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Nutrition and Food Marketing - Consultation comments - 22/12/2006
 
FSA consultation The Notification and Marketing of Food for Particular Nutritional Uses
FSA consultation The Notification and Marketing of Food for Particular Nutritional Uses.


1. Trends in the food market, nutrigenomics, and metabolomics are blurring definitions of commodities intended for general or particular use and presented as functional foods or specifically fortified products. Treatments with drugs, complemented by dietary regiment and aversions for the various reasons of perceived idiosyncratic allergy and intolerance, will increase opportunities for particular nutritional uses.

2. Many of these opportunities will be met by replacements and substitutions with look-alike, cook-alike, and eat-alike properties, for which labelling and warnings will require special attention and control. The aversions may be based on firmly-attested clinical grounds implying acute sensitivity in the consumer’s intakes to rarer and little understood origins associated with religious and “ethical” restrictions entailing severe abstentions and frugality, especially when in combination and rigor to what may be classified as extreme and calling for polypill vitamin and mineral supplementation if adequate nutrition may be assured; or parnuts of suitable variants of products such as Complan may be valuable.

3. Some special groups in these categories requiring special attention would include:

a. Consumers of South Asian descent and Caribbean origin with a special tendency to metabolic syndrome and its consequences, for which dietary and bodyweight control are especially important. They are part of a large population of abstainers heeding the vigorous warnings of the Food Standards Agency enjoining prudent dietary and lifestyle reform.

b. Patients diagnosed as suffering from familial hypercholesterolemia or with other risks such as apoE4 genetics.

c. Sufferers from well-attested enteropathies associated with certain cereal proteins and milk sugar (lactose) and proteins.

d. Consumers undergoing growth spurts or disturbances and personality problems problems prompting restrictions such as anorexia, bulimia, and pica that result in irreversible harm and impaired catch up. Such populations would include adolescents and pregnant mothers and their offspring (as in DOHAD, Developmental Origins of Human Adult Diseases). Remedial nutritional adjustments must take account of age and gender and the speciation of particular nutrients: the fortification (as “mass medication”) of common foods such as flour with folate (with or without vitamin B12) illustrates nicely a challenge the FSA is facing at the moment.

e. Populations trending in a vegetarian fashion – as meat-reducers and dairy-free – to dietaries and abstentions in tune with the general wellbeing of the environment and of all its inhabitants. Such observances would comprehend the extremes of veganism, raw food regimens, macrobiotics, and Rastafarianism. Instances of such ill-advised extremes may result in court orders to take babies from their parents owing to malnutrition of the baby and prosecutions of the parents (Munchhausen by proxy).

4. We can cite an example presented to the FSA in another context of a parnuts introduction that infringed prudent marketing practice. A collection of alternative cheeses, imitating various common varieties, unmistakably presented customers with choices comparing well against the original products in categorizations of foodstuffs according to the FSA’s current traffic-light system. They are also distinguished with the international vegetarian seedling symbol in various modifications and with approvals and approbations by the British Vegetarian and Vegan Societies. However, their (plant) protein contents are considerably lower than those of the familiar dairy-based products; unwary dairy-free families could therefore suffer nutritional harm by the substitution and all parties would benefit it the Agency was allowed “to restrict trade in foods for particular nutritional uses, which endanger human health”. Such enforcement should prompt commercial enterprise in improved products fit for purpose and informatively labelled. It is an instructive example.

5. National initiatives at curtailing the prevalence of obesity and the serious consequences of ill-judged food consumption and bodily conformation and scoring could well extend to labelling on commodities other than food, specifically outsize clothing, say: advice could be sown into male waistbands on trousers etc for over 40-inch (100cm) girth and corresponding measurements could be applied for women’s wear.
 
 
 

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