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European Lecithin Manufacturers Association

ELMA

- To represent and defend the interest of Lecithin industry - To monitor issues on scientific, technological, and regulatory matters

Lobbying Activity

Response to Amendment of products and substances allowed in organic production

15 Aug 2019

ELMA, the European Lecithin Manufacturers Association, would like to thank the European Commission for the opportunity to submit comments on the draft Commission Implementing Regulation amending Regulation (EC) No 889/2008 laying down detailed rules for the implementation of Council Regulation (EC) No 834/2007 on organic production and labelling of organic products with regard to organic production, labelling and control. We would like to point out that further to the renewal of the authorisation of lecithins (E 322) as a feed additive, the number for lecithins complying with the purity criteria in the specification for E 322 has been changed to 1c322i by Commission Implementing Regulation (EU) 2018/1980 amending Implementing Regulation (EU) 2017/2325 as regards the terms of authorisation of preparations of lecithins liquid, lecithins hydrolysed and lecithins de-oiled as feed additives for all animal species. Therefore, we would suggest replacing the old number E 322 which is now used in the EU for lecithins used as a food additive only, in the entry for lecithins in Annex III of the draft Regulation referring to Annex VI – Feed additives used in animal nutrition referred to in Article 22(g), Article 24(2) and Article 25m(2) with the new number 1c322i for lecithins authorised as a feed additive, in order to align the numbering system with the relevant EU legislation concerning feed additives mentioned above.
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