: http://tiny.cc/ozvp9x
Parmesan cheese listed in the USDA table has a typical moisture content of 29.16% and a fat content of 25.83%. Using the method described in 21 CFR 133.5, the milkfat in solids of this typical parmesan cheese is calculated to be 36.5%
100% – 29.16% = 70.84% solids 25.83% / 70.84% = 36.5%
As stated above, the minimum milkfat content for parmesan cheese is 32%. The use in grated/shredded cheese lowers that limit to 31%. A “typical” parmesan cheese as listed in the USDA Nutrient Tables has a milkfat content in solids of 36.5%, which theoretically leaves 5.5% available for the optional ingredients listed in 21 CFR 133.146 (c), which includes antimycotics (mold inhibitors), anti-caking agents (cellulose, starch), spices and flavorings.
That said, the actual milkfat in solids content of the starting cheese would need to be known and controlled to determine the actual level of optional ingredients that could be added to a specific grated cheese while maintaining regulatory compliance. A lower milkfat in solids level in the starting cheese could significantly limit the amount of optional ingredients that could be added. For example, starting with a lower end 32% in solids milkfat parmesan cheese block, the optional ingredients, including the anti-caking agent for grated cheese, would be limited to 1%.
Verification for regulatory compliance with 21 CFR 133.146 Grated Cheese, is based on the minimum milkfat content of the cheese and not on the absolute level of optional ingredients (including anti-caking agents).
VP of Food Technology
Sweetener Supply Corp. 2/19/16