 |
Brussels, 30 september 1997
EURO COOP's comments on the Commission's discussion paper on the addition of vitamins and minerals to food and food supplements (doc. III/5934/97)
EURO COOP welcomes the Commission's discussion paper, but notes that the proposed addition of vitamins and minerals to foods (fortification) and the proposed food supplements are two different issues and should not have been combined in the same discussion paper.
EURO COOP considers that, due to national differences, it is impossible to regulate precisely the notion of fortification, and therefore urges the Commission to start with the establishment of general principles and guidelines on this issue.
EURO COOP appreciates the various problems in the internal market which may be due to the different national approaches to the addition of vitamins and minerals to food. However, the issue of fortification should first of all be analysed on the basis of general principles laid down by the Commission. We would like to stress the principles of fortification set out by the Codex Alimentarius.
The following comments from EURO COOP are confined to the Commission's questions on food supplements.
I. Specific composition considerations
- Nutrients to be contained in food supplements and purity criteria
- Euro Coop considers that there should be restrictions on the composition of these products, which should be based on the composition doses and purity criteria. These criteria should also be considered when dealing with the use of substances, and chemical forms of nutrients that can be used in the manufacturing of food supplements.
- Euro Coop is in favour of putting a « positive list » of substances allowed in use.
- On the issue of the purity criteria for substances used in food manufacture, Euro Coop believes that it should be the same as, and not stricter than, those applicable to substances used in making drugs.
- Maximum limits for the nutrients contained in food supplements
- Euro Coop believes that there should be maximum limits set for all vitamins and minerals used in food supplements. These limits should, in line with the precautionary principle, be based on the best available scientific knowledge criteria. The label should clearly state this maximum limit.
- Minimum limits
- Euro Coop supports the setting of a minimum limit for food supplements, without which the market would be open to all kinds of fake products claiming to remedy all ills.. Furthermore, we would like to underline the importance of having the percentage of the daily recommanded daily amount (RDA) in each pill, tablet, or capsule, to be clearly stated on the label.
II. Labelling issues
- Euro Coop's labelling policy is based on the principle that all labelling requirements should derive from the Directive 79/112.
- There should be a statement for maximum limits, along with the percentage of the RDA for each tablet. In cases where the maximum is exceeded, it should be dealt with at national level.
- The food supplements' nutrient content should be declared per tablet, capsule or drops.
- Euro Coop considers that compulsory statements or warnings on maximum intakes should be given on the labels of food supplements.
- On food claims, Euro Coop urges the Commission to produce a Directive to cover all foods including food supplements' issues.
III. Packaging
- As regard the issue of CRCs (child resistant closure), EuroCoop agrees that it would be more practical to limit the use of CRCs to products containing nutrients presenting particular dangers to children (e.g. iron, fast soluble vitamins).
- Finally, Euro Coop wishes to stress the need to have a date-mark, at least on those products which loose potency over time.
|
|
