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Specialised Nutrition Europe

SNE

Specialised Nutrition Europe represents the association for the specialised nutrition industry across Europe.

Lobbying Activity

Meeting with Pietro Fiocchi (Member of the European Parliament)

30 Jun 2025 · Tematiche ambientali

Meeting with Margarita De La Pisa Carrión (Member of the European Parliament)

18 Jun 2025 · Nutrition in Europe

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

21 Mar 2025 · Discussion on the possible harmonisation of maximum permitted limits for vitamins and minerals in food

Meeting with Stefan Köhler (Member of the European Parliament) and European Biodiesel Board and Friedrich-Alexander-Universität Erlangen-Nürnberg

4 Mar 2025 · Politischer Austausch

Meeting with Antonella Rossetti (Cabinet of Commissioner Christophe Hansen)

3 Mar 2025 · Exchange of views on food for people with specific nutritional needs

Meeting with Laurent Castillo (Member of the European Parliament)

19 Feb 2025 · Nutrition

Meeting with Vytenis Povilas Andriukaitis (Member of the European Parliament) and Cancer Patients Europe

6 Feb 2025 · EU Health Policy

Meeting with Maria Noichl (Member of the European Parliament)

22 Jan 2025 · specialised nutrition

Meeting with Céline Imart (Member of the European Parliament) and Farm Europe

21 Jan 2025 · Agriculture

Meeting with Pietro Fiocchi (Member of the European Parliament)

21 Jan 2025 · Nutrizione e obesità

Meeting with Cristina Maestre (Member of the European Parliament)

21 Jan 2025 · Introductory meeting with Specialised Nutrition Europe

Meeting with Estelle Ceulemans (Member of the European Parliament) and Medical Nutrition International Industry

9 Dec 2024 · Dossier SANT à venir

Meeting with Oliver Schenk (Member of the European Parliament)

15 Oct 2024 · Die neuen Regelwerke der World Health Organization (WHO) zur Säuglings- und Kleinkindernährung

SNE seeks specialized nutrition exemptions from EU packaging waste rules

20 Feb 2023
Topic — This consultation reviews EU packaging requirements to promote design for reuse and recycling.
Message — SNE requests exemptions for specialized nutrition from recyclability, recycled content, and reuse requirements. They argue that infant and medical foods need the same protections as medicines.12
Why — This would ensure patient safety and security of supply for vulnerable groups.3
Impact — Environmental groups lose because exemptions reduce the amount of packaging being recycled.4
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Response to Import conditions and border controls of trade samples and certain composite products

23 Nov 2021

Specialised Nutrition Europe, the voice of the specialised nutrition industry in Europe, welcomes the opportunity to provide feedback on this draft Delegated Regulation. Our comments, detailed in the attached paper, relate to two aspects of the draft Regulation: 1. The import conditions for vitamin D3 derived from lanolin; and 2. The import conditions and border controls of R&D samples and certain composite products.
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Response to Setting of nutrient profiles

