Comments and Correspondence
ICGMA COMMENTS ON CODEX PROPOSED HEALTH CLAIMS RECOMMENDATIONS
Dr. Rolf Grossklaus
Chairman of the Codex Committee on Nutrition
and Foods for Special Dietary Uses
Bundesinstitut für Risikobewertung (BfR)
P.O. Box 33 00 1314191
Berlin, Germany
Dear Dr. Grossklaus:
The International Council of Grocery Manufacturers Associations
(ICGMA) is pleased to provide input on the “Proposed Draft
Recommendations on the Scientific Basis of Health Claims"
at Step 3 of the procedure.
ICGMA, a recognized INGO before the Codex Alimentarius Commission,
represents the interests of national and regional associations who
collaborate with all sectors of the consumer packaged goods industry.
ICGMA promotes the harmonization of scientific standards and policies
concerned with health, safety, packaging, and labeling of foods,
beverages, and other consumer packaged goods. ICGMA also works to
facilitate international trade in these sectors by elimination or
preventing artificial barriers to trade.
Preamble
The Codex General Guidelines On Claims (CAC/GL 1-1979 (Rev. 1-1991)
does not contain a statement that "health claims should be
forbidden if they cannot be justified." ICGMA does not believe
this statement is necessary, as the first statement already states
that no food should be described or presented in a manner that is
false, misleading or deceptive.
ICGMA believes the reference to national health policy is beyond
the scope this document and should be deleted. This document is
to be recommendations for the scientific basis of health claims,
and should not reference where it might be practiced or enforced.
2.1 Identification and stability of the food, the substance
or the ingredient
The reference to validated analytical methods is a regulatory (enforcement)
issue; it is included in the Draft Guidelines for Use of Nutrition
and Health Claims (Sec 7.3), and should be deleted from this document.
A new evaluation should not be necessary if the claim characterizes
the food or ingredient, unless the food is a different product from
the regulatory perspective.
Section 2.2 Safety of the product
As stated in the preamble of the Proposed Draft, other provisions
are relevant to food safety. ICGMA suggests that this Section be
deleted. The contents of this section are about safety assessment,
which, as stated, is the subject of different provisions.
Section 3.1 General Requirements
Delete the word "alleged" (alleged claim) from the second
para of this section.
Section 3.2 Nature of the Scientific Evidence on the Claimed
Effect
ICGMA suggests that the paras with criteria for toxicological effects
and consumption data for adverse effects are references to safety
assessments, which should not be included in this document. As stated
above, these are food safety issues and would be included in other
provisions.
Change "alleged effect" to "proposed benefit that
is the subject of the health claim" in the penultimate bullet
point in this section.
Section 3.3 Relevance of the Evidence at Population Level
ICGMA does not understand the need for this section and suggest
that it be deleted.
Section 4 Evaluation of the Scientific Proofs Used to Justify
a Claim
Qualified experts are experts that are qualified by scientific
training and experience; they do not all have to be government experts.
All the available scientific data should be taken into account;
however, if there is a credible body of scientific data, and the
weight of the scientific evidence in support of the claim outweighs
the scientific evidence against the claim, the claim should be permitted.
The nature and specificity of the claim must match the quality
and quantity of the supporting scientific evidence.
Section 5 Periodic Re-Evaluation
Health claims should be reevaluated only if significant new findings
have been published that directly impact the underlying science
of the nutrient effect relationship. Companies should not be required
to continue to conduct studies on a claim that has already met the
scientific criteria to make a claim.
Monitoring consumption levels and patterns should not be required
because this issue would have been addressed in the safety evaluation.
ICGMA appreciates the opportunity to submit these comments.
Respectively yours,
Mari Stull
Executive Secretary
International Council Grocery Manufacturers Associations
cc: Secretary, Codex Alimentarius Commission,
Joint WHO/FAO Food Standards Programme,
FAO,
Viale delle Terme di Caracalla, 00100
Rome, Italy
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