VEGA comments on an FSA Consultation on nutritional labelling.
VEGA comments on an FSA Consultation on nutritional labelling, available from the FSA website.
Discussion Paper from the Commission on the Revision of Technical Issues relating to the Nutrition Labelling for Foodstuffs Directive 90/496/EEC
1. Inadequate use is being made of IT to complement information on labels and in claims and advertisements. Customers in any but the smallest stores must be able to reach such information on site or, if ordering goods from home, from a standard computer. Exemptions would have to be made for foodstuffs sold fresh (and unwrapped) from farmers’ markets or small shops and any detailed data should allow for the considerable variations expected, according to type of crop and method and time of harvesting. Variations in true health foods would be much bigger than in manufactured products sold in substantial packaging.
2. Warnings, especially on supplements, should indicate the risks of exceeding maximum intakes. Regular consumption of seaweeds, taken with supplements, as part of corrections of hypothyroidism could lead to thyroid problems, for instance. Manufacturers can’t resist “super” versions of old favorites, such as kelp tablets, which may be augmented now with sources of iron and calcium, which are unnecessary and may even be harmful.
3. Speciation, interactions, and consequent changes in bioavailability must be allowed for. Enthusiastic adoption of exhortations of intakes of fruit and veg could raise absorption of dietary iron to adequate or even excessive levels. Examples of speciation of possible nutritional significance, especially in fortified foods and supplements, are elements existing in a variety of valency states or coordination and exemplifying such caution are selenium, iron, chromium, calcium and zinc, and organic substances such as vitamins D and E (D2 and D3 should always be specified to satisfy most consumers’ interests). Some possible confusions need to be anticipated: for instance, some “natural”, “health foods”, such as seaweeds and fish, may contain quite high contents of arsenic in an apparently harmless form as a betaine or glycoside (however, this benign modification may become harmful as a result of processing, eg for powdered kelp, and the details may be lost when the results of combustion analyses are assessed. Likewise, analyses of, say, seaweeds for iodine content fail to prove the biological action of such dietary components on thyroid function: the iodine in the plants may be in an inorganic or organic form – in chemical terms – or partition as essentially fat- or water-soluble. Analyses of iodine in milk attract similar reservations: the biological activity may be due to organic compounds of the thyronine-type and bound to proteins).
4. Supplements in particular should move out of a grey area of control into the stricter stipulations applicable to over-the counter (OTC) pharmaceuticals. Customers must be able to find out the provenance of the main biologically active substances and the materials used as processing aids and in formulations. Some of these issues apply also to nutrients added to foods. These considerations apply particularly to products suitable for people with specific aversions on grounds of religion, ethnicity, or of animal welfare and environmental concern or on diets restricted for other reasons, eg metabolic disorders, intolerances or allergies. Components of manufactured foods will fall increasingly into analytical practicability as equipment for gas chromatography, mass spectroscopy, isotopic differentiation, and immunology becomes accessible and cheap. Sharpened analytical tests should prompt manufacturers into greater enterprise to satisfy consumers’ demands: for instance, a Muslim or vegetarian woman is unlikely to find an OTC (or prescription) calcium-and-vitamin D preparation (eg in the treatment of bone disorders and dietary and lifestyle inadequacies) consumption of which does not violate her principles. Such difficulties are common too in supplements, prescription drugs in which gelatine, lactose, shellac, and coal-tar dyes are used in the formulations and lactulose, are among the active principles. Such difficulties and objections may compromise essential therapy.
