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Brussels, 30th November 2000
Euro Coop's comments on the addition of nutrients to food
European Commission
Mr David Byrne
Commissioner
DG SanCo
Rue de la Loi, 200
B-1049 Brussels
Dear Commissioner,
In its White Paper on Food Safety the Commission announced the publication of a Directive on fortified foods by September 2000. A preliminary draft proposal relating to the addition of nutrients to food has already been prepared and circulated by the Commission services, with the aim of finalising a proposal by December 2000.
Euro Coop, the European Community of Consumer Co-operatives is concerned by the approach taken by the Commission in its preliminary draft proposal. Today, there is a growing number of these foods on the market, with benefits to consumers which are not always clearly demonstrated. Products of bad dietary value, but with added nutrients, are being marketed. Consumers can be mislead, and believe they are eating a balanced diet on the basis of claims for daily intake of the various nutrients, when they are in fact not eating a healthy, balanced and varied diet. In addition products with added nutrients which are usually substantially more expensive than 'standard' products, are progressively replacing the latter, leaving little or no choice to consumers.
We want to underline that Euro Coop is not opposed to the voluntary addition of nutrients to food by manufacturers, and recognises that in some cases it can be beneficial to consumers, but we urge the Commission to impose restrictions on the production and marketing of these products.
In all EU countries, a normal varied and balanced diet, as recommended by public health authorities, will provide the necessary nutritional needs of the general population. When this is not the case, governments can provide for compulsory addition of nutrients to food, such as vitamins A and D in margarine. A small part of the population (pregnant women, and elderly people) may need supplements to this diet. This may be addressed by food supplements or foods with added nutrients.
Foods with added nutrients are marketed in a way that makes all consumers believe that they are necessary or will be beneficial for health. This is increasingly the case now that the link between diet and health is widely recognised and accepted by consumers.
We would like to draw your attention to the following areas of concern which are not properly addressed in the Commission draft proposal. In many cases, the benefits for health of these products is not clearly demonstrated, or is not based on any scientific evidence. The EU regulation must ensure that only foods with added nutrients, which are widely accepted as beneficial by the public health authorities, are placed on the market. The future European Food Authority could play a role in ensuring the existence of appropriate scientific and public health evidence to support the marketing of these products.
Also, the EU should place restrictions on the types of foods to which nutrients can be added. For instance products high in fat or sugar, such as crisps or sweets, which should be a limited part of the diet, are not appropriate for the addition of nutrients. They are particularly attractive to young people, who may believe that they are eating their daily amount of vitamins, minerals, and fibres, without considering their full dietary needs. Addition of nutrients to food should therefore be limited to basic foods (bread, dairy products, cereals, etc).
Other crucial provisions, which are not fully developed in the Commission draft, concern the labelling and advertising of these foods. The Recommended Daily Allowance (RDA) should be stated clearly on labels, to inform consumers about the concentration of the product to their diet, and guide them in their use. All products should clearly state that a balanced diet, as recommended by public health authorities, provides all nutrients necessary to the average consumer.
Finally, claims on the benefits of these products must be strictly controlled. This must be addressed in the future Directive on labelling due to be published by the Commission in July 2001. Nevertheless, Euro Coop is concerned that the Directive on addition of nutrients to food may enter into force, before adequate legislation on claims is adopted.
Euro Coop supports the proposal by the Commission to impose minimum and maximum levels for the addition of nutrients to food. Minimum levels will ensure, that consumers are not mislead by foods claiming to have added nutrients, when they do not contain higher levels than would normally be found in the food. Maximum levels are required to ensure that excess levels do not adversely affect the health of consumers.
We hope that these comments will be useful to you and your services, and that they will be taken into account during preparation of the Directive.
Yours sincerely,
Caroline Naett
Secretary General Euro Coop
Cc:
Mr M Power, Head of Cabinet, Health and Consumer Protection
Mrs V. Arnault, Deputy Head of Cabinet, Health and Consumer Protection
Mr R. J. Coleman, Director-General, DG Sanco
Mrs P. Testori-Coggi, Director, Unit D, DG Sanco
Mr P. Deboyser, Head of Unit D 4, DG Sanco
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