Consultation on a proposal for a regulation of the European Parliament and of the council on nutrition and health claims made on foods
1. We have had much experience since the 1960s in dealing with manufacturers, retailers and government departments on the labelling on and claims for foods and household goods. Although we represent a vegetarian constituency, our surveillance is of use to a wider population of consumers on restricted diets and with varied aversions, among whom we count especially meat- and fish-reducers and dairy frees. These are customers devoting above-average attention to information, claims, labelling and warnings offered (or not) on comestibles of all types.
2. Control must therefore require scrutiny from all points of view, some being of much significance to the affected few while of little importance to the many. Objective nutritional information and warnings must always receive more prominence than health claims. Correspondingly, the FSA and Depts. Of Health, Education, and Trade, as well as DEFRA, must accommodate these requirements, and school syllabuses must include interpretation of information on food among the skills taught in the practice of citizenship.
3. These stipulations apply with special force for commodities sold as nutraceuticals or functional foods, for which the products should be sold with instructions in the manner of the information required on pharmaceuticals.
4. Sponsorships and approvals, many suspect as ill-advised essays in "selling the symbol" or "leasing the logo", can be vexatious and dubious. Vegetarians are ill-served by statements that foods and goods are "suitable for vegetarians", as the public are interpreting this description in an ill-defined way, and with increasing rigour from fishytarians, cheesytarians, and egg-abstainers to full-blooded vegetarians (or vegans).
5. We are concerned that customers become fed with overreaching "illusions", e.g. believing that RSPCA Freedom Foods are organic and "healthy" and that approved vegetarian products must likewise qualify for distinction and be GM-free. Vegetarians lose trust in a system in which "vitamin D" may be D3, not D2, lactates and stearates may or may not be of animal origin, and ingredients, such as vitamin B2 or citric acid and processing aids, may be in a GM category or otherwise objectionable (e.g. formulated as gelatin-coated beadlets).
6. These misgivings may result in some customers practising their own precautionary principles in aversions to otherwise desirable fortified foods or nutraceuticals. Such denials are common for populations with allergies or intolerances to nuts or dairy products or for celiacs able to consume, say, oats from dedicated mills and factories; for vegetarians acceptability of B vitamins and vitamins D and K and of iodine and selenium must not be compromised by doubts over declarations on manufactured foods of nutrient contents.
7. Correspondingly, retailers must ensure that they are selling foods and ingredients that can be traced to source and authenticated. Vegetarians look at the folate situation differently from most of the British population: vegetarians are less likely to need fortification with folate but more in need of balancing additions of vitamin B12 and other B vitamins. Some of these adjuncts pass through the hands of brokers in international markets. We have lost the trail at the moment to the sources of vitamin B12 (cyano- or hydroxocobalamin) and thus to indications of potency - or even of any biological activity.
8. These considerations also inform our efforts at increasing the availability of low-salt yeast extracts, now topical in the light of FSA earnests to reduce or redress dietary sodium-potassium ratios. Marmite soldiers are a useful item for children and are promoted for vegetarians; however, Marmite and supermarket own-brand equivalents are very salty and generate the taste, even if they may claim that they contribute little in modest usage to the total dietary load of sodium. The dominance and claims for the major products disadvantage the salutary contribution the less accessible and less advertised low-salt versions may make. Further, our efforts at traceability indicate that some supposedly yeast extracts are in fact undistinguished "vegetable hydrolysates", one of which - surprisingly - is imported from Italy.
9. Soup cubes are another expensive way of buying salt and have been subject in our ASSALT course. Labelling must ensure on products such as this that the contents of nutrients and additives when the product has been diluted and prepared are declared. Data cited for nutrient contents should be declared as results of typical analyses or as calculations (e.g. from tabulations of the composition of foods). High accuracy and consistency cannot be expected for seasonal fresh crops (e.g. fruit and vegetables) and for products of various systems of husbandry (e.g. organic, GM etc.), and notes on labels must be included to warn customers of these variations.
