European Food Emulsifiers Manufacturers Association
EFEMA
The main objectives of the Association are to support and promote the general scientific, economic and technical interest of producers in Europe of food emulsifiers based on fats and their derivatives.
ID: 61813266495-76
Lobbying Activity
Response to Commission Regulation on maximum levels for glycidyl esters in certain foods
14 Sept 2017
EFEMA noted that, in its whereas (5) the Draft Regulation amending Regulation (EC) 1881/2006 as regards maximum levels of glycidyl fatty acid esters in vegetable oils and fats, infant formula, follow-on formula and foods for special medical purposes intended for infants and young children provides that: “Because of the health concern for infants, toddlers and young children it is appropriate to establish a stricter maximum level for vegetable oils and fats destined for the production of baby food and processed cereal-based food for infants and young children”.
However, we noted that the row 4.2.2 in the Annex to this draft Regulation only refers to “Vegetable oils and fats destined for the production of baby food and processed cereal-based foods”, without specifying that these “processed cereal-based foods” are destined for infants and young children, as it is clearly stated in the whereas (5) of the Draft Regulation.
We also noted that the row 4.2.2 includes a footnote 3, which relates to footnote 3 of the consolidated version of Regulation 1881/2006 setting maximum levels for certain contaminants in foodstuffs . Indeed, footnote 3 relates to: “Foodstuffs listed in this category as defined in Regulation (EU) No 609/2013 of the European Parliament and of the Council of 12 June 2013 on food intended for infants and young children, food for special medical purposes, and total diet replacement for weight control and repealing Council Directive 92/52/EEC, Commission Directives 96/8/EC, 1999/21/EC, 2006/125/EC and 2006/141/EC, Directive 2009/39/EC of the European Parliament and of the Council and Commission Regulations (EC) No 41/2009 and (EC) No 953/2009 (OJ L 181, 29.6.2013, p. 35).”
We also noted that, according to Article 2.2.(e) of Regulation 609/2013 , “processed cereal-based foods” are defined as: “intended to fulfil the particular requirements of infants in good health while they are being weaned, and of young children in good health as a supplement to their diet and/or for their progressive adaptation, to ordinary food; and
(ii) pertaining to one of the following categories:
— simple cereals which are or have to be reconstituted with milk or other appropriate nutritious liquids,
— cereals with an added high protein food which are or have to be reconstituted with water or other protein-free liquid,
— pastas which are to be used after cooking in boiling water or other appropriate liquids,
— rusks and biscuits which are to be used either directly or, after pulverisation, with the addition of water, milk or other suitable liquids”.
However, and for clarity’s sake, we would suggest adding “for infants and young children” next to “processed cereal-based foods” in row 4.2.2 of the Annex to the Draft Regulation.
We thank you for your consideration to our comment.
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