19 Jan 2021

• Front-of pack nutrition labelling (FOP) & nutrient profiles (NP) SNE supports science-based policy initiatives that aim to improve public health by promoting healthy nutrition & helping consumers understand nutrition labelling & make informed decisions. Foods covered by the specialised nutrition sector are tailor-made dietary solutions for populations with very specific nutritional needs including infants & young children, patients under medical supervision, sportspeople, overweight & obese consumers, & those suffering from coeliac disease. They are regulated with specific requirements on composition, labelling, hygiene, packaging, etc. These requirements are based on science, incl. the dietary recommendations of recognised authoritative scientific bodies. Therefore, SNE supports a general exclusion for specialised nutrition from FOP schemes & NP developed for general foods (i.e. for population above 36 months). This includes the following product categories: Foods for Specific Groups (Regulation (EU) 609/2013); Meal Replacements for weight control (Regulation (EU) 2016/1413); Young child formulae; Foods intended for sportspeople. FOP schemes for general foods adopt calculation methods which are not suitable for specialised nutrition products, as they are developed for the healthy adult population. These schemes unjustifiably discriminate specialised nutrition foods: • They do not consider the ratio between macronutrients & micronutrient density; • Rate foods with a high fat content negatively. However, some specialised nutrition products, such as infant nutrition, have a fat content required by law, in adequacy with infants’ specific nutritional needs; • Ignore the reformulation constraints of gluten-free foods; • Some express a score per 100 grams of finished products, which is illogical for some specialised nutrition products as sports nutrition or slimming foods (formulation linked to the quantity of consumption recommended by the manufacturer). • Origin labelling SNE remains fully committed to transparency, i.e. by providing origin information when relevant. SNE considers that specific requirements currently in place provide sufficient information, & therefore support “Option O - Baseline (‘business as usual’)” for all specialised nutrition products. Specialised nutrition products contain several ingredients of both animal & non-animal origin to satisfy the nutritional needs of specific groups of consumers. There are various dairy ingredients added, e.g. skimmed milk powder, milk protein hydrolysate, whey protein concentrates or lactose. Consumer’s purchasing decision is likely not be substantially affected by the lack of origin indication for milk & milk ingredients in these foods. Moreover, specialised nutrition products have to display several additional particulars in addition to those required by FIC Regulation. Providing additional information could lead to an overload of information & could distract consumers’ attention from important information specific to specialised nutrition. Lastly, as for all products, it is important to accommodate flexibility to enable SNE manufacturers to respond to unforeseen challenges due to fluctuations in seasonal availability, quality differences, costs, & sustainability of raw materials. • Date marking Specialised nutrition products are nutrient-dense foods specifically formulated to respond to the needs of specific consumers. By their specific mandatory composition requirements, these products are usually fortified with vitamins & minerals, whose content can decrease over the product shelf-life. The ‘best before date’ is an essential element to ensure that specialised nutrition products contain a sufficient amount of nutrients along the shelf-life. SNE is of the view that the current EU rules provide adequate quality and safety parameters for specialised nutrition products.
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Response to Green Paper on Ageing

11 Dec 2020

Specialised Nutrition Europe (SNE) appreciates the opportunity provided by the European Commission to answer to the consultation on the Roadmap on the Green Paper on Ageing. SNE welcomes this proposal, which will set out the key issues and discuss ways to anticipate and respond to the socio-economic impacts of demographic change and to harness further opportunities. More specifically, the Green Paper will approach “How to meet people’s needs - taking into account both the challenges that come with an ageing society as well as the new opportunities”. As the voice of the specialised nutrition industry across Europe, SNE would like to highlight the burden of malnutrition in Europe; 33 million people are at risk of malnutrition in the EU. Malnutrition is estimated to cost European countries €170 billion a year (Ljungqvist O & de Man F 2009). Undernutrition - a major health problem in Europe, Nutr Hosp 24:368–370), primarily among hospital patients and the ageing population. Older people are particularly affected by malnutrition (Kaiser MJ et al. J Am Geriatr Soc 2010; 58:1734-8): -More than 1 in 3 people in care homes are malnourished or at risk of malnutrition; -1 in 3 older people living independently are at risk of malnutrition. Often older people are unable to meet their nutritional needs through the normal diet, and are therefore more at risk of malnutrition. Malnutrition is caused by inadequate intake of energy, protein and/or other nutrients as a result of diseases or their treatment or loss of appetite. Despite the availability of screening tools, malnutrition among older people often goes undetected and untreated. Malnutrition among older people leads to increased risk of complications such as infection, poor wound healing, frailty and falls which leads to additional hospital admissions/readmissions and increased length of stay, with the associated health costs. It can also result in loss of independence, reduced quality of life and increased mortality. Malnutrition should not be accepted as an inevitable consequence of the ageing process. In this context, food for special medical purposes is the most effective way to provide them with the essential nutrients they need. Across Europe, different national approaches and initiatives have been developed and implemented to fight malnutrition in a growing context of ageing population. Some countries are particularly advanced, and have set national multidisciplinary knowledge centre for the awareness, prevention, identification and treatment of malnutrition: -for example, in the Netherlands: the Dutch Malnutrition Steering Group: https://www.fightmalnutrition.eu/dutch-malnutrition-steeringgroup/the-dutch-malnutrition-steering-group, with a focus on children, chronically and acutely ill and older persons. - in the UK: https://bsna.co.uk/uploads/banners/BSNA_infographic-leaflet-November-2018.pdf In some other countries of the European Union, malnutrition of older people still goes undetected and untreated, due to lack of knowledge of the prevention and treatment of malnutrition. SNE would therefore support the integration of malnutrition as a key consideration in the Green Paper on Ageing, in order to respond to the nutritional needs of an ageing population: - This would ensure that the European Union would support, coordinate and complement Member States’ efforts to fight malnutrition in elderly populations and ensure a healthy and active aging; - This would also have a positive impact on the sustainability of public budgets, as an early diagnosis, screening and treatment of malnutrition avoids further complications, which are associated with higher healthcare costs.
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Response to Model health certificates for certain categories of animals and goods

