Changes to acrylamide regulations in 2023: What biscuit and cookie manufacturers need to know

By Gill Hyslop

- Last updated on GMT

Changes to acrylamide regulations in 2023: What biscuit and cookie manufacturers need to know

Related tags Acrylamide EU legislation Dsm food specialties Enzymes Biscuits Cookies infant biscuits

EU legislation on acrylamide is set to be renewed next year, meaning its crunch time for a number of manufacturers who are still producing biscuits and cookies with acrylamide levels above the 350 ppb benchmark level (BML).

This year marks the 20th anniversary of the discovery of acrylamide in common foods, such as biscuits, cookies, potato chips, coffee and several other cereal and potato-based foods prepared at high temperatures (>120°C) under low-moisture conditions.

Acrylamide is the naturally formed component of the browning effect – also known as the Maillard reaction – between amino acids and reducing sugars under heat. It is also considered a carcinogen, and in 2018, EU legislation introduced the BML in biscuits and cookies below 350 parts per billion (ppb).

Acrylamide science Drypsiak
Pic: GettyImages/Drypsiak

However, recent tests showed many samples surpassed this limit.

“Current legislation states is that food manufacturers are required to apply practical steps in their production according the ALARA principle, which is striving for ‘as low as reasonably achievable’,”​ said Kees Veeke, technical service manager of Baking Enzymes at DSM.

Although Veeke believes most food manufacturers are aware of the acrylamide levels in their products, many still find it difficult to meet the benchmark levels.

“This has to do with the variations in recipes and ingredients, which can cause acrylamide varying from 50 ppb up to 7,000 ppb. Biscuits and cookies have different levels of acrylamide and it can be very difficult to monitor for manufacturers [of multiple lines].”

It comes down to the type of flour used – “Asparagine levels between white flour and whole meal flour can vary by up to the effect of whole meal, and that automatically also results in higher level of acrylamide” – ​to the different types of concentrations of sugar – “Fructose is much more reactive compared to glucose, for instance, and therefore contributes significantly to the production of acrylamide.


“Also, we have the water and the activity. Water is needed to activate enzymes … to make it productive. Water is also needed to improve the extraction of the asparagine and for rotary molded cookies, for instance, not so much water is used, which makes it very challenging for producers.”

Consumer awareness

Long before the pandemic – but certainly exacerbated by it – consumers were interested in the role food had on their health and wellbeing, and Veeke believes that today, most are aware of acrylamide and its potential effects.

In 1994, it was classified as a ‘probable’ human carcinogen (group 2A) by the International Agency for Research on Cancer (IARC). Exposure to industrial levels can cause nerve damage, including muscle weakness and impaired muscle coordination, but this is way beyond what is found in food. Studies also suggest that chronic dietary exposure is capable of damaging nerve cells in the brain and could potentially play a role in the development of neurodegenerative disease like Alzheimer’s.

However, scientists admit the body of evidence in humans is still cloudy,​ even after 20 years of research. In fact, a systematic review published in Frontiers of Nutrition in April 2022 even concluded there was no association​ between high dietary acrylamide exposure and increased risk of any of the investigated cancers, including those of oral cavity, oesophageal, gastric, colon-rectal, pancreatic, prostate, bladder, lung, renal, lymphoma, myeloma, thyroid, brain, larynx and melanoma.

Acrylamide levels across the EU have been subject to a benchmarking system since 2018, but exceeding a benchmark level doesn’t mean a product cannot be placed on the market. Under the system, manufacturers are tasked to aim for As Low As Reasonably Achievable (ALARA) acrylamide levels and if the BML is exceeded, to review their mitigation measures and work towards lowering levels.

However, with 64% of consumers indicating interest in the influence food has on their health, it’s a barrier that bakery and snack producers can’t afford to ignore.


“Consumers these days are gathering more information on their daily diet – with more access to different sources like social media – and are very keen to know what they are actually eating.

“Those who are aware of acrylamide are very concerned, especially for children’s health.”

What’s in store?

EU Regulation 2017/2158 on acrylamide is set to be renewed in 2023, expected to adjust BMLs and introduce new maximum levels. According to Veeke, the current benchmark level of 350 ppb in biscuits and cookies will go down to 300 ppb, with a maximum level of 500 ppm.

If products exceed the proposed maximum levels, the consequences are anticipated to be far more stringent than if the BMLs are exceeded currently.

The new legislation is also predicted to include new categories, including root vegetable fries, fruit crisps, cocoa powder and potato-based dishes such as rösti and croquettes. In 2019, the EU broadened the list of baked goods​ to be monitored, to include pita and specialty breads, pancakes, tortillas, churros, doughnuts and croissants. It also covers a wide range of rolls, including hamburger and whole wheat rolls.

Kids eating biscuits Image source
Pic: GettyImages/Image Source

Help at hand

Thankfully, producers have a range of sources and mitigation methods to help them through the quagmire, such as DSM’s smart cookie guide.

“Our smart cookie guide is a compilation of our experience and knowhow built up over two decades with regards to acrylamide mitigation. We like our customers to have a better understanding of the formulations and processes they could use, [especially] the optimum efficiency of our enzymatic solution,”​ said Veeke.

“Enzymes are recognized as one of the better solutions, in this case, for acrylamide mitigation, but if you look to a broader perspective, enzymes are natural occurring proteins [that] appear everywhere around us. They are biocatalysts, actually; they are biodegradable; and they are able to convert a product into another product in a natural way.

“In this case, asparaginase is converting asparagine into aspartic acid and by doing that, you take out a contributor in the Maillard reaction, which helps to reduce the acrylamide level. Enzymes can also help to delay staling in bread, for instance, but also enable longer freshness in baked goods.

He added, “For acrylamide reduction, asparaginases are an ideal solution, because they require no significant change to the recipe or process. So, it is almost like a plug and play solution.”

DSM’s PreventASe enzyme – suitable for a variety of recipes from savoury crackers to sweet crispy wafers – enables producers to reduce acrylamide by 90% in crispy wafers, 80% in biscuits and 80%-87% in infant biscuits.


What are the health effects of acrylamide and how can it be reduced in food?

American Chemical Society, August 22, 2007

Dietary acrylamide and human cancer; even after 20 years of research an open question

Authors: Janneke GF Hogervorst and Leo J Schouten

The American Journal of Clinical Nutrition, 2022, nqac192

Dietary Acrylamide Exposure and Risk of Site-Specific Cancer: A Systematic Review and Dose-Response Meta-Analysis of Epidemiological Studies

Authors: Tommaso Filippini, Thorhallur I. Halldorsson, Carolina Capitão, et al

Front. Nutr., 25 April 2022, Sec. Nutritional Epidemiology

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