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VEGA's comments on proposals for new EU Regulations on Food Additives and Enzymes.
1. Attempts at integrating food laws into comprehensive, simplified and more effectual legislation are welcome; however, the concerns of minorities, who may compromise numerous populations within the (now extended) EU, must not be submerged in proposals for highly topical issues still uncertainly defined and likely to require amendations and further debate in the next few years.
2. Recognition in the draft proposals that experimentation and tests on animals must be “reduced, refined and replaced” (the 3RRs) as far as possible is welcome and must be emphasized. The EU’s REACH intentions on testing of thousands of household chemicals, some of which may have applications for culinary, preparation and manufacturing purposes, must also be included in these reservations. Possibilities of duplication must be averted by tests already carried out in countries outside the EU and considered adequate or better for EU purposes. The emphasis must be made continually that the S in the FSA stands for standards, which comprise safety in the wider appreciation of health and well-being. Accordingly, claims of “not tested on animals” or “cruelty-free” must be understood to lack (questionable) assurances of safety that untutored customers, retailers, manufacturers and producers may (overreachingly) claim, but where deference to the wider ethical principles entails hardly any risks beyond those arising from “natural”, healthy, balanced, “organic” diets. Labelling and advertising must be monitored accordingly.
3. Constraints of space on labels for objective information can no longer be adduced in defence of coyness over explanations of ingredients and processing on websites. The public should be assured of full access (e.g. on appropriate websites, which should generally be accessible in-store) to detailed information, printed out if required. The additional possibilities for scrutiny by independent assessors would raise manufacturers’ and retailers’ practices and manifestations of due diligence and attention to traceability. Customers should have access to such details on food and beverages consumed or sold in restaurants, hotels, cafés and take-aways, such availability being recorded as part of good catering practice and observance of HACCP principles.
4. Categorization causes confusion and duplication with additives fulfilling mixed functions. Caramels, for instance, may be used both as colouring adjuncts and as thickening or texturizing agents. Further, caramels (some of which are “chemicalized” and objectionable to consumers and the industry jibbing at cruelty in experimentation on the safety assumed for inclusion of such agents in cosmetics) are added in the composition of many foods and beverages (notably soft and carbonated drinks, such as colas consumed by and popular with children); for these purposes they are added and consumed in gram quantities, compared to the mg scale of intakes of coal-tar colorants. Intakes, duration and extent of consumption, and side-effects are more strictly monitored for prescribed and over-the-counter drugs and supplements. Any artefacts for “tarting food up” or merely cosmetic purposes are now otiose and untenable causes for avoidable testing and suffering because the technology of good manufacturing practice and cuisine suffices to retain essential qualities in foods and beverages. Comprehensive disclosures and informed competition furnish consumers with choices to avoid complicity in objectionable devices and passing off.
5. Additives, especially colorants, are applied in various household contexts and under different descriptions and in different grades, e.g. as E numbers or FD and C numbers, or with chemical names (of which there may be variations, if only for reasons of language). Draft Regulations must clarify this usage and define the languages in which labelling is worded. Free trade within the EU and entry of products from without, as well as descriptions on exported goods, require standards of presentation. Requirements of travellers and holiday makers must also be entertained. Some customers may need assurances of what is not in certain foods, for reasons of dietary intolerances, residues of husbandry (e.g. in animal-derived products such as honey or eggs) or aversions due to infringements of religious precepts (e.g. distinguishing ordinary Marmite from the kosher form).
