New from July 2019: The MHD administration!

Today an article appeared in the newsletter of the Federal Office of Consumer Protection and Food Safety which I consider to be quite memorable... See original text below.

The LMIV and the Food Supplements Ordinance actually regulate exactly how a substance must be labelled. See also our info page: https://www.energyvital.de/vit-min-erlaubte-stoffe

There is no such thing as "vitamin C" or "iron", but every vitamin or mineral must be added to a food supplement, for example, in a chemical form that enables the body to absorb the substance. There are good and less good compounds, both in terms of absorption and tolerability in the gastrointestinal tract.
See also our blog post: The quality of food supplements.

There is often a direct cost/benefit correlation: expensive ingredients are very well absorbed, cheap ingredients are poorly absorbed or cause nausea after ingestion, for example.

It is logical that manufacturers like to "cheat" here, so they prefer to write "vitamin B12" in the list of ingredients if it only contains cheap cyanocobalamin. Or "vitamin C" instead of ascorbic acid, as otherwise you would have to admit that you are using the cheapest chemical form of vitamin C instead of, for example, high-quality natural vitamin C from acerola.

For me as an expert, it is always exciting and entertaining when I research what very expensive food supplements that are particularly popular with customers consist of. Many people will be familiar with this from magazines, tips from friends or coffee trips: completely overpriced products where the list of ingredients (if there is one at all) only contains, for example, vitamin C and vitamin B12 instead of the actual names.

I have previously categorised this practice as fraudulent. Unfortunately, the Federal Office has now taught me better... (or worse...)

In my shop, customers can be sure that the lists of ingredients are 1. as complete as possible and 2. that I avoid this concealment as much as possible!

Appendix

Published in the Journal of Consumer Protection and Food Safety

J Consum Prot Food Saf (2019). https://doi.org/10.1007/s00003-019-01252-2
https://link.springer.com/article/10.1007/s00003-019-01252-2

Statement of the Working Group of Food Chemistry Experts of the Federal States and the Federal Office of Consumer Protection and Food Safety (ALS)

On the basis of § 8 No. 6 of the Rules of Procedure, the Working Group of Food Chemistry Experts of the Federal States and the Federal Office of Consumer Protection and Food Safety (ALS) publishes the technical statement adopted at the 113th meeting in Hamburg from 8 to 10 April 2019:

Statement No. 2019/18:

Labelling of vitamins

Facts/question:

According to Art. 18 Para. 2 of Regulation (EU) No. 1169/2011 (FIR), the ingredients of a food must be indicated in the list of ingredients with their specific designation in accordance with Art. 17 Para. 1 FIR.

Is this requirement fulfilled by the use of the designation "Vitamin [...]"?

Decision:

According to Art. 17 para. 1 of Regulation (EU) No. 1169/2011 (LMIV), the "common name" is deemed to be the name of the food if a legally prescribed name is missing. This applies in the case of vitamins that are used as an ingredient in the production of food.

The working group does not regard the names for vitamins listed in Annex II of Regulation (EC) No. 1925/2006 as legally prescribed but as possible names.

According to Article 2(2)(o) of the FIR, the "common name" is a name that is accepted by consumers in the Member State in which the food is sold as the name of that food without the need for further explanation. The designation "VITAMIN [...]" fulfils this requirement.

Irrespective of this, the specific name of the vitamin compound is of course also a permissible indication in the list of ingredients.

This Opinion (No. 2019/18) replaces Opinion No. 2014/42.