Council for Responsible Nutrition UK
CRN UK
The Council for Responsible Nutrition UK (CRN UK) is a trade association based in the United Kingdom (UK), whose members market food supplements, functional foods and their ingredients in the UK, across the whole of the European Union (EU) and globally.
ID: 425248337905-06
Lobbying Activity
Response to Import conditions and border controls of trade samples and certain composite products
22 Nov 2021
The Council for Responsible Nutrition UK (CRN UK) is a trade association based in the United Kingdom (UK), whose members market food supplements, functional foods and their ingredients in the UK, across the whole of the European Union (EU) and globally.
CRN UK has very serious concerns regarding the proposed revisions to Delegated Regulation (EU) 2019/625 as regards Combined Nomenclature (CN) and Harmonised System codes and import conditions of certain composite products; and also the proposed revisions to Delegated Regulation (EU) 2019/2122 as regards certain samples and pet birds exempted from official controls at border control posts, as follows:
1. Vitamin D3
- As currently proposed, this Regulation could have a major impact on the public health of the EU population, which relies significantly on added vitamin D3 in foods in order to achieve adequate vitamin D status.
- Vitamin D3 is a highly processed and highly pure organic chemical that should continue to be treated as such, as has been the case to date.
- If vitamin D3 is treated as a product of animal origin (POAO), and no other coinciding technical revisions are put in place, vitamin D3 will not be able to be imported into the EU, nor will it be possible to manufacture vitamin D3 in the EU, as its starting material (cholesterol) will also be restricted.
- The designation of vitamin D3 as a POAO imposes the need for it, and most products containing it, to be accompanied by an export health certificate (EHC) when entering the EU, which is disproportionate for a highly pure chemical substance for which there is no public health concern.
- The requirement for EHCs has a major adverse financial and cost impact on businesses and could reduce the viability for many companies to import products containing vitamin D3 into the EU.
2. Samples
- It is essential that there is a differentiation between samples imported for chemical/microbiological laboratory testing, which will not be consumed, and those for organoleptic testing or other trade purposes, which might be consumed.
- The inconsistency and lack of harmonisation between EU Member States as regards the importation of trade samples is likely to increase.
- It is unclear what is meant by the requirement for the certificate or declaration in accordance with Commission Implementing Regulation (EU) 2020/2235. Is this the same EHC as needed now or something new?
- It is unclear what form of Official Controls are intended to be implemented at destination.
The above concerns are explained in more detail in our submitted document.
Read full response21 Apr 2020
The Council for Responsible Nutrition UK (CRN UK) is a trade association based in the United Kingdom (UK), whose members market food supplements, functional foods and their ingredients in the UK, across the whole of the European Union (EU) and globally.
CRN UK and its members consider the safety of consumers to be paramount when placing products on the market. However, we are extremely concerned about the scope of this proposal in relation to the use of Aloe extracts in foods, including food supplements. The measure proposed for Aloe extracts is highly disproportionate, in terms of the products involved and in light of more recent data:
- The unconditional ban of all Aloe extracts is not proportionate to the identified risk, the limited scope of the EFSA opinion adopted in 2017, the data gaps and the persisting uncertainty.
- The wording of the proposal means that products with very low hydroxyanthracene derivative content that, to our understanding, were not intended to be covered are now in scope.
- The proposal does not give food business operators the opportunity to provide data on these other product types, despite these product types not having been covered in the EFSA opinion.
- The ban of all Aloe extracts does not respect the legal requirement that in cases where uncertainty persists, substances should be put in Part C of Annex III to allow for the generation and submission of further data and a subsequent EFSA opinion.
Our more detailed comments are given in the attached document.
Read full response