6. Origin and provenance, and traceability are issues increasingly exercising consumers. These requirements must include additives and ingredients, as well as composite foods (which would extend to pet foods and feedstuffs) and to toiletries, especially those (such as toothpaste) likely to be ingested. A consumer-need on an animal-vegetable-mineral (AVM) basis has arisen, informed and illustrated in various “free” ways - free from trans-fats, dairy-free etc. “Cruelty-free” cosmetics and clothing initiated such a trend. These stipulations are sought by a constituency extending beyond customers identifying themselves e.g. vegetarians, vegans, Jewish, Muslim, Hindu or organic- or health-minded. Some customers’ perceptions, especially if they are interested in the environment, would relate to components of packaging and the consequences of recycling, biodegradability, sequestration and “carbon economics”. Some items may derive from any of the AVM categories, e.g. glycerol and stearic acid and compounds thereof. Finings (clarifying agents used in the production of beers, wines, spirits and fruit juices) are processing aids – and therefore not usually declared – that may be derived from animal proteins such as gelatin or obtained from hens’ eggs or from seaweed. Milk and dairy produce should be distinguished by prefixes or suffixes illuminating the AVM-principle – cow’s milk, soya milk, ice cream and yogurt for instance, as well as dairy-free spreading and cooking fats. Whey is a product that can be A or V; egg-white may be from caged, barn or free-range birds. “Gelatin” and tallow may come from various animal and even vegetable sources, pig and fish varieties being favoured at the moment over bovine derivatives.
7. An adequate definition of GM is still required. The artificially-bred freaks of modern plant and animal breeding, as well as the capability of microorganisms to undergo chromosomal and plasmid changes in generating resistance to antibacterial agents indicates persistent problems developing before the age of GM and the consequent furor. Just as barleys esteemed for brewing have been derived by the action of irradiation or toxic chemicals to induce ablating mutations, GM activities in yielding allergen free wheat or connecting up the biochemical chain of fatty acid synthesis in oilseed rape to the preserved magnificence in seaweed are likely to soften antagonism to genetic modifications. Advances in human and animal genomes may come to benefit consumers with better-informed choices in their dietary fare and the choices they can indulge in within the limits of their nutritional repertoire and the inherited functions of their vital organs.
8. Jewish and Muslim authorities take differing views on GM. Production of “human” insulin, rather than bovine or porcine versions, by means of GM-microorganisms has appealed to vegetarians and Jews, and the advent of the (misleadingly-named) “vegetarian” cheese made by applications of enzymes derived from GM microorganisms has been hailed as a success, albeit a dubious one on several counts, the products being far from dairy-free. Objection to GM are on an unsound basis, innovations being simultaneously welcomed for products needing some of the improvements people look for while the same constituency damns the whole concept of GM indiscriminately. While this lack of consistency persists and full labelling remains essential – and it emphasizes the need for including processing aids in lists of ingredients – longstanding and better informed campaigns for objective claims and labelling should not be overshadowed. In our experience opponents of GM take few pains to establish the sources and processes of citric acid or riboflavin (vitamin B2, which is also used as a colorant); and the origins of enzymes and microorganisms involved in brewing, bakery, dairy, fortification, nutraceuticals (e.g. probiotic and symbiotic), supplements and pharmaceuticals and for other products of fermentation are likely to attract more concern over the composition of the culture media than of the genetics of the microorganisms themselves, enzymes, bacteria and fungi (moulds) are likely to feature in components escaping scrutiny if they are omitted, as processing aids, “live” or dead, from lists of ingredients.
9. Sugars are usually sweet. Sugar as a singular should not be used to describe sucrose: generically glucose, fructose, lactose, isomerose, maltose and maltodextrin are all sweetening sugars with significance in the food industry. They are also eligible for definition as polyhydric alcohols, a class that may include non-reducing sweetening components such as glycerol (glycerine), xylitol and sorbitol. Modern analytical methods can distinguish sources, e.g. “pure” sucrose obtained from cane (botanically a C4 plant) or from beet (a C3 plant), a significant difference to consumers informed by factors in world trade and economics, and wishing to avoid purchases of what they descry as unfair trading. Use of the word alcohol also needs clarification: the unqualified word usually applies to ethyl alcohol, which is of significance for abstainers and for followers of Islam (for whom even the alcohol used in the tinctures by which certain vitamins, flavourings and colourings are added to manufactured foods and beverages is objectionable). Manufacturers may avoid these complications by replacing ethyl alcohol (ethanol) for such purposes with a propanol or butanol. Encapsulating agents are also components of concern to customers with vegetarian principles.
10. In the UK fluoridation remains a contentious issue, contents of fluoride in tap water and local policies need disclosure in the appropriate media. However, water comes high in the lists of many ingredients without indication of the fluoride content. “Natural” or filtered waters may contain fluoride or be fortified. The final content in all the relevant foods and beverages should be declared.