EU Specialty Food Ingredients

The objectives of the federation are: 1.To represent the mutual interests of the European specialty food ingredient Industry, principally in scientific, technological and regulatory matters. 2. To make representations to the European Commission and other relevant authorities on all aspects of current and proposed legislation affecting specialty food ingredients. 3.To establish continuing liaison with other relevant organisations having interests in specialty food ingredients and related matters. 4. To monitor upcoming issues affecting specialty food ingredients within the EU and to distribute relevant information to Members. 5. To encourage and support Members in increasing the awareness of food manufacturers and the public of the functions and safe use of specialty food ingredients. 6. To encourage inter-association co-operation while individual member associations remain responsible for their own sectors.

Lobbying Activity

Response to Food and Feed Safety Simplification Omnibus

10 Oct 2025

EU Specialty Food Ingredients, the association representing more than 200 European manufacturers of specialty food ingredients (www.specialtyfoodingredients.eu), thanks the European Commission for the opportunity to contribute to this call for evidence. Specialty food ingredients like functional carbohydrates, vitamins, specific proteins and fats like omega 3, minerals, fibres, food additives, salt replacers etc., have technological and/or functional benefits and are essential in providing todays consumer with a wide range of tasty, safe, healthy, affordable, qualitative and sustainably produced food. They are key segment in the European food industry that is used in many of consumer foods. Our association supports legislative simplification to help advance Competitive, Innovative, Resilient, and Sustainable EU food systems. To this end, it is essential to: Ensure that the European Food Safety Authority (EFSA) operates at optimal performance to enhance the global competitiveness of the EU agri-food sector, reducing the unpredictability of the Risk Assessment process and including close cooperation with the applicants and the Member States experts and institutions. Shape a fit for purpose and predictable regulatory framework that can adapt to an evolving society and agri-food systems. For example, members support legal clarification that for fermentation products where Genetically Modified Microorganisms are used as production strains, the resulting food, subject to adequate purification, is to be considered produced with genetically modified microorganisms (i.e., outside the GMO legislation). This will create regulatory certainty and harmonised enforcement practice. Additionally there is a need for authorities to lead more decisively on addressing science and data gaps where the market is impacted by safety issues (e.g., ethylene oxide) and/or new regulatory limits are under consideration (e.g., MOAH limits for food additives). Transparency and proportionality in decision making are essential. Improve the regulatory efficiency of legislation through a practical, on-the-ground approach to strengthen the resilience of the EU food supply chain, utilising systematic evaluations, targeted consultations, and ongoing open dialogue with sector representatives. Food safety measures to be based on a balanced science-backed and transparent risk/benefit analysis together with a holistic approach. For example, it is proposed to improve the Novel Food Regulation, where novel food ingredients are produced with the use of enzymes (see attachment). EU Specialty Food Ingredients statement Key recommendations for EU Institutions towards Competitive, Innovative, Resilient, and Sustainable EU Food Systems is also attached for full reference. Thank you for your consideration.
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Meeting with Claire Bury (Deputy Director-General Health and Food Safety) and

17 Sept 2025 · EFSA’s performance evaluation

Response to Evaluation of the European Food Safety Authority (EFSA) 2017-2024

28 Mar 2024

Thank you for the opportunity to comment. Please find attached EU Specialty Food Ingredients comments. Best regards.
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Response to Revision of the definition of engineered nanomaterial in food

12 Jan 2024

EU Specialty Food Ingredients thanks the European Commission for the opportunity to comment on the draft Delegated Regulation amending Regulation (EU) 2015/2283 as regards the definition of "engineered nanomaterials". Please find our comments in attachment. Yours sincerely,
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Response to Streamlining EU scientific and technical work on chemicals through the EU agencies

4 Apr 2022

EU Specialty Food Ingredients represents the European manufacturers of specialty food ingredients, a wide range of functional carbohydrates, vitamins, specific proteins and fats, minerals, fibers, food improvement agents such as food additives and food enzymes, cultures, etc. Many of these ingredients are subject to a pre-market authorisation that implies the assessment of their safety for human consumption by the European Food Safety Authority (EFSA). Our comments are attached. We thank the European Commission for the opportunity to comment and look forward to the upcoming targeted consultation of businesses to provide more detailed insights about the considered initiative.
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Response to Sustainable food system – setting up an EU framework

25 Oct 2021

EU Specialty Food Ingredients appreciates the opportunity to comment on the inception impact assessment on the future initiative setting a framework for sustainable food system. As a signatory of the EU Code of Conduct on Responsible Food Business and Marketing Practices, our federation and its members are fully engaged in the dynamic transition towards a more sustainable system. We are therefore happy to share our comments in the attached document.
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Response to Setting of nutrient profiles

29 Jan 2021

EU Specialty Food Ingredients welcomes the opportunity to comment on the Inception Impact Assessment concerning a revision of Regulation (EU) No 1169/2011 on the provision of food information to consumers. Please find our comments attached.
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Response to Amending the rules concerning the re-evaluation of approved food additives in view of the “Transparency Regulation”

