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Consultation - CODEX Recommendations on the Scientific Basis of Health Claims - 26/09/2003
 
VEGA responds with the vegetarian view
1. We foresee many difficulties with definitions of such words as foods, science, nutrition, and health and even the word claim, because allowance has to be made for consumers of different types and requirements. Concepts of science and nutrition are subject to changing interpretations and the document offers no indication of the arbitrating authority.

2. Increasing knowledge of genetic polymorphisms in human populations will complicate the relevance and importance of claims and descriptions. Emphasis on remedying dietary deficiencies is not redressed by warnings of excessive intakes of nutrients: for instance, claims of benefit for athletes must be tempered by warnings of risk to less active enthusiasts for healthy nutrition.

3. Control of sales of the specially designated foods should be exercised more in the manner of the distribution of pharmaceuticals, i.e. under some surveillance even with OTC sales, with staff supposedly adequately trained and supervised. However, trends in free trade and reduced nannying over the controls advertising and sale of drugs directly to the public and the workings of online purchasing throw much greater responsibility on the customer, well-informed or not, and on nutritional information services and consumer organisations to provide continuous freely-available commentaries.

4. The Draft Recommendations need much testing with working examples. We have some scientific experience because our dietary and health interests involve us in claims with a variety of the relevant foods and products, with a range beyond the requirements of vegetarians (which is itself a variously interpreted word, although tinged with allusions to a healthy lifestyle).

5. “Suitable” and “approved for” vegetarians could therefore be contented as descriptions pitched more persuasively than “acceptable for vegetarians”.

6. The statement “contains B vitamins. Suitable for vegetarians” seems to be making a health claim for a yeast extract ignoring the merits of a similar low-salt product. However, it can be argued – and is – that the dietary consumption of such yeast extracts contribute little to total intakes of sodium and the cultivation of a generally salty taste – and then an appreciable population may presume that they enjoy a genetic immunity to the risks that inform the FSA’s present teachings to the general public.

7. Current nutritional research is complicating definitions and interactions among vitamins, antioxidants, fats and constituents of proteins, for all of which claims may be made, modified, or recanted. It can’t be long before foods, nutraceuticals, or herbs can be found (or fortified) with natural statins. They would present selective indications of benefit for consumers of Afro-Caribbean or south Asian origins, but need warnings for populations of other genotypes for whom the biological effects were excessive.

8. Customers would be confused with descriptions of products bearing health claims while carrying alongside warnings on safety matters (e.g. deferring to sufferers with allergies). Similar clashes might arise with, for example, red wine and some cereals and derivatives (e.g. based on oats and quinoa) for which manufacturers unable to ensure the safety of their products to people with, say, wheat enteropathies (e.g. celiac disease), wish to protect themselves with (possibly exaggerated) warnings on contamination in factories and mills not regulated with the rigour required of pharmaceutical or electronic products. Some customers might object to health claims on commodities declaring a GM content.

9. We have evidence that some vegetarians’ diets in the EU and other prosperous countries deficient in the essential trace element iodine, therefore we are bound to alert the FSA and manufacturers and retailers to appropriate provisions, especially to women in their child-bearing years. Labelling and information in the composition-of-food tables (some of which we provided by agreement with the then MAFF) offer incomplete data, and consumers who resort to supplements may be relying on questionable results quoted on containers and packaging: analyses commissioned by MAFF, in collaboration with us, revealed some serious departures from the manufacturers’ information.

10. Promotion of seaweed offers an apparently “healthy” solution to this problem. Seaweeds could be included in various forms among the vaunted 5 (plus) fruit and veg, and many healthfood stores and some fishmongers are selling edible seaweeds in fresh and dry varieties. Some seaweed products (e.g. agar, alginates and carrageen) turn up as additives and processing aids, e.g in ice-creams and yoghurts with no declared iodine content (and similar uncertainties relate also to investigations on other essential elements, such as selenium).

11. Useful claims could be made for these marine products for their salutary dietary contributions, provided that analytical (rather than calculated) contents of iodine are declared and reservations are made in descriptive matter of the dangers of excessive intakes (e.g. to consumers of animal-derived foods – in which the content is mostly derived from fortified feeds – and of supplements as pills or tablets).

12. At the moment soya milks (although Euro-speak denies them that specific and obvious definition) are on sale boasting healthy claims and allusions, and they list potassium iodide among the list of ingredients; however, the amount is not given, nor is the customer offered any appropriate advice. We have obtained from the manufacturers the information that iodide content approximates to the level in comparable cow milks (however, this is seasonally variable). We are confused because the levels given in the information yielded to us puts the content several times lower and about the same as in human breast milk. We await information on iodide contents in other plant-derived dairy products.

13. We hope the foregoing illustrations exemplify the care needed in descriptions of foods making healthy claims – especially when assertions are made that “there are no unhealthy foods, only unhealthy diets”. Customers need comprehensive, independently-vetted information on labels, in packaging and on websites or dossiers in-store. Unfortunately, this will entail an unhealthy increase in packaging material and costs of surveillance.

14. In the interests of objectivity in what is becoming an increasingly controversial subject a Welfare Warning is apt. Such as obligatory statement would be of the type “Justification of the health claims for this product entail testing on live animals”, unless the food can lay claim to be cruelty-free, at least in this regard.


Yours truly,

Dr. Alan Long
VEGA Research
 
 
 

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