2 Nov 2020

Specialised Nutrition Europe (SNE) would like to thank the European Commission for this consultation, and is willing to share the following comments on the consultation on Food safety - Standard health certificates for animals & goods: - Article 5(e): This is not a practical requirement. While the inclusion of the certificate along with the consignment is the practice for air freight, it is not logistically possible to fulfill this requirement for ocean freight. The EU certificates require significant traceability details that are known only when the loading is complete, the pieces and weights are verified, and the container is sealed. The exporter requests the certificate from the competent authority once loading is complete. The competent authority issues the certificate within 5 working days based on the plant’s eligibility under the national system of inspection. There is no inspector physically present at the loading facility to issue a certificate and place it in the container. Therefore, propose this article to be appropriately amended to be practical and implementable. - Missing Reference Document in Annex: Commission Implementing Regulation (EU) 2020/… [SANTE/7140/2020] is referred to in several of the attestations in the animal health sections of the dairy certificate. The text of this draft regulation is not yet available to review. Therefore, it is not possible to provide a full review of the draft certificates since we are unaware of the content of this draft implementing regulation. - Animal Health Requirements – Not aligned with OIE requirements: The draft dairy certificates contain new animal health attestations that go beyond the World Organization for Animal Health’s (OIE) recognition of disease freedom and demand that the competent authority sign to specific regulatory controls, focusing on process rather than outcome. - Chapter 35 II.2.3: This requirement is inconsistent with OIE guidance (https://www.oie.int/index.php?id=169&L=0&htmfile=chapitre_fmd.htm), which states that the animals “were kept since birth or for at least the past three months in a FMD free country or zone where vaccination is not practised or a FMD free compartment.” Therefore, the OIE appears to allow travel between FMD-free countries and zones as long as these countries and zones have the same FMD status, whereas the EU language requires the cow to be domiciled in the zone of milking for 3 months. In addition to inconsistency with OIE provisions, this statement should not be applicable to trade in pasteurized dairy products according to the EU’s legislation. Article 154 of Commission Delegated Regulation 2020/692 states that this 3-month residency requirement applies only to consignments of raw milk, colostrum, or colostrum-based products. However, dairy products exported under the NT certificate will be pasteurised. They are not raw milk. - Chapter 35 part II.2.4. (a) and (b): The two proposed farm-level requirements provide specific regulatory controls aimed at regulating how a country achieves disease-free recognition, going beyond OIE recognition of disease status. Therefore, SNE requests that this draft regulation recognizes OIE disease status of the country rather than includes specific process requirements. Similar requirements exist in all Model Official Certificates for Dairy products: OIE Official disease status: https://www.oie.int/en/animal-health-in-the-world/official-disease-status/
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Response to Action plan for the development of EU organic production

