EHPM welcomes the interest of the Portuguese Presidency of the Council of the European Union in the European food supplement regulatory framework.

EHPM would like to highlight that the EU applies one of the highest food safety standards in the world – largely thanks to the solid set of EU legislation in place, which ensures that food should be safe for consumers. Food supplements in order to be placed on the market, need to comply with a strict set of rules on manufacturing, labeling, communication etc. These rules are thorough and define all the necessary components from product definition and scope, to contaminants and communication of health effects to consumers. At the same time the sector has adopted soft tools to reinforce quality, by adhering to the rules of the EHPM Quality Guide (eds 2007, 2014).

The European regulatory framework for food supplements is solid and efficient for guaranteeing safety, quality and efficacy.

As with all EU regulations in place, specifics areas of the Food Supplements regulations could be updated in order to optimise the legal provisions in place and contribute to the monitoring of the sector in a pan- European scale.

EHPM has identified key areas of regulatory optimisation, alongside which is the lack of harmonisation in some areas of food supplement regulation. Together with national and European regulators the EHPM is working towards targeted proposals that satisfy all three major criteria, that of safety, quality and efficacy. In this framework, EHPM launched in January 2021 its proposal for the assessment of health claims on Botanical Food Supplements in the EU: the so-called “Graded Approach”. EHPM is also working at the third edition of its quality guide in order to take into account developments in manufacturing processes and latest best practices. At the same time, EHPM is working on a self-regulating nutrivigilance protocol that has already raised interest among many national associations and companies. Also, EHPM is updating its model on maximum levels for vitamins and minerals that will be published soon.

EHPM has been engaging with European and national authorities for decades to find applicable and fair solutions to the regulatory challenges faced by the sector and affecting food business operators, in particular in the possibility to innovate and fairly compete within the EU Single Market.

However, EHPM regrets that stakeholders representing industry – national and European associations representing the sector – and consumers’ associations were not consulted ahead and were not put in the position to concretely contribute with their direct experience to the drafting of the Report presented by the Portuguese Presidency on the 23rd of June 2021. In fact, national and European associations representing the food supplement sector would have been glad to proactively and concretely contribute to this work. EHPM firmly believes that a constructive dialogue between decision-makers and stakeholders representing industry and consumers is essential in order to allow the regulatory framework to evolve.

Moreover, we would like to remind the important role food supplements play in the betterment of citizens’ health and the benefits that an informed usage generates.

Food supplements, alongside a balanced diet and a plan of exercise, play a significant role in maintaining the normal state of homeostasis in the body. While food supplements are not meant to prevent or treat any disease, the ingredients of food supplements have science based properties which could contribute to reducing certain risk factors associated with disease, as it is the case of DHA, EPA, Folic acid, Vitamin D etc.

As such, food supplements, together with a healthy lifestyle, contribute to the improvement of citizens’ health and wellbeing, and to the reduction of the financial burden of healthcare systems on Member States. The reduction of diet-related risk factors for several diseases is a sustainable option, which serves the needs of the EU population first and foremost. This is particularly important in the EU, as an increasing 20 percent of the population is aged 65+.

EHPM reiterates its call to European and national authorities to engage in a constructive dialogue with stakeholders, in order to work together for the development of fair and efficient EU framework, to avoid any unilateral national initiative which would generate inequalities between companies and would jeopardise the free movement of goods in Europe. Such framework should prioritise safety, high quality standards and truthful information to consumers that will allow them to make informed choices.