 |
Brussels, 14/11/2000
Euro Coop asks for clear restrictions on the authorisation of food supplements
Euro Coop is the European Community of Consumer Co-operatives, whose members are the national organisations of consumer co-operatives in 12 of the 15 Member States of the EU and in 4 Central and Eastern European countries.
Created in 1957, Euro Coop today represents over 3,200 local or regional co-operatives, membership of which amounts to over 19 million consumers in the EU and 2 million in the associated countries of Central and Eastern Europe. Euro Coop's major objectives have been to promote, defend and represent consumer interests at European level.
It is on the basis of this expertise that Euro Coop has prepared the following comments on the recent Commission's proposal on food supplements.
Euro Coop welcomes the Commission's proposal for a Directive on food supplements of 8 May 2000 (COM (2000) 222 final).
In Euro Coop's view, it is essential for consumer protection to set clear restrictions on the authorisation of food supplements. We consider that food supplements can be useful to respond to certain consumers' needs, but that they can be dangerous if consumed inappropriately. Food supplements must be seen in conjunction with a balanced healthy diet and have a use for those needing or wishing to supplement their daily diet.
Euro Coop is concerned about the restrictive scope of the proposed Directive on food supplements, which only covers vitamins and minerals. Euro Coop regrets that, given the lack of current European legislation, the Commission has not seized the occasion to regulate the production and marketing of all nutrients. Euro Coop has also identified several areas where consumer safety could be undermined.
Euro Coop urges the Commission to expand the scope of the proposed Directive and to strengthen it in order to ensure a higher level of consumer safety. The following comments explain more fully Euro Coop's position on the Commission's proposal for a Directive on food supplements.
We request the Commission to consider the following points:
Euro Coop welcomes the Commission's approach of the positive list and the purity criteria
Euro Coop welcomes the Commission's approach of the positive list of authorised nutrients . Euro Coop also supports the Commission's proposal to set restrictions on the composition of food supplements. We agree that composition of nutrients should be based on the composition doses and purity criteria.
Euro Coop is concerned that the Commission's proposal only addresses vitamins and minerals
Euro Coop is very concerned that the proposed Directive on food supplements only covers vitamins and minerals. We believe that Article 2 of the proposed Directive is too restrictive and ask the Commission to include amino acids, fatty acids, and fibre. Euro Coop considers that restrictions on the authorisation of these food supplements must also be strictly regulated to ensure consumer safety.
We request the Commission to provide more information about the statement that "It has been decided for practical reasons to deal at this stage in detail with products containing vitamins and minerals". We also ask for more detail about the Commission's declaration to amend the Directive in the future to cover in detail products containing other nutrients and/or ingredients".
Euro Coop agrees that maximum and minimum limits must be established but underlines that country-specific nutritional needs must be taken into account
Euro Coop agrees with the Commission's proposal that there should be maximum and minimum limits set for all vitamins and minerals used in food supplements. We believe that such measures are essential to ensure the safety of these products. On the one hand, inappropriate use could lead to an intake exceeding desirable levels and result in health problems. On the other hand, the setting of a minimum limit for food supplements is necessary to avoid the production and marketing of fake products claiming to remedy all ills.
However, Euro Coop underlines that specific nutritional needs must be respected when establishing maximum and minimum limits. We believe that nutritional needs vary greatly among European consumers, therefore we doubt that European wide minimum or maximum levels would be appropriate. For instance Vitamin D supplements are often necessary as an addition to the Scandinavian winter diet but would rarely be required in the southern Mediterranean countries. Therefore, we would like to see country specific limits established taking into account the precautionary principle.
Euro Coop urges the Commission to adopt a horizontal Directive on claims
There is currently no legislation on claims at the European level. Euro Coop has always called for a horizontal Directive on claims and underlines once again that such a Directive is crucial to ensure consumer safety. We request that the future horizontal Directive announced in the White Paper on Food Safety covers all foodstuffs, including food supplements.
We are pleased to see that the issue of claims has been included in the working programme of the Commission, but we are very concerned that the Commission has not planned to propose a Directive on claims before July 2001. As the proposed Directive on food supplements does not contain any provision on claims, it is very important that the Commission promptly set clear restriction on their authorisation.
According to the existing working programme of the Commission, the Directive on Food Supplements will be adopted and enter into force before the legislation on claims. We seriously question how consumers' protection will be ensured in the interim period.
Therefore, Euro Coop urges the Commission to adopt the horizontal Directive on claims.
Euro Coop welcomes the labelling requirements but considers they should be strengthened
Euro Coop welcomes the labelling requirements contained in the proposed Directive, in particular:
- The proposal that labelling of food supplements should draw from Directive 79/112/EC on the labelling, advertising and presentation of foodstuffs;
- The prohibition of medical claims that the product can prevent, treat or cure illness;
- The percentage of the daily recommended daily amount (RDA) in each pill, tablet, or capsule, is clearly stated on the label;
- A warning about the possible health risks of excessive use in the diet.
However, Euro Coop believes that additional labelling requirements should be included in the proposal to further protect consumer safety, in particular:
- 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 drop;
- Compulsory statements or warnings on maximum intakes should be given on the labels of food supplements;
- Euro Coop fully supports the mandatory inclusion on labels of a statement that "food supplements should not be used as a substitute for a diversified diet". However, we feel that the current drafting does not sufficiently stress that food supplements are normally not needed when consumers have a normal and healthy diet.
- A date-mark, at least on those products which loose potency over time.
Euro Coop urges the Commission to include additional packaging requirements in the Directive
We welcome the proposal that packaging resembling that of pharmaceutical products will have to carry the statement "This is not a medicinal product".
Euro Coop is very disappointed about the absence of provision on child resistant closure (CRCs). Many children confuse food supplements and sweets and encounter serious health problems. Therefore, we request the Commission to address this important issue and to insert a provision requiring the use of CRCs for all nutrients.
|
|