5. Controls on the sales of dietary supplements should merge with those applying to OTC pharmaceuticals such as aspirin, paracetamol, ibuprofen, and statins. Mass medication implies elevation of such medications to vitamin status for some human populations. “Biologics” such as fish oils and alternatives and their components such as DHA, EPA, ARA, CLAs, as well as foods fortified with them, present such challenges and have long attracted attention as sources of vitamins D and F. Consumers and controlling bodies must have the means to trace sources of such materials via licensed manufacturers operating competent procedures and quality controls and ability to substantiate claims up to standards required for pharmacopeias or better. Such stipulations must apply consistently to veterinary feedstuffs for pets and non-human animals; and they would require rigor in definitions, eg in speciations (D2 or D3 for vitamin D and allowance for isomeric and other chemical descriptions eg for vitamin K, tocopherols, lactic acid, and sugars). Manufacturers of foods and supplements, as well as prescribing physicians, should ensure that consumers are warned that certain drugs (eg amiodarone and X-ray contrast agents) and ingredients and processing agents in common foodstuffs (eg colorings such as erythrosine and texturing compounds such as alginates, agar, and carrageenan) and residues from supplemented feedstuffs and disinfectants may be contributing substantially in “ordinary” diets to their iodine content.
6. Special dietary needs have to be anticipated, going beyond the detailed recommendations officially offered for growing children and babes, breast fed or not. The elderly need special advice, eg on blood variables, and women of child-bearing age and also post-menopausal, as well as at various stages of adolescence, pregnancy and lactation, should be interpreting factors in their diets that may not be revealed in clinical testing, screening programs, or involvement in epidemiological studies. Increasing availability of diagnostics and tests that can be done non-invasively and at home or through pharmacies or by post – as well as mechanical devices for such measurements – will stimulate the demand for published (eg by labelling and on official websites) information relevant to their condition. Genetic characteristics must also be accommodated, as well as the effects of treatments with drugs and therapies involving non-officinal agents such as herbs. Evidence may emerge justifying warnings on, say, cruciferous vegetables of contents of sulphur-rich components with goitrogenic potential; and more knowledge on competitive biochemistries may require declarations of sulphur-selenium ratios.
7. For some groups on diets restricted for various established reasons certain dietary factors may be elevated to vitamin status. For vegetarians, for instance, taurine, carnitine, creatine, and certain long chain PUFAs may fall into this category and, as “health foods for athletes” show, they can attract many claims for supplementary dietary ingredients. Interpretations over salt (sodium) intakes need special attention for “high sweat” activities and for general purposes sodium / potassium ratios might be better for labelling in manifestations of observance of official pronouncements on fruit, vegetables, and salt. Declarations on folate contents and additions must be balanced by assurances that an untoward imbalance with vitamin B12 is not developed.
8. The list of minerals in the present list might be extended to silicon and boron, even if their dietary significance is limited at present. Supplements especially and foods generally should bear statements on contents or declarations of negligible risk of elements such as aluminium, lead, and cadmium, and goods made with water as an ingredient should show the fluoride content. Recent instances of the dairy cows’ curiosity in littered pastures and premises for dumped sources of potentially toxic substances (eg tire-wire disease) require manifest assurances that these threats are dealt with at source and confirmed, batchwise, for residues of “heavy metals” and other likely toxic and anti-nutritional substances in meat, milk, eggs and fish and their derivatives.
9. We agree with all efforts at standardizing methods of analysis, with the precedence of FAPAS procedures. Phosphorus should be spelt so in the documents you’ve provided (phosphorous has a special meaning outside the relevant chemistry). Sulfur (and derivative words) is now the internationally accepted spelling – but not fosforus. Aluminium (not aluminium) has been agreed likewise. A case may be made for declarations of GI (glycemic index) on foodstuffs.
10. Increased labelling on foods will produce more sub-divisions of major categories: thus fats are itemized and already disclosures on contents of trans (hydrogenated) components are sought. Further itemization may be necessary to give information on specific amino acids in proteins. Consumers interested in origin and provenance will be seeking derivations on an animal/vegetable/mineral basis; accordingly, proteins, fat, and energy values can be so differentiated on an animal or plant source by application of mass spectrometry and other physical means of differentiating isotope ratios, particularly of atoms of low atomic weight.