CPG Sec. 585.900 Tomato Products - 
Adulteration with Mold 
REGULATORY ACTION GUIDANCE: 
All mold counts are to be confirmed by a qualified analyst before consideration for regulatory 
action. 
A.  The following represents the criteria for direct reference seizure *requests to the Office of 
Human and Animal Food Operations (OHAFO) in consultation with the Office of 
Enforcement and Import Operations (OEIO) and CFSAN, and for direct citation by the 
appropriate Field Office within the Human and Animal Food Program* if any of the 
following mold count criteria are met or exceeded by any code, or by the lot if no code is 
present: 
Article  Six Subsamples Examined 
Tomato juice  Average 24% or above & all subs above 20%. 
Tomato Paste or Puree (refractive index 
as indicated AOAC Methods of  Average 45% or above, and all subs above 40%. 
Analysis) 
Tomato sauce (Undiluted)  Ditto 
Average above 15% and all subs above 12%. Based on 
Canned tomatoes with or without added 
examination of juice packing medium drained from 
tomato 
canned tomatoes. 
Average above 29% and all subs above 25%. Based on 
Canned tomatoes packed in tomato 
examination of packing medium drained from canned 
puree juice 
tomatoes. 
Pizza sauce (based on 6% total tomato 
Average 34% and all subs above 30% 
solid after pulping) 
Tomato soup and tomato products  Average 45% or above and all subs above 40%. 
B.  REMARKS: 
C.  Seizures involving these products must be discussed with the U.S. Department of 
Agriculture because some lots may have been graded by them. *E-mail* or FAX the 
following information to CFSAN/Office of *Compliance*/Division of Enforcement 
(HFS-605) and await reply before processing:    Sample Number 
o
  Article Involved 
o
  Amount of Lot 
o
  Codes 
o
  Date of Shipment 
o
  Dealer 
o
  Shipper 
o
  Analytical Conclusions 
o
SPECIMEN CHARGE: 
Article adulterated when introduced into and while in interstate commerce, within meaning of 21 
U.S.C. 342(a)(3), in that it consists wholly or in part of a decomposed substance by reason of 
presence therein of decomposed tomato material. 
D.  The following represents the criteria for recommending legal action to CFSAN/Office of 
*Compliance*/Division of Enforcement (HFS-605): 
Article  Six Subsamples Examined 
Tomato catsup  Average 55% or above 
Tomato powder (except spray dried)  Average of 45% or above and all subs above 40%. 
Tomato powder (spray dried)  Average 67% or above 
E.  Note: Tomato Powder - check to determine if it has been spray dried. (See attachment). 
Attachment to Sec. 585.900 (CPG 7114.30): 
Tomato Powder 
Tomato powder is produced by dehydrating concentrated tomato pulp. In preparing the powder 
for mold counting the moisture content is disregarded and a dilution of water is made to give a 
mixture with approximately the tomato solids content of the standardized preparation for mold 
count of tomato puree or paste, namely, 8.5 percent. 
Identification of powder as spray-dried product:  Mold counts of spray-dried tomato powder show significantly higher counts than the paste from 
which it is made due to breakage of mold hyphae aggregates. Use following procedure to 
determine whether powder represents a spray-dried product. 
To determine microscopically whether the product has been produced by spray-drying, suitable 
mount a small portion on a microscope slide in mineral oil or other non-aqueous mounting 
medium and examine microscopically at 100-200X. Spray-dried particles are translucent and 
contain air bubbles and numerous small granules within the particles. The shape of the particles 
ranges from spherical to elongate to irregular with rounded outlines and essentially no sharp 
angles. In the rehydrated powder, practically no intact tomato cells are evident. Drum-dried or 
similarly processed powder or flakes are characterized by irregular-shaped particles with angular 
outline and practically no embedded air bubbles. 
Examine spray-dried tomato powder for HMC by AOAC 44.211. 14th ed. 
*Material between asterisks is new or revised* 
Issued: 10/1/80 
Revised: 3/1/82, 7/1/83, 9/1/84, 1/16/85, 3/95, 8/96, 5/2005 
Updated: 11/29/05