Position Paper
FIBRE
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
May 5, 2005
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 III).Our
comments pertain only to the section on the definition of dietary
fiber and the use of this definition. We will wait until the definition
the definition is finalized before providing our comments on nutrient
content claims for fiber.
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.
Definition of dietary fiber
ICGMA supports a definition of fiber that characterizes dietary
fiber as “a degree of polymerization (DP) of 3 or higher.”
The AOAC definition and the Institute of Medicine (IOM) Macronutrient
Report classified non-digestible carbohydrates with DP of 3 or more
as fiber. The definition in the Life Science Research Office (LSRO
1987) did not exclude these shorter polymers. ICGMA agrees that
it will be necessary to enhance the dietary fiber analysis methods
to incorporate the definition of fiber that characterizes dietary
fiber as a degree of DP of 3 or higher.
ICGMA supports a definition of fiber that is obtained from food
raw material. ICGMA believes we should not exclude fiber from animal
origin because animal fibers such as chitin or chitosan are non
digestible carbohydrates that have been shown to have physiological
benefits on blood lipids in clinical studies.
RECOMMENDATIONS TO CODEX COMMITTEES USING THIS DEFINITION
OF DIETARY FIBERS
Under the fourth bullet point:
ICGMA believes the Committee should provide guidance on the criteria
to quantify physiological effects rather than leave it to national
authorities. The fourth bullet point reads as follows:
- “With the exception of non-digestible edible carbohydrate
polymers naturally occurring in foods as consumed, where a declaration
or claim is made with respect to dietary fiber, the physiological
effect must be scientifically demonstrated by clinical studies
and other studies as appropriate. The establishment of criteria
to quantify physiological effects is left to national authorities.”
ICGMA encourages the CCNFSDU Committee to develop the criteria
to quantify the physiological effects. The Committee should establish
reasonable scientific evidence of efficacy as a basis for fortificant
fibers to be declared as dietary fiber.
ICGMA appreciates the opportunity to provide these comments to
Codex. Please contact me at (202) 337-9400 should you have questions.
Sincerely,
Mónica González, M.S.
cc: Codex Alimentarius Commission, Rome, Italy
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