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Comments and Correspondence
ICGMA COMMENTS ON FIBER

Dr. Rolf Grossklaus
Chairman of the Codex Committee on Nutrition and Foods for Special Dietary Uses
Bundesinstitut Fur Risikobewertung (bfR)
P.O. Box 33 00 1314191
Berlin, Germany

October 26th, 2004

Dear Dr. Grossklaus:

The International Council of Grocery Manufacturers Associations (ICGMA) is pleased to provide input on 1) the Guidelines for the Use of Nutrition Claims: Draft Table of Conditions for Nutrient Contents (Part B) Dietary Fibre (ALINORM 04/27/26, Appendix II), and 2) the Proposals for a Definition and Methods of Analysis for Dietary Fibre Content (CX/NFSDU 04/3-Add.1).

ICGMA, a recognized NGO 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.

ICGMA urges the Codex Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU) to adopt both a definition for dietary fibre and the conditions for dietary fibre content claims “source” and “high”.

1. Table of Conditions for Dietary Fibre Content Claims

ICGMA supports the removal of the square brackets surrounding “Dietary Fibre”.

ICGMA does not support the proposed definitions for the levels of fibre for “source” and “high” as found in the Table of Conditions for Dietary Fibre Content Claims. ICGMA proposes the level for fibre for “source” should be not less than 2.5 g per 100 g or 2.5 g per serving. ICGMA proposes the level of fibre for “high” should not be less than 5 g per 100 g or 5 g per serving.

2. Proposals for a Definition of Dietary Fibre and Methods of Analysis for Dietary Fibre Content

ICGMA is in support of the proposals for a definition and methods of analysis for dietary fibre as prepared by a drafting group led by France and Sweden. The definition as proposed recognizes a continuum of carbohydrate and allows for flexibility to incorporate new fiber sources developed in the future. They may include synthetic fibers i.e., polydextrose or natural fibers i.e., inulin following demonstration of beneficial physiological effects in humans.

ICGMA urges the CCNFSDU to pursue a definition that will promote harmonization of scientific standards and policies concerned with health and labeling of foods and beverages. ICGMA urges CCNFSDU to facilitate international trade in the food and beverage sector by eliminating or preventing artificial barriers to trade with our global partners through adoption of an accurate scientific definition that can be consistently implemented worldwide.

ICGMA appreciates the opportunity to provide these comments to Codex. Please contact me at (202) 337-9400 should you have questions.

Sincerely,


Alison J. Kretser

cc: Codex Alimentarius Commission, Rome, Italy