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Kerry Ingredients & Flavours Ltd.

Kerry

Kerry group is a world leader in food ingredients and flavour technologies, serving the food, beverage, and pharmaceutical industries, and also a leading consumer foods processor and supplier in selected EU markets

Lobbying Activity

Response to Flavourings - as regards certain flavouring substances

24 Nov 2016

Dear Sir/Madam, Re: Public Consultation on FGE.203 Draft Regulation Kerry Ingredients and Flavours would like to take the opportunity to comment on the proposal. We are members of the UK Flavour Association (UKFA) and The European Flavour Association (EFFA) and we support their views on this topic. We fail to see the justification for changing the rules of engagement in the process previously applied. There is a legal certainty in maintaining the original approach as established in Regulation 872/2012 whereby flavouring substances still under evaluation remain on the list with a footnote until the risk evaluation and authorisation procedure has been concluded. To introduce temporary risk management measures before the risk management has been completed is, we believe, disproportionate as there will be no risk to health. Toxicity data to support the safe use of these materials was submitted in a timely fashion to the Authority. The safety data submitted does not, we believe, indicate safety issues with the flavouring materials concerned. The concept of this precautionary measure has already resulted in a administrative burden on Kerry as it responds to its customers’ demands about the presence and use levels of the affected flavouring substances. If the Regulation is passed into law we expect that demand to rise significantly. We have identified a range of Kerry flavouring products that are affected by the draft Regulation and these are used in a range of different food and beverage applications. Some customers will await further safety studies but others will demand removal of these substances and that demand will impose extra unnecessary burdens of time and cost on our RD&A function. It must be acknowledged that any removal of such a substance will be terminal. Any future change in legislation that then allows unrestricted use will have no effect as re-engineering of the products will not be commercially viable. We question what the proposed legislation achieves with regard to decreasing the risk to health and urge the Commission not to proceed with a measure which we view as disproportionate and unnecessary. Best regards Mike Gilligan Regulatory Affairs Manager
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