Brussels, 19 April 2005

Dear Member of the European Parliament,

I am writing with reference to the proposed Regulation on the addition of vitamins and minerals and certain other substances to foods (COM(2003) 671). As you know, many of your colleagues on the ENVI Committee have tabled amendments to this proposal in advance of the voting session scheduled for 26 April 2005.

As a Member of the ENVI Committee you are certainly aware of the political importance that a large number of European stakeholders attach to this legislative dossier.

Since the publication of the proposal in 2003 EURO COOP - the European Community of Consumer Co-operatives - has been actively contributing to the related EU legislative debate. As a recognized European stakeholder, EURO COOP has been consulted by the competent Commission services in the preparatory stage of the proposal as well as in its subsequent developments.

Overall, EURO COOP expresses support for the Commission's willingness to regulate the voluntary addition of vitamins, minerals and other substances to foods. Indeed, it is a fact that such an addition is often used by some food businesses in order to market their products as if they were healthier, which is not always the case. From a consumer perspective, this practice poses therefore serious threats: as a result consumers might in fact be mistakenly led to increase the consumption of foods that should be preferably consumed with moderation because of their overall composition (e.g. chocolate and confectionery products).

EURO COOP therefore believes that an adequate level of consumer protection in the European market can be achieved provided that the addition of vitamins and minerals and other substances is strictly regulated. As a general principle, EURO COOP thinks that addition should be allowed only when the food which vitamins or minerals are added has a desirable nutrient profile. Furthermore, in case such an addition is made to foods whose over-consumption can represent a proven threat to health (e.g. chocolate, confectionery products and soft drinks), addition should be ideally prohibited.

As for the Commission's proposal on Nutrition and Health Claims, EURO COOP is therefore highly supportive of the inclusion in the Fortification proposal of a provision referring to the establishment of nutrient profiles for certain foods or categories of foods. It is however understood that such profiles should be elaborated with a view to fully ensuring legal coherence amongst the two Commission's proposals.

Finally, as far as the Annex III concerning substances other than minerals and vitamins is concerned, EURO COOP thinks that a higher level of consumer protection and legal certainty would be better-achieved if a positive list of authorised substances which may be added to foods is established.

In the light of the concerns expressed above, we have identified the following short list of amendments tabled by your colleagues that fulfil our expectations and which we would therefore kindly invite you to consider supporting, namely amendments: 12, 50, 65, 66, 67, 68, 69, 75, and 122.

We hope that you will take on board our concerns.

Thank you for your time and attention in this important matter.

Yours sincerely,

Dónal Walshe

Secretary General