Biopolymer International
The mission of the association is to protect and promote fair world-wide trade and use of biopolymers that are safe and produced according Good Manufacturing Practices and applicable legislation in different regions of the world where they are manufactured and sold for use in foods, pharmaceuticals, cosmetics, animal feed and other industrial applications.
ID: 93533519997-62
Lobbying Activity
Response to Amendment of the list of products and substances authorised in organic production
17 Nov 2022
On behalf of Biopolymer International, please find attached comments in response to this public consultation
Read full responseResponse to Agriculture - List of products and substances authorised in organic production
22 Apr 2021
Biopolymer International, the association that represents the manufacturers of xanthan gum and gellan gum, wishes to comment on the provision according to which gellan gum must be from organic production, in Annex V – Part A – Section A1 - Food additives including carriers.
Our members can adapt their manufacturing processes to the organic requirements but cannot have access to key agricultural raw materials in organic form.
More precisely, gellan gum is produced by fermentation. Glucose syrup, the carbohydrate source used for the production of gellan gum, is not available in the EU in a quality that could be used in organic production, based on the current applicable EU regime.
The purification treatment that glucose syrups undergo is Ion Exchange and Absorption Technology (‘IEX’) which is incompatible with organic production under the new organic regulation. IEX is essential to remove processing aids and unwanted substances and does not generate any chemical change in the products on which it is used.
Additionally, there is difficulty sourcing materials in organic form that match the quality and functionality of their conventionally produced forms.
As a consequence, Biopolymer International wishes the specific provision “only from organic production” to be lifted for gellan gum.
If this provision is maintained, there will most certainly be a disruption to the organic supply in the EU, especially since gellan gum is vital in certain organic products such as beverages. Therefore, Biopolymer International would strongly suggest an extension of the implementation by i.e., two years.
We thank you for considering our request.
Biopolymer International.
Read full response2 Nov 2020
Biopolymer Int. is the association of world-wide manufacturers of xanthan gum and gellan gum. Xanthan gum (E 415) and gellan gum (E 418) are food additives that were subject to EFSA’s re-evaluation, as provided in Article 32 of Regulation 1333/2008 .
As a member of EU Specialty Food Ingredients, Biopolymer Int. fully supports the federation’s comments on this draft implementing act.
Our association values the purpose of Regulation 2019/1381, which notably aims at restoring the consumers’ trust in the EU food regulatory system and in in fine food additives like xanthan and gellan gums. Based on our experience with the re-evaluation process, we would like to share our comments on the following elements:
- Recital 2 of the draft implementing Regulation: From a legal standpoint, Regulation 2019/1381 only brings in amendments to Regulation 1331/2008 with regard to applications for approval of food additive, not to the Regulation 257/2010 setting up re-evaluation programme. In our view, an amendment to Regulation 2019/1381 would be required before this implementing act could be enacted.
- Article 1 of the draft implementing Regulation inserting new Article 7c – paragraph 1 into Regulation 257/2010: We understand that this Article reflects Article 32b of the General Food Law as revised by Regulation 2019/1381. However, if the responsibility to notify a study lies with the interested business operator AND the laboratory, a study could in theory be notified twice by two different actors. We are aware that the European Food Safety Authority is working on the establishment of a database (paragraph 1 of Article 32b) and on a system that would avoid duplicated notifications and we would appreciate if this could be clarified to all stakeholders, for instance in the recitals.
- Article 1 of the draft implementing Regulation inserting new Article 7c – paragraph 4 into Regulation 257/2010: In our view, Article 32b of Regulation 2019/1381 does not foresee a process where the Commission consults EFSA on the need to notify studies when an EFSA Opinion is not required or requested. In addition to the mere practical and organisational aspects such consultation would entail, we believe that the legal grounds for this specific provision should be clarified.
- Article 1 of the draft implementing Regulation inserting new Article 7c – paragraph 5 into Regulation 257/2010: We would question the proportionality of this provision. The failure or inability to provide data from one study in full should not jeopardise all of the submitted data. It is also possible that data relevant to the re-evaluation cannot be obtained in full by the interested business operators and interested parties, but what is available to them is provided in good faith. This is all the truer that the re-evaluation of an additive does not rely on an application and various stakeholders are often involved in the submission of data, such as the producers and the users of the additive.
- Article 2 of the draft implementing Regulation: We suggest that the implementing Regulation clarifies that it does not apply to data submitted as part of an on-going re-evaluation that is in progress already as of 27th March 2021, and that this includes any subsequent requests for follow-up data that are part of that same re-evaluation.
We thank you for this opportunity to provide comments.
Biopolymer Int.
Read full responseResponse to Amendment of products and substances allowed in organic production
12 Aug 2019
Thank you for the opportunity to comment. Biopolymer International, the association that represents the manufacturers of xanthan gum and gellan gum, would appreciate if the 3-year transition period provided for gellan gum to adapt to organic production rules could be extended by 2 additional years (i.e. 5 years). Gellan gum is produced by fermentation, a process that requires time to be adapted to organic production rules. We thank you for considering our request.
Read full response