ANH - the Alliance for Natural Health situated in the UK but representing medical doctors, complementary health practitioners, consumers as well as food manufacturers and distributors from all over Europe - has filed a response to a discussion paper of the European Commission which asks for input regarding the "how and why" of restrictions to dosages of nutrients in foods envisioned by two pieces of European legislation: The food supplements directive and a proposed regulation on food fortification, that is, the addition of vitamins and minerals to "normal" foods.
The Alliance's director Dr Robert Verkerk criticizes the EU authorities' approach to risk assessment, saying that the methodologies proposed so far will lead to inconsistent outcomes and in some cases to restrictions on dosage that may prevent optimal amounts of nutrients from being available to consumers.
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Summarizing, the ANH response concludes:
The EC and EFSA appear to be prematurely seeking to establish limits on allowed vitamin and mineral ingredients (and soon phytonutrients, essential fatty acids, amino acids, and other groups of nutrients) (under Article 4 of the Food Supplements Directive) as well as limits on dosages (Article 5) when proper methodologies for risk assessment, and more specifically risk/benefit assessment, have yet to be defined and validated properly.
Such an approach can only be made to work if extremely and disproportionately precautionary approaches are adopted, and while these can be justified for environmental chemicals and other toxins, there is no evidence of adequate justification for their use in the case of nutrients which are consumed primarily for their beneficial properties.
The entire document - Consultation response to the European Commission Discussion Paper on the setting of maximum and minimum amounts for vitamins and minerals in foodstuffs - can be found here.
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