Composition of non-brewed condiment

Reginald SmithAll About Vinegar, Non-brewed condiment, Uncategorized, Vinegar Industry17 Comments

Image from Wikimedia; photo by Matthias Meckel

Ah, what would fish and chips be without malt vinegar non-brewed condiment? Non-brewed condiment is more quintessentially British than even malt vinegar since while malt vinegar is produced and sold here in the US and other places, non-brewed condiment has a much more limited range of geographies where it can be sold since it is not fermented by bacteria like normal vinegars. In the US, this makes it illegal for retail sale, even as “non-brewed condiment” though non-fermented acetic acid can be used as a food additive in some limited cases.

Non-brewed condiment has been around for decades. It has an interesting legal history where the British malt vinegar industry fought very hard to exclude it from the ‘vinegar’ designation due to cost competition. The government was originally hands off but finally required it to not be labeled as vinegar in 1949* (see story below).

Despite this, its status as the un-vinegar wasn’t really known but is periodically popularized such as Tom Scott’s YouTube video with 2.2M views and counting. It was also raised by viewers in the comments of Adam Ragusea’s recent vinegar history video (disclosure: I am a participant)!

So this article gives the full details on non-brewed condiment and how it is made, contrasting this with white distilled/spirit vinegar. For information on the ingredients and production processes of white distilled/spirit vinegar, see my blog post here. In short, it is made of distilled alcohol fermented with bacteria in industrial vinegar plants to vinegar.

Non-brewed condiment has a different origin. In short, it is made from food grade glacial acetic acid, diluted with water, colored with caramel, and with some salt or spices added for flavoring.

The origin of the acetic acid that is used in non-brewed condiment is the massive scale acetic acid production operations that make acetic acid for industrial uses like making PET for plastic bottles. The most common process for making acetic acid on these scales is a complex process reacting methanol with carbon monoxide in the presence of a metal catalyst. This catalyst determines the name of the process. The older Monsanto process uses a rhodium catalyst while the newer Cativa process uses iridium. As a quick historical notes, these catalysts are both cheaper than the first known catalyst to produce acetic acid, platinum, discovered by Sir Humphrey Davy in the 19th century.

This acetic acid is purified and distilled. Most is shunted for industrial customers but some is made food grade for food manufacturers including non-brewed condiment makers. The standard for food grade glacial acetic acid most commonly used is based on the Food Chemicals Codex which specifies a purity by weight of no less than 99.5% as well as max allowable levels for arsenic, heavy metals, and a few other requirements. A good example is this specification from BP Chemicals which is one of the largest suppliers of food grade glacial acetic acid to non-brewed condiment manufacturers.

Once sold to the non-brewed condiment manufacturer it is diluted with water down to 4-8% (4.5 -5% is usually considered ready use while higher acidities are for ease of shipping and require subsequent dilution). In addition, color is added with caramel, usually caramel E150c. The amount varies by recipe but cannot exceed 50,000 mg / kg of condiment per the FAO Codex Alimentarius. This is actually the same maximum as for some balsamic vinegars that can have up to 50,000 mg/kg of caramel E150d. In addition some salt or spices can be added to better mimic malt vinegar.

While non-brewed condiment and white distilled/spirit vinegar both have primary components of acetic acid, there are subtle chemical differences that give an improved flavor and other properties to naturally brewed vinegar. These are not known to make a health difference though and white vinegar/non-brewed condiment of similar acidities can be used in a similar way as long as caramel coloring and possible higher sodium are not an issue. A summary of the differences between plain acetic acid and distilled vinegar was made by the FDA in the 1960s:

In April 1968, 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 (1965), 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.

In many countries, the local vinegar market is stymied by (sometimes illegal) imports of glacial acetic acid from China and India. Additionally, it can be used to adulterate or increase the acidity of vinegar products.

*From Slater, A.W. (1970). The Vinegar Brewing Industry. Industrial Archaeology: The Journal of the History of Industry and Technology. 7, 292-309.