22 Oct 2020

Specialised Nutrition Europe (SNE) is grateful for the opportunity given to stakeholders to share their views on the future Commission Action Plan on organic production. The specialised nutrition sector supports the Commission’s target to reach at least 25% of the EU’s agricultural land under organic farming by 2030. In order to achieve this target, it is important that the future Action Plan takes a comprehensive approach towards organic production and addresses all aspects that currently impede the growth of the organic market in Europe. SNE’s members are committed to working towards a more sustainable food system that responds to consumers’ demand for healthier and more environmentally friendly food. Organic farming is a major way to achieve that. Some of the companies of our national member associations are already producing most of their products organically. However, and as the roadmap rightly emphasises, further production incentives should be developed to reach the 25% target. In this context, SNE would like to share a few considerations that are specific to the specialised nutrition industry. Specialised nutrition manufacturers who want to offer their products in organic versions are currently facing many challenges raised by the relevant EU provisions, thus limiting the supply of organic products in this sector. Because they are intended for consumers with specific nutritional needs (e.g. people with medical conditions and/or specific nutritional needs, infants and young children, sportsmen and women etc.), specialised nutrition foods are complex products to which vitamins, minerals and other substances – which do not always exist in organic forms - are very often added and/or required by EU legislation. However, according to current EU rules on organic production and labelling, the addition of non-organic vitamins, minerals, amino acids and micronutrients to organic specialised nutrition products is allowed only in organic infant formula, follow-on formula and baby food. This can have consequences for other categories of specialised nutrition, like young child formula (targeting young children from 1 to 3 years), food for special medical purposes, food intended for sportspeople, total diet replacements and meal replacements for weight control: under certain interpretations of the current EU rules, these foods cannot be placed on the EU market as organic. This situation not only impedes the growth of the organic market for specialised nutrition products but also limits the innovation in the sector by discouraging further research. Another important point concerns the export of organic products from the EU to third countries, which will be an important mean to achieve the 25% target by 2030. As the third biggest agri-food exporter in the EU (https://www.fooddrinkeurope.eu/uploads/publications_documents/FoodDrinkEurope_-_Data__Trends_2019.pdf), the specialised nutrition sector could significantly contribute to achieve this target. However, SNE is concerned that the upcoming application of Regulation (EU) 2018/848 could have a negative impact in terms of export if the current limitations for organic specialised nutrition products are kept. There is currently a growing demand for EU-certified organic products in third countries. This should incentivise the EU to support the export of these products, notably by removing existing technical limitations, but also by protecting current equivalence agreements that will be renegotiated under the new legislative framework and concluding more equivalence agreements with some key third countries. SNE is willing to support the EU in its ambition to promote a global transition for sustainability. This will be essential to maintain the competitiveness of the European specialised nutrition industry at global level.
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Meeting with Catherine Geslain-Laneelle (Cabinet of Commissioner Janusz Wojciechowski), Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

29 Apr 2020 · SNE to present its vision for a sustainable Europe in the context of the new European Green Deal and the associated ‘Farm to Fork Strategy’.

Response to Europe’s Beating Cancer Plan

2 Mar 2020

Specialised Nutrition Europe (SNE) welcomes the European Commission’s initiative on the European Beating Cancer Plan. Cancer is one of the leading causes of mortality and contributes to 20% of the total disease burden in Europe. Treatment targets cancerous cells and tumours, however it should also include measures against cancer-related symptoms, such as pain, fatigue and malnutrition with the aim of improving quality of life of patients and survival. 1 in 3 cancer patients are at risk of malnutrition: malnourished patients may experience inter alia organ damage; immune system dysfunction and lean muscle loss. They have a significantly increased risk of infections & complications, leading to diminished tolerability of chemotherapy, and impact on overall survival. The cost of their care increases placing a significant burden to healthcare systems. Malnourished cancer patients are more frequently hospitalised, and experience longer hospital stays (+3 days). In addition, it is estimated that the cost of not treating malnutrition in cancer costs at an additional €17 billion/year in the EU. As also highlighted by a recent WHO report, appropriate nutritional care helps cancer patients cope better with their illness and treatment. Nonetheless, cancer-related malnutrition often remains underdiagnosed and undertreated in current clinical practice. Where patients are unable to sufficiently feed themselves, medical nutrition helps sustain patients during treatment. However, a recent study shows an overwhelming majority of cancer patients not being screened for nutritional status, nor receiving information on nutritional support (including artificial nutrition) or cachexia (disease induced muscle wasting syndrome and extreme weight loss) from their health professionals. SNE calls for a transformation of current oncology care models as follows: • Education on malnutrition & nutritional care in cancer treatment for healthcare professionals & cancer patients. Integrating curricula on medical nutrition in the training of healthcare professionals, education & awareness around nutritional interventions and supportive care will increase the survival chances, reduce hospital stays and provide cost-savings to the healthcare budgets. The EU should provide funding support for health literacy projects focused on patient education & for developing up-to-date educational modules for healthcare professionals & foster best practice sharing among countries. • Diagnostic/therapeutic approaches to be delivered by a multidisciplinary team, including a dietitian/nutritionist. While it represents the cornerstone of an integrated patient care, this is not the reality of care delivery in the EU today. • Mandatory screening for malnutrition at diagnosis & follow-up throughout treatment to provide timely nutritional care for all cancer patients. Nonetheless, only Scotland and the Netherlands established mandatory screening for malnutrition in cancer patients. • Implementation of existing clinical guidelines on nutritional care for cancer patients in routine treatment protocols, including timely use of medical nutrition (The European Society for Clinical Nutrition and Metabolism & the European Society for Medical Oncology (guidelines under development). • Equal access to nutritional care for all patients; reimbursement of medical nutritional interventions by national healthcare systems. SNE would be pleased to further discuss with the European Commission - as part of the upcoming stakeholders’ consultations - the importance of nutrition in cancer care as an integral part of care pathways. Please also find in attachment more details and the references to our response.
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Response to Farm to Fork Strategy

