"The general approach of the Commission to the interpretation and implementation of this legistlation should be to provide consumers with accurate information upon which they may make informed, individual choices," states the CHC response.
The comments from CHC focus on seven questions: What should be the upper safe limit for nutrients that have no scientifically established numerical tolerable intake levels? Is there a reason to impose maximum levels for vitamin and minerals that are well tolerated even at high intake levels? Should separate levels be set for dietary supplements and fortified foods?Where the Commission should look to find data on vitamin and mineral intakes in the EU. Can such data from certain Member States be used to set levels across Europe? Should different population groups (pregnant women, the elderly) be taken into account when setting the levels?How far should RDAs be taken into account when setting maximum vitamin and mineral levels?
Chris Whitehouse of lobby group The Whitehouse Consultancy called the response a "strong and well-argued submission that makes a cogent case for the defence of consumer choice in the interpretation and implementation of the Food Supplements Directive."
The CHC stated that they welcomed the recent comment from Commissioner Kyprianou who said that a main purpose of the legislation is to "provide a wide choice for consumers to supplement their diet"
In September 2005, the Food Standards Agency (FSA) set four principals that should form the basis of discussions over maximum levels: "Consumers should have the right to make an informed choice unless their safety is compromised; an evidence base is necessary to ensure consumer safety is safeguarded; there is a need for ongoing monitoring of supplements in the marketplace to continue to support the evidence base; the evidence base needs to take into account the risk assessment by scientific experts." CHC said that the original draft risked undermining these.
The FSA is only half-way through its own stakeholder consultation process, and has confirmed that the its second meeting with stakeholders on its draft response will be held of 4 September.
The agency spokesperson told NutraIngredients.com at the beginning of this month that: "The basis of the Agency's policy in relation to food supplements remains safety and consumer choice, and to seek a proportionate evidence-based approach to setting maximum levels of vitamins and minerals in food supplements."