Artificial vinegar, or dilute acetic acid…was marketed under the names of ‘table vinegar’, ‘pure vinegar’, and even ‘malt vinegar’, despite the fact that in 1928 it was decided, in a High Court case, that the sale of acetic acid as ‘table vinegar’ was a contravention of the Food and Drugs Act, and in 1937 the decision of the Chief Magistrate at Bow Street, that it was ‘not permissible to sell as vinegar or table vinegar a substance which is not the product of fermentation’, was upheld at the London Sessions. After this decision acetic acid was sold as ‘Non-brewed Vinegar’, but in 1949, in a test prosecution at Bow Street under the Merchandise Marks Act, the Chief Metropolitan Magistrate decided that ‘Non-brewed Vinegar’ was in fact a false trade description, his decision being upheld in the King’s Bench Division, whereupon the trade association concerned announced that in the future their product would be sold as ‘Non-brewed Condiment.’ It has now ceased to be a threat to the manufacturers of brewed vinegar….

17 Comments on “Composition of non-brewed condiment”

  1. Interesting blog post. I am from the UK and most of the population here do not even realise that what they are pouring on their chips in the Chip Shops is not even real vinegar. Chip Shops used to often have Malt Vinegar but that seemed to die out in around 1980s and 1990s and i have not seen Malt Vinegar in any Chip Shops for years now.

    What is interesting is that here in the UK almost all the Chip Shops in England use the coloured (with Ammonia Caramel Colouring added) NBC where as almost all the Chip Shops in Scotland use the uncoloured (just Water and Acetic Acid only) NBC instead. I am not really that sure why this is but for some reason the English prefers it coloured and the Scottish prefers it uncoloured. Some chip shops around the UK also have the Onion Flavoured one and Pickling Spice Flavoured one but these are not really that common. They will normally just use the plain flavoured ones.

    The NBC that is sold in shops (which is only really sold in some of the larger supermarkets and in greengrocers and some other independent shops) is always the plain uncoloured version with just Water and Acetic Acid only and no colouring and no flavouring. It must be incredibly cheap to produce though. In my local greengrocers they sell a huge 5L bottle (the plain flavoured and uncoloured version) of NBC for just £0.99 for that huge bottle. All of the other shops i have seen it in charge similar prices. In the same shop they also sell a huge 5L bottle of Spirit Vinegar but that is £1.99 so i suppose the cheapness of NBC is why it has become so popular with Chip Shops and food manufacturers.

    I have two questions about this Non Brewed Condiment if you do not mind.

    I have been to the USA a couple of times and i know that i have seen Acetic Acid listed in the ingredients of quite a few packaged food products in supermarkets over there so i am surprised that they do not allow the Non Brewed Condiment to be sold! Normally the UK has far stricter food laws than the USA rather than the other way round! Can i ask is there any particular reason why they will allow it in packaged food but not sold on its own as Non Brewed Condiment like we do in the UK? I was just wondering what exactly makes this illegal if they are not calling it vinegar and the Acetic Acid is allowed in food products?

    Also i was reading your blog post about making your own Spirit Vinegar at home and was just curious could someone make their own Non Brewed Condiment at home from scratch? Could you produce your own Food Grade Glacial Acetic Acid and then just dilute that to 5% Acidity to create Non Brewed Condiment at home? Or does the production of the Food Grade Glacial Acetic Acid require a factory and specialist machines? I was just wondering if someone had the right stuff this would be possible or would you say it is not possible to create the Food Grade Glacial Acetic Acid at home? I am not planning to but just simply curious! It would certainly be interesting to do if it is possible though!

    Great blog post by the way. I have been aware of NBC for a long time but never knew much about how it was made.

    1. Thanks for the reply! Vinegar legislation is an interesting and surprisingly complicated topic here in the US. I stated ‘illegal’ though it is more complicated than that but still not likely. In short, the FDA does allow the use of acetic acid up to 9% in condiments. Also, the FDA historically allowed diluted acetic acid to be labeled as ‘imitation vinegar’. The latest case of this to my knowledge goes back to the late 1980s in Puerto Rico where a packager was allowed to call diluted acetic acid ‘imitation vinegar’. So it would seem clear that you can do it, so what is the problem?

      First, vinegar makers are cautious since there was a case, all the way to the Supreme Court, warning against mis-branding vinegar (I wrote about it here). Second, the FDA, while accepting non-fermented acetic acid as an ingredient, strongly warns against using it where vinegar is expected and forbids it in pickling. Finally, and the big issue here, is the raft of state regulations forbidding it.