27 Feb 2020

SNE welcomes the European Green Deal and Farm to Fork Strategy. We look forward to working together with EU decision-makers and third-party stakeholders to facilitate the transition to a sustainable and healthy Europe. In attachment: SNE position on the Green Deal/ Farm to Fork Strategy. Together, let’s work towards: 1. Providing safe and high-quality nutrition from farm to fork. This is a non-negotiable responsibility of our sector and this will be critical to strengthen responses to today’s societal challenges ranging from rising obesity rates to malnutrition. We will continue to foster collaboration across the food supply chain to ensure high-quality and responsibly sourced ingredients and raw materials in our products (regular checks for safety, quality and freshness; strong relationships with farmers/ suppliers to ensure full traceability of ingredients). We call for greater harmonisation and consistency across all food related policies and welcome the EU ambition to work across the supply chain towards the development of sustainable alternatives to pesticides. 2. Helping consumers to make the healthy and sustainable choice. Our sector is committed to responding to consumer demand for more sustainable and nutritious food, including investing in organic farming. Consumers also increasingly want to know where their food comes from and what it contains. We will continue to provide reliable, comparable and verifiable information to enable consumers to make sustainable decisions. 3. Leveraging innovative developments for a healthier life. Our sector is at the forefront of innovation in nutritional science. We invest in R&D to develop/ market evidence-based innovation to protect the health and well-being of European consumers with specific nutritional needs. Innovation is key to guaranteeing the high-level quality/ safety requirements our sector must meet as well as optimizing product packaging/ storage. We welcome European policies that support research and innovation in nutrition and health, taking into consideration consumers’ specialised nutrition needs and delivering solutions to promote healthy ageing. 4. Encouraging sustainable trade and exports. Our sector is the third biggest agri-food exporter in Europe. We are committed to playing our role in promoting an EU trade policy that can support transition towards more sustainable food systems (SFS). 5. Leveraging our sector’s expertise to achieve a circular economy. We are committed to promoting sustainable growth at the heart of the EU economy. Our sector has a long experience manufacturing specialised nutrition products – one of the most strictly regulated foods in Europe. We have been able to identify optimal conditions for the manufacturing of these products with the objective to provide consumers with safe and nutritious foods; and limit our environmental footprints. This helps minimising the loss of resources and food waste. We are ready to continuously support the transition to a circular economy at EU level and would support the creation of a dedicated stakeholders’ platform supporting open stakeholder dialogues in relation to the upcoming European initiatives on the Farm to Fork Strategy. This shall ensure the timely delivery of appropriate input and coordination in order to achieve Farm to Fork Strategy objectives.
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Response to Amendment of products and substances allowed in organic production

