HRS 1:2026 — Annex D

Ingredient assessment guidance

Public consultation draft — draft v0.1 — issued 2026-09-07

This is a consultation draft, not an operative standard

The scheme described here is not yet certifying. No certificates have been issued and the Approved Supplier Register is not yet populated. Nothing in this document may be relied on as evidence of certification.

It is published for comment before it is finalised, because a certification standard that cannot be read by the people it governs is not a standard. Clause 12.2 commits us to publishing it; we would rather publish it early and be corrected.

Comments are invited until 2 November 2026. See How to respond. Passages marked ⚖️ are open questions on which we are specifically seeking views. Passages marked 📋 will be reconciled against OIC/SMIIC standards before issue.

This document is a scheme design. It is not a fatwa and does not purport to state Islamic law; questions of Shari'ah are for our Shari'ah Committee, whose rulings will be published with their reasoning.

Companion to HRS 1:2026 draft v0.2, clause 5.5. ⚖️ = Shariah Committee. 📋 = reconcile against OIC/SMIIC 24:2020 on acquisition — that standard, not this annex, is the authority.

D0. Status and a warning about sources

This annex is provisional. It exists so that assessment can begin, and so that the established method is agreed before the substance list is finalised against OIC/SMIIC 24:2020.

⚠️ Do not build this list from the Wiley handbook's Table 10.2. That table classifies E140 (chlorophyll), E161b (lutein), E252 (potassium nitrate) and E431 as haram. These are plant- or mineral-derived and that classification is not defensible. The same chapter contradicts itself at §10.10.3: "The list of prohibited E numbers is very short. E120 and E904 are prohibited… All other E numbers are basically permitted." That statement is correct; Table 10.2 is not. Table 10.3 (origins) is the sound table in that book. Publishing wrong haram verdicts on plant additives would damage our credibility faster than being too strict.

D1. The governing method — origin, not E-number

An E-number identifies a function, not a source. The same code can denote a plant-derived, animal-derived, synthetic, or microbial substance. Classification therefore proceeds by origin, and an E-number alone is never sufficient evidence in either direction.

D1.1 Decision tree

Is the substance animal-derived?
├─ NO — plant, mineral, synthetic, or microbial
│   ├─ Is it or does it contain ethanol? ──── YES ──▶ ⚖️ see D4
│   └─ NO ─────────────────────────────────────────▶ PERMITTED
│
├─ CANNOT BE DETERMINED ─────────────────────────────▶ MASHBOOH → NOT PERMITTED (cl. 5.5)
│
└─ YES
    ├─ From a prohibited species (pig, dog, carnivore, etc.) ─▶ PROHIBITED
    ├─ From an insect ──────────────────────────────▶ ⚖️ see D3
    └─ From a permitted species
        ├─ Slaughter status per HRS 1 evidenced? ─ YES ─▶ PERMITTED
        └─ Not evidenced / unknown ────────────────────▶ PROHIBITED (cl. 2.1)

Clause 2.1 governs the bottom branch. Animal-derived material from a permitted species with unknown slaughter status is not mashbooh-and-arguable — it falls under the meat rule and is treated as prohibited until evidenced.

D1.2 Evidence that satisfies "origin established"

1. Manufacturer's specification sheet stating the source of each animal-derived component; or
2. A valid halal certificate from a recognised body (Annex B, B3) covering that item; or
3. Written manufacturer declaration on letterhead, naming source and species.

Not acceptable: a distributor's verbal assurance; "it's vegetarian" without a statement of source; a certificate for a different product or site; the absence of animal ingredients on a consumer label (processing aids are frequently not declared).

Undeclared processing aids are a documented blind spot in halal and kosher production (Al-Mazeedi, Regenstein & Riaz 2013, cited in the Wiley handbook). A consumer ingredient list is not a specification sheet.

D2. Substances requiring positive origin determination

Provisional. 📋 Reconcile against OIC/SMIIC 24:2020.

D3. ⚖️ Insect-derived

The Wiley handbook (§10.10.3) treats E120 and E904 as the prohibited cases and E901 as permitted. Committee to confirm and to rule on carmine specifically, since it is common in confectionery and beverages.

D4. ⚖️ Ethanol — must align with HRS 1 clause 5.6

Clause 5.6 as drafted is an absolute prohibition on ethanol-containing ingredients. If that stands, this annex must apply it without exception, which prohibits:

• Vanilla and other alcohol-based extracts (very widely used in pastry)
• Flavourings using ethanol as a carrier (extremely common; often undeclared)
• Any liqueur or wine in cooking, including where cooked off

Questions for the Committee:

1. Is there a permitted trace threshold for unintended, non-intoxicating residual ethanol from carriers?
2. Vinegar — traditionally produced from wine but converted to acetic acid. The Wiley handbook (§10.10.5) records the settled view that vinegar is permitted, including where labelled "wine vinegar", since the ethanol is converted and it cannot intoxicate. Confirm.
3. Sugar alcohols (sorbitol, xylitol, maltitol, and other -itols) are chemically alcohols but are not ethanol and cannot intoxicate. The handbook (§10.10.5) treats them as permitted. Confirm — this needs to be explicit or auditors will flag them wrongly.

Q2 and Q3 are the two cases most likely to be misapplied by a junior auditor who has learned "no alcohol" as a slogan. Both should be stated positively in the issued annex.

D5. ⚖️ Bone char in refined sugar

Cane sugar is decolourised with bone char in some refineries; brown and confectioner's sugar derived from it are affected, and supermarket sugar is blended from multiple refineries so origin is often untraceable (Wiley §10.10.10).

This is a threshold-setting decision, not a detail. If bone-char sugar is prohibited and origin is untraceable, then most sugar in Azerbaijan becomes mashbooh and the standard becomes unworkable for any establishment serving dessert or bread. If it is permitted — whether on istihala grounds or because no bone material remains in the product — say so explicitly and publish the reasoning, so it does not resurface as an accusation later.

Beet sugar is unaffected and is a practical route if the Committee rules strictly.

D6. Assessment record — required per ingredient

Held by the establishment, reviewed at audit (Annex A items A2.9, A2.10).

D7. Consultation questions

1. D4 ethanol threshold ⚖️ — absolute, or trace tolerance for carriers? Determines whether a large part of the pastry and beverage sector can be certified at all.
2. D5 bone-char sugar ⚖️ — threshold decision with wide reach.
3. C4.4 istihala ⚖️ — must be ruled before gelatin and glycerine can be settled here. Annex C flags it; it lands here.
4. D3 carmine ⚖️ — confirm prohibited.
5. Vinegar and sugar alcohols ⚖️ — confirm permitted, and state positively.
6. Depth of assessment for compound ingredients — do we require origin declaration to the second tier (a supplier's supplier)? Rigorous, but rapidly becomes impossible for manufactured sauces and seasoning blends.

D8. In preparation

• D-F1 Ingredient assessment form
• D-F2 Manufacturer declaration template (the letter we ask suppliers to sign)
• D-F3 Approved / prohibited substance list, after OIC/SMIIC 24:2020 reconciliation
• D-F4 Auditor quick-reference card — the twenty ingredients most often wrong in practice