10. Nutritional data should also include notes on the speciation of some elements and on the bioavailability and interactions, e.g. of iron, calcium and zinc and fibre. These precautions apply for fortifications of B vitamins and the differing significances for women of childbearing age and for the elderly. Fortification with vitamins D need similar attention.
11. Recent results in our long-term efforts at ensuring iodine status in European diets, especially for vegetarians, reveal persistent confusions among nutritionists, doctors, manufacturers, and food technologists and authorities. We try to avert severe consequences of deficiency for pregnant women and their offspring and of possibly dangerous excesses for consumers of some supplements. The delusion of safety in iodised salt persists and is deceptive for various reasons: hardly any salt used in Britain in the home, in catering, or in manufactured foods is iodised (although the practice is common in many European countries). Advocacy of salt as a vehicle for the essential nutrient iodine is unlikely to receive much favour; however, appropriate labelling is necessary. (See information on our website)
12. Dairy products, reflecting fortifications of animal feeds and residues of disinfectants, provide much of the iodide in British diets, with significant seasonal variation. As a result of our persuasions manufacturers of non-dairy alternatives are including potassium iodide in the ingredients of some of their products, but with no indication of the quantity (it would amount to the equivalent found in breast milk, i.e. much lower than in cow milk).
13. Some foods, including non-dairy yoghurts and ready-made custards are thickened with additives such as agar, alginates and carrageen which, as seaweed derivatives, are rich in available iodine (we have provided the results published in the HMSO Composition of Food Tables of analyses we had commissioned). This contribution has been overlooked by manufacturers, from whom we are awaiting information we are unable to deduce from the sparse data on labels. Strawberry- and raspberry-flavoured products may also be coloured with the iodine-containing dye erythrosine. Such omissions must be remedied in more rigorous surveillance of nutritional data easily available to consumers taking salutary dietary measures.
14. Seaweed, sold dried or fresh, is another source of dietary iodide, but without appropriate declarations to avoid thyrotoxicosis from excessive consumption.
15. Fluoride is another halide attracting controversy - as now - for which the concerned customer as well as the epidemiologist is bereft of information on labels. Beverages, brewed and non-brewed, and fruit juices reconstituted from concentrates are among many products that may add fluoride to diets from sources other than the local tap water or from bottled waters. Labels must carry relevant declarations.
16. Dominant and heavily-subsidised elements of the food industry can afford to sponsor research with the likelihood of providing them with grounds for authorised and prominently-advertised claims beyond the resources of other interests to establish similar emphasis for their virtues. The commercial research in the interests of the live/deadstock industry belittles the endeavours of, say, the producers and merchants of fruit and vegetable products, as well as of specialised foods, with similar merits but unsung. Claims for dietary calcium in milk have been overdone in a mass effect of this type. Balance must also be struck with imposed warnings, as well as ungoverned acclamation. The need for precautions in handling raw poultry must be accompanied by official warnings on labels that such products are likely carriers of zoonotic disease. Claims and advice on labels must also be prepared for genetic polymorphisms among the population that surpass the prevalence of the specific allergies presently recognised, probably excessively.
17. In claims over dietary fats conjugated linoleic acids (CLAs) may feature in an unbalanced way. Some of these acclaimed factors may contain trans-double bonds.
18.We have repeatedly urged that modern IT allows consumers, whether in-store or at home, opportunities for much more than is disclosed in the space on labels. Manufacturers must be forced into more openness by recourse to these means.
19. Pet foods are a large part of the food industry. Sales of these products by major retailers and by vets cover a wide range accompanied by many health claims of types familiar for foods for human consumption (although it is not unknown for them to be eaten by people). Claims, nutritional assessments (adjusted for species differences) and advertising must be surveyed and controlled. The FSA seems the most suitable agency for this wider function, especially as many pets are given more than crumbs from the table and suffer from allergies and intolerances familiar to their providers.
Dr. Alan Long