New from July 2019: The MHD administration!

Today a piece appeared in the Newsletter of the Federal Office of Consumer Protection and Food Safety that I find rather remarkable... Original text below.

In fact, the LMIV and the Food Supplements Regulation precisely stipulate how a substance must be designated. See also our info page: https://www.energyvital.de/vit-min-erlaubte-stoffe

There is no such thing as "the vitamin C" or "the iron"; each vitamin or mineral, for example, must be added to a food supplement in a chemical form that enables the body to absorb the substance. There are better 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 relationship: expensive ingredients are very well absorbed, cheap ingredients are poorly absorbed or, for example, cause nausea after ingestion.

It is logical that manufacturers like to "cheat" here, i.e. prefer to write "Vitamin B12" in the ingredient list if only cheap cyanocobalamin is present. Or "Vitamin C" instead of ascorbic acid, because otherwise they would have to admit that they are using the cheapest chemical form of vitamin C instead of, for example, high-quality natural vitamin C from acerola.

As a professional, I always find it fascinating and entertaining when I research what particularly popular, very expensive supplements that customers buy consist of. Many will know this from magazines, tips from acquaintances or coach trips: completely overpriced products where the ingredient list (if one exists at all) contains, for example, only Vitamin C and Vitamin B12 instead of the actual designations.

I have hitherto classified this practice as fraudulent. Unfortunately, the Federal Office has now taught me otherwise... (or rather, worse...)

In my shop customers can be sure that ingredient lists are 1. as complete as possible and 2. I avoid this obfuscation 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-Chemical Experts of the Länder 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-Chemical Experts of the Länder and the Federal Office of Consumer Protection and Food Safety (ALS) publishes the technical statement decided at the 113th meeting held from 8–10 April 2019 in Hamburg:

Statement No. 2019/18:

Designation of vitamins

Facts/Question:

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

Is this requirement met by using the designation "Vitamin [...]"?

Decision:

According to Article 17(1) of Regulation (EU) No. 1169/2011 (LMIV), the "customary name" shall be considered the name of the food where a legally prescribed name is absent. This applies in the case of vitamins used as ingredients in the manufacture of foods.

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

The "customary name" is, pursuant to Article 2(2)(o) of the LMIV, a designation which consumers in the Member State where the food is sold accept as the name of that food without further explanation being necessary. The designation "VITAMIN [...]" fulfils this requirement.

Notwithstanding this, the specific designation of the vitamin compound is of course also an admissible indication in the ingredients list.

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