      You are correct that UK and EU food regulations tend to be more consumer vs. industry friendly as compared to here in the US. What often can happen though is individual states can pass laws more stringent than the federal government. In this case, many states including important states like New York have bans on making or selling “imitation vinegar”. More widespread are state laws forbidding artificial coloring of any vinegar or imitation vinegar. So colored NBC would be illegal to sell in many states and even clear NBC is illegal in states than ban “imitation vinegar”. Most of these laws are 100+ years old and were pushed by the American cider vinegar manufacturers when large scale cheap acetic acid (then wood vinegar) came onto the market. Imitation vinegar has barely been tried since the 1940s I think though I guess if you found somewhere that didn’t forbid it and labeled it imitation vinegar, you could do it.

      Regarding making glacial acetic acid at home, it is near impossible and honestly would not be worth it even if you could since food grade glacial acetic acid is so cheap. I don’t know how distribution in the UK works but I think someone could probably get 5L of food grade glacial acetic acid and then dilute it. However, glacial acetic acid is very caustic and dangerous. Gloves, full cover goggles, are required at a minimum. Due to the caustic effect on skin, full plastic protection is probably a good idea too. It would be better to buy acetic acid at a lower strength, 30% max, to make NBC at home.

  2. Hello Reginald,
    I just saw a video on YouTube with you explaining how to make vinegar. Extremely interesting!! Do you do demos? I know Covid-19 has stopped many things. I’m really curious to see your facility up close and in person. My families from Bermuda, so I grew up putting vinegar and red pepper flakes on all my fish meals. Well it was fun chatting!

    Until later,
    Una T. Sutton

  3. Just two typos. You have written both E105C and E105D when i think that you actually mean E150C and E150D instead. E105C and E105D do not exist and E105 is Fast Yellow AB which is an artificial colour that has been fully banned in the UK and in the whole entire EFTA/EEA/EU area. E150C is for Ammonia Caramel and E150D is for Sulphite Ammonia Caramel which i assume is what you mean. Hope this helps.

    1. Thanks, that was an unfortunate oversight that I have corrected. I really appreciate you bringing this up.

  4. Hi there! I loved the article and it was very helpful. I grew up in the US and then lived in the UK for 2 years. I fell in love with the fish ‘n’ chips there and wondered for years why the vinegar in the US was so different than the vinegar used in the shops in the UK. I’m assuming I actually fell in love with NBC instead. Since I now live in the US and cannot easily get NBC, what would be the best replacement for it? Thanks!

    1. Honestly, malt vinegar is basically what we have available in the US. If you can find a caramel colored vinegar that is imported or if you want to buy caramel and color white vinegar yourself, that is the closest equivalent. There is a gourmet malt vinegar from Cornwall that is slow brewed you could try too.

  5. also found you from the you tube video.

    seconding the idea of doing any video classes or so on- it would be fun!

    since i am in Philadelphia… are you doing any local pick up (non contact i presume) or local delivery for vinegar or mother? or is it all through Amazon?

    1. Hi, we do not do local pickup unfortunately since we just have a brewery and not a storefront. Amazon is the only outlet now but we should have ecommerce on the site later this year. We are also looking at Youtube videos for teaching vinegar making.

  6. I just thought that i would point out a couple things in regards to the comments above about obtaining Non Brewed Condiment in the USA which can indeed be rather difficult to find.

    Malt Vinegar is not similar to Non Brewed Condiment at all. Malt Vinegar tastes completely different. If you can not get hold of Non Brewed Condiment than i would not recommend Malt Vinegar due to how different it is. You can definitely notice a big difference in flavour. Taste the two of them together and you will definitely notice a big difference.

    The most similar alternative to Non Brewed Condiment is just your ordinary cheap Spirit Vinegar (aka Distilled Vinegar or White Vinegar or whatever you call it) as this actually tastes rather similar and is easily available all over the USA and pretty much every country around the world. I think that it is made from Corn or Sugar Beet or Sugar Cane but it tastes pretty much the same as Non Brewed Condiment tastes. You will not really notice any difference in taste.