16 Aug 2019

Specialised Nutrition Europe (SNE) would like to thank the European Commission (EC) for the possibility to comment on the proposed draft Regulation, and shares the following first comments. Taking into account the timing of this consultation, SNE can only provide below a non-exhaustive list of the sector’s comments. SNE will be pleased to provide further detailed comments at a later stage to the EC. 1) Transition period In Recital 5 of the Draft Regulation, it is specified that: “To allow for sufficient time to adapt to that new requirement, operators should be given a three-year transition period.” SNE therefore asks that the new rules apply as from 1 January 2023 (instead of 1 January 2022). SNE would like to note that the 3-year transition period is needed as a transition to organic for the raw material part requires time. Due to the nature of organic production and its reliance on sometimes uncontrollable climatic and natural conditions, there may not be a consistent and adequate supply of organic ingredients so a safe and suitable non-organic alternative is required for these situations. 2) Food additives specific conditions or restrictions in addition to Regulation (EC) 1333/2008 • Annex IV, Section A – E170 Calcium carbonate: SNE proposes to amend the proposed specific conditions and restrictions as follows: “Shall not be used for colouring of products”. Rationale: Calcium carbonate (E170) may be used as a source of calcium in foods. Prohibiting use of calcium carbonate as a source of calcium in these products would be inconsistent with its allowed use in non-organic versions of the same products from a scientific perspective, which in turn could put organic products at a disadvantage in the marketplace. • Annex IV, Section A – E322 Lecithin: SNE questions the meaning of the proposed specific conditions and restrictions for lecithin (“With regard to foodstuffs of animal origin: Milk products Only when derived from organic production”): - Does this mean that lecithin is only allowed in milk products, but not other animal-derived products? - Would foods for infants and young children (IYC) fit into that category? Or is this a reference to the amount of lecithin that is calculated when determining % organic? • Annex IV, Section A – E407 Carrageenan: Similarly as for Lecithin (see above), SNE questions the meaning of the proposed specific conditions and restrictions for carrageenan (“With regard to foodstuffs of animal origin: milk-based products”): - Does this mean that carrageenan is only allowed in milk-based products, but not other animal-derived products? - Would foods for IYC fit into that category? Or is this a reference to the amount of carrageenan that is calculated when determining % organic? • Annex IV, Section B: SNE is very concerned by the following provisions: - Both calcium carbonate and calcium hydroxide would not be allowed in the preparation of organic products produced from animals; - Magnesium chloride would only be allowed for use as a “coagulation agent”; - Thiamin hydrochloride would only be allowed for “use in processing of fruit wines (…)”. Rationale: Similar to the one provided above for calcium carbonate. SNE would question why nutrient sources such as calcium carbonate are considered as acceptable for non-organic products and yet it is proposed to exclude them from organic products? Nutrients should be acceptable for all product types. SNE suggests that if there is a wish to promote organic produce from the EU then there should be equivalence in relation to permitted nutrients. • SNE would also appreciate confirmation of the below interpretation: SNE reads these new requirements as applicable only for the direct use of additives – meaning that additives allowed to be added in nutrients intended to be used in foodstuffs for IYC as per Regulation (EC) 1333/2008, Annex III, part 5 section B, are not in scope. Can the EC confirm this interpretation?
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Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis)

14 Aug 2019 · SNE manifesto 2019-2024

Meeting with Anne Bucher (Director-General Health and Food Safety)

26 Jun 2019 · SNE priorities, EU developments related to specialised nutrition (food additives, sports nutrition, chlorate in food, processed cereal based foods, baby foods)

Meeting with Marika Lautso-Mousnier (Cabinet of Vice-President Jyrki Katainen), Risto Artjoki (Cabinet of Vice-President Jyrki Katainen)

21 Mar 2019 · Regulatory issues for the specialised nutrition industry

Response to Commission Regulation setting maximum residue levels for chlorate in or on certain products

15 Feb 2019

Specialised Nutrition Europe (SNE) welcomes the opportunity to provide comments to this draft regulation. Despite the fact that the draft regulation focuses on the setting of MRLs for commodities, and not processed foods, SNE is very concerned by the proposed text due to the legal framework considered. This framework is not technically relevant and not legally applicable: 1) The EU pesticide framework is not technically relevant for chlorate: The possible presence of chlorate in food has been found to come from multiple sources, such as water use, disinfection and processing aids, but not as the result of pesticides use. One example is the use of chlorinated drinking water during cultivation, harvest and processing. 2) The EU pesticide framework is not legally applicable for chlorate: SNE strongly believes that Regulation (EC) 396/2005 is not the appropriate legal framework for the management of multiple source substances and especially chlorate as a by-product of biocides, for which different entry points may occur across the supply chain up to the final product intended for the consumer. SNE – with other industry partners – is currently working on a legal assessment to identify the appropriate framework for a risk management approach on chlorate in food. Results of this work should be soon available. 3) The EU pesticide framework and the proposed MRLs for commodities create inconsistencies in the risk management approach while significant efforts and investments have been already done: The proposed draft regulation, setting MRLs for commodities, would be inconsistent with the application of the 0,01 mg/kg by-default limit for chlorate in foods for infants and young children. The European Commission would also have to address a similar inconsistency for the reconstitution of powdered formulae with drinking water, taking into account the current chlorination of drinking water across Europe (in line with WHO drinking water guidelines). The inconsistency towards other legislations from which chlorate is coming from legal uses of disinfection and processing aids should also be addressed. In addition, significant efforts and investments have been made since 2014 by the Industry coalition – composed of SNE and several EU food associations – to reduce the levels of chlorate in foods, and particularly in foods for infants and young children, without compromising food safety. We are however reaching the limits of what can practically be done using existing technologies and within the boundaries of what is legally and economically feasible, and above all, taking into account the importance to preserve microbiological safety. As part of this Industry coalition, SNE has been committed to comply with proposed industry target values for the last two years (see attached Roadmap). 5) Concluding remarks SNE urges the regulators to delay discussions on changes to pesticide MRLs for commodities. Risk management measures for chlorate in foods should take place after the finalisation of the ongoing review of the Drinking Water Directive and should consider the conclusions of the REFIT exercise for the EU pesticides legislation. SNE calls the regulators to continue the dialogue with industry to define a cross-sectorial, consistent, appropriate and proportionate framework for chlorate in Europe, by taking into account: • The provisions in other EU legislations (inter alia contaminants, food hygiene, biocides, food additives); • The industrial constraints linked to the use of chlorine based-products for hygiene and microbiological safety and • The industry efforts to reduce the level of chlorate in foods, and particularly in foods for infants and young children.
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Meeting with Szabolcs Horvath (Cabinet of Commissioner Tibor Navracsics)