29 Oct 2020

EU Specialty Food Ingredients would like to thank the European Commission for the opportunity to comment. Our contribution is enclosed.
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Response to Amending administrative & scientific requirements for applications for novel foods in view of “Transparency Regulation

20 Aug 2020

EU Specialty Food Ingredients would like to thank for the opportunity to comment on the draft regulation via the public consultation. We look forward to see how the new particulars will be implemented in practice in an international competitive environment. For transparency and for the sake of engagement with stakeholders, we would welcome that a similar consultation be offered for the draft Practical Arrangements on confidentiality, transparency, notification of studies, public consultation of third parties and pre-submission advice before their adoption, bearing in mind that these Arrangements do implement the Transparency Regulation too and have far-reaching consequences for the preparation of applications.
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Response to Amending the rules for applications for food additives, enzymes & flavourings in view of the “Transparency Regulation"

19 Aug 2020

EU Specialty Food Ingredients would like to thank the European Commission for the opportunity to comment. Our contribution is enclosed.
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Response to Farm to Fork Strategy

5 Mar 2020

Please find attached the contribution of EU Specialty Food Ingredients. Thank you for the opportunity to comment.
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Response to Establishing a legal limit for the industrial trans fats content in foods

31 Oct 2018

EU Specialty Food Ingredients would like to thank the European Commission for the opportunity to comment on the proposed regulation. Please find our comments in the attached document. EU Specialty Food Ingredients Secretariat
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Response to Transparency and sustainability of the EU risk assessment model in the food chain

22 Jun 2018

EU Specialty Food Ingredients represents a united voice for the specialty food ingredients industry on scientific, technical and regulatory issues relating to food products in Europe. In total, more than 200 international and national food ingredients companies (of which 22 % SMEs) are currently involved in the activities through direct membership or an association. 3-8% of EU specialty food ingredients manufacturers' turnover is dedicated to research and development, which makes the sector within the food industry at the cutting edge of research and innovation. This strong innovation-driven and science-based position in the food chain makes our business a key contributor to the competitiveness of the European food industry sector. Members of EU Specialty Food Ingredients submit applications for the authorisation of novel food ingredients, new food additives and food enzymes, the safety of which is assessed by EFSA as part of a well-established pre-market authorisation procedure. We have supported and still support the establishment of EFSA as the body for centralised risk assessment in the European Union, the scientific outputs of which shall be reliable and trusted to allow the access to the EU market of safe food ingredients. EU Specialty Food Ingredients therefore welcomes the intention of the European Commission to address the societal demand that the risk assessment process in the area of food law be more transparent to the extent that it is expected “to contribute to the Authority acquiring greater legitimacy in the eyes of the consumers and general public in pursuing its mission, increases their confidence in its work and ensures that the Authority is more accountable to the Union”. Nevertheless EU Specialty Food Ingredients deeply regrets that no impact assessment has been carried out prior to the adoption of the proposal by the College of Commissioners, given the consequences of the proposed transparency measures on innovation and competitiveness for our sector. We insist that the proposed measures have no equivalent in the EU legislation to date and they deserve an impact assessment of the provisions related to: - Notification process - Process for disclosure of non-confidential documents - Questionable added value for food additives, enzymes and novel food ingredients - Confidential versus non-confidential business information - EFSA empowerment for establishment of internal rules and decision on confidentiality. In particular the proposed proactive automatic disclosure on EFSA website of non-confidential business information at the time the application is submitted to EFSA would simply flag a company business strategy to all competitors around the world, thus depriving it from its competitive advantage.
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Response to Implementing act on the Union list

2 Nov 2017

Dear Sir, Dear Madam, Please find attached the EU Specialty Food Ingredients Comments on the draft Implementing Act. Best regards, Petr Mensik EU Specialty Food Ingredients
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Response to Commission Implementing Regulation laying down administrative and scientific requirements for novel food applications

11 Aug 2017

Dear Sir, Dear Madam, Please find attached the EU Specialty Food Ingredients Comments on the draft Implementing Act. EU Specialty Food Ingredients Secretariat
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Response to Commission Impl. Reg. laying down administrative & scientific requirements for traditional foods from a Third Country

11 Aug 2017

Dear Sir, Dear Madam, Please find attached the EU Specialty Food Ingredients Comments on the draft Implementing Act. EU Specialty Food Ingredients Secretariat
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Response to Implementing act on procedures for novel food status

11 Aug 2017

Dear Sir, Dear Madam, Please find attached the EU Specialty Food Ingredients Comments on the draft Implementing Act. EU Specialty Food Ingredients Secretariat
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Response to Specific rules concerning food replacing the whole daily diet for weight reduction purposes

17 Mar 2017

As the voice of the specialty food ingredients industries in Europe, the EU Specialty Food Ingredients very much appreciates the European Commission’s attempts to seek the stakeholders’ views on the content of the draft delegated regulation setting the specific compositional and information requirements for total diet replacement for weight control. We would like to raise some points we believe should be taken into account when considering the essential composition of these products. Our comments as regards compositional requirements for DHA, EPA, fibre and the use of nutrition and health claims are summarised with relevant references in the attached document.
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