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International Sweeteners Association

ISA

The Association is a non-profit making association.

Lobbying Activity

Response to EU cardiovascular health plan

16 Sept 2025

Dear Madam, Dear Sir, The International Sweeteners Association (ISA) is an international non-profit organisation with scientific aims representing suppliers and users of low/no calorie sweeteners, including tabletop sweetener manufacturers. We thank the European Commission for this opportunity to provide information that can support the development of this important EU cardiovascular plan. Our input can be found in the attached document. Yours sincerely, the ISA team.
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Meeting with Alexandra Nikolakopoulou (Head of Unit Health and Food Safety), Sabine Pelsser (Head of Unit Health and Food Safety) and

16 Sept 2025 · Specific conditions for the use of sweeteners in the food additive legislation, in particular, the requirement to replace sugars for the production of energy-reduced food

Meeting with Ariane Vander Stappen (Head of Unit Health and Food Safety), Sabine Pelsser (Head of Unit Health and Food Safety)

12 Feb 2025 · Discussion of several points related to low/no calorie sweeteners

Response to Use of sweeteners in food category 07.2 fine bakery wares

23 Jun 2017

The International Sweeteners Association (ISA), representing suppliers and users of low calorie sweeteners, would like to provide the following comments in relation to the draft Commission regulation and related Annex amending Annex II to Regulation (EC) No 1333/2008 of the European Parliament and of the Council as regards the use of sweeteners in fine bakery wares (encl.). The use of sweeteners in 'fine bakery products for special nutritional uses' was first authorised by European Parliament and Council Directive 94/35/EC on sweeteners for use in foodstuffs and is currently authorised in Annex II of Regulation 1333/2008 on food additives. The draft text (Whereas (4)) states, “fine bakery products for special nutritional uses' covered 'foods for persons suffering from carbohydrate metabolism disorders (diabetes)' regulated by Council Directive 89/398/EEC.” Whilst we infer from this text that the intention was to ensure that this entry covered “foods for persons suffering from carbohydrate metabolism disorders (diabetes),” as regulated by Directive 89/398/EEC, neither a definition nor a reference to this text was included in Directive 94/35/EC, nor is there any clarification for this entry provided in the Guidance document describing the food categories in Annex II of Regulation 1333/2008. As such, fine bakery products for special nutritional uses, which typically contain no-added sugar, have been legally placed on the EU market for many years. Importantly, these products have not necessarily been marketed as suitable for diabetics. Following the repeal of the PARNUTS legislation via Regulation (EU) 609/2013, which abolished the concept of ‘foodstuffs for particular nutritional uses,’ it is clear that no products can be marketed as suitable for diabetics. On the above basis, to ensure the proper functioning of the internal market, we would respectfully ask for a transition period whereby fine bakery products for special nutritional uses lawfully placed on the market for three years after the date of entry into force of this Regulation, may continue to be marketed until stocks are exhausted. Thank you in advance for considering these comments. International Sweeteners Association
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