    I would not worry about getting any coloured version or buying colouring to colour the vinegar as the colouring is completely flavourless so has no impact on the taste at all. Plus anyway some of the Non Brewed Condiment in the UK is served uncoloured too. Not all brands add the colouring to it. It is probably a lot healthier without the added colouring too.

    If you really want Non Brewed Condiment though then i believe that there are some sellers on Amazon and Ebay who ship from the UK to the USA so that is an option too but the postage charges might be expensive.

  7. So could i ask what exactly does the Food Grade Glacial Acetic Acid for the Non Brewed Condiment come from in the first place? Like what are the chemicals made from?

    You say it is normally made by reacting Methanol with Carbon Monoxide in the presence of a Metal Catalyst but what are all of these things made from in the first place? They sound like chemicals but i presume they must be made from something?

    Also out of interest do you know if all of the Non Brewed Condiment manufacturers normally produce their Food Grade Glacial Acetic Acid themselves? Or do they simply purchase the Food Grade Glacial Acetic Acid themselves and then dilute it to 5% Acidity (or whatever Acidity level is being used) rather than making it from scratch? I have seen Food Grade Glacial Acetic Acid sold online (which i personally would not want to buy seeing how dangerous it is without tons of protective equipment) so guessing they must as i can not think of what else that you would use the Food Grade Glacial Acetic Acid for other than for Non Brewed Condiment production?

    One last question? When you look at Food Grade Glacial Acetic Acid sold online it normally says 99.85+% so i am just wondering what exactly this means? What exactly is the other less than 1% of the 99.85+% made of? The list of ingredients does not seem to list anything else in it so i am just confused as to what this other less than 1% is?

    1. Hi, the glacial acetic acid made from the various processes is still pure acetic acid in the end. The Methanol and Carbon Monoxide can come from a variety of industrial sources but is not present in the end product.

      Non-brewed condiment manufacturers all purchase their food grade glacial acetic acid and then dilute and color it. They do not manufacture it. Manufacturing is done by huge corporations like BP.

      As far as the less than 1% residual, it is hard to tell. I think maybe some intermediate products like acetalaldehyde or ethyl acetate are present which are generally harmless.

  8. Great to find this. Really simple question to hopefully solve an on going argument.
    What sort of date was NBC first used within England ?
    Pie mash and Liquor being a traditional London dish since late 1800’s has always had the option of having chilli vinegar with it as far as anybody alive can remember.
    The debate is would it have originally been a chillied malt vinegar or NBC that could have possibly been referred to as vinegar pre 1949!

    Which is traditionally correct to have with pie mash and liquor? Vinegar or NBC?

    Really appreciate your thoughts

    1. Hi Scott, there are two answers to this question:

      First, NBC was used for many years (likely made from wood vinegar) but was called vinegar until 1946 when the British Malt Vinegar Brewers’ Federation convinced the Ministry of Food that it should be designated “non-brewed vinegar”. This was further changed in 1951 by the High Court case Kat v. Diment that ruled ‘vinegar’ was essentially misbranding for non-fermented acetic acid and thereafter it became known as “non-brewed condiment”. See more info from the UK Vinegar Brewer’s Federation here.

      As far as which is more ‘traditional’ artificial acetic acid from wood vinegar and later other processes didn’t become big until the late 19th century so before that anything with vinegar in the UK usually meant malt vinegar unless imported French wine vinegar was preferred.

  9. I live in the UK, and I have just bought a litre of Acetic Acid ((.85 ACS Food Grade.
    I intend making the fish & chip vinegar I love, which as an earlier blog states tastes totally different to malt vinegar and any other vinegar.
    I am nearly 78 years of age and I first learned how to make this vinegar from a local greengrocer about 55 years ago. his name was Dai Giles and he used to sell jars of pickled onions which were the the best in Wales. He also used to sell the vinegar all made in back of his little shop.
    This vinegar is by far the best for making Mint Sauce, and poured on Welsh Lamb with red currant jelly is out of this world..
    One question, I am pretty sure I used to dilute the acetic acid x 12 water to 1 of acid, with just a couple of teaspoons of liquid gravy browning to colour.
    The question is will this rate of dilution give me somewhere near 8% Vinegar?

    1. Hi, I think 12:1 water to acid will give closer to 6.5% which I think is a good acidity. For 8% use 1 part vinegar to 9.5 parts water.

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