7 Dec 2018 · If the EU does not act to harmonise rules, individual Member States may fill this legal vacuum by adopting national rules, resulting in a fragmented internal market

Response to Reducing marine litter: action on single use plastics and fishing gear

23 Jul 2018

Specialised Nutrition Europe (SNE) represents the interests of the European specialised nutrition industry. SNE is committed to supporting the European Commission (EC) in its aim of reducing the impact of certain plastic products on the environment and welcomes the public consultation on the proposed measures. In the context of the European Plastics Strategy as part of the transition towards a more circular economy, SNE would like to provide some comments on the EC Proposal for a Directive on the reduction of the impact of certain plastic products on the environment published on 28 May 2018. Medical Nutrition products The Commission proposal currently under consultation, is driven by the need to reduce marine waste and is focused on the main contributors to this problem, i.e. single use plastics contained in fast moving consumer goods (FMCGs) and fishing gear. It is not intended to impact critical healthcare products and, therefore, SNE requests that medical nutrition products should be clearly exempted from this proposal. Food for special medical purposes (FSMP), falling under Regulations (EU) No 609/2013 and (EU) No 2016/128, and their associated delivery systems, otherwise known as medical nutrition products, are specific categories of regulated products intended for patients who have medically-determined nutrient requirements resulting from a disease, disorder or medical condition. FSMP are placed on the market in plastic containers, some of which may be single use plastics. The products are specialised feeds and may require the use of delivery systems (tubes and giving sets) classified as medical devices to administer the products into the gastrointestinal tract. They are used in hospitals and also may be used within the patient’s home under medical supervision. The design of medical nutrition products and their packaging is very specific to their intended use in patients and takes account of: • Safety and sterility requirements for feeds; • Connectivity required with feed delivery systems; • Ease of use for patients, e.g. elderly patients; • Suitability and functionality of use in a healthcare setting. SNE understands, and seeks confirmation, that it is not the intention of this proposal to include medical nutrition products in its scope and that the proposed requirements for food or beverage containers, in terms of design, consumption reduction and/or separate collection do not apply to this product category, in the same way that the discontinuation of certain single use plastics does not include swabs or straws used in medical applications. SNE proposed amendments: The Directive should confirm that Medical Nutrition products (food for special medical purposes and associated delivery systems) are out of scope.
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Response to Revision of the Drinking Water Directive (RECAST 2017)

22 Mar 2018

SNE welcomes the Revision of the Drinking Water Directive (RECAST 2017), and the specific consideration given to the chlorate concentrations in drinking water and its contribution to the exposure for infants and toddlers (referring to the 2015 EFSA opinion conclusions on Chlorate in food). Chlorination of potable water used in food processing plays an essential role in the control of microbial, viral or parasitic pathogens and limits the occurrence of foodborne diseases. In the Revision of the Drinking Water Directive, the European Commission is proposing “to set the value for chlorate and chlorite at the stricter level of 0.25 mg/l, which is around 3 times lower than proposed by the WHO”. SNE welcomes this proposal aiming at reducing the levels of chlorate in drinking water and harmonizing – for the first time in the EU – the drinking water legislation on the presence of chlorate. (Chlorinated) water is an essential element in food production: - At farm level: water is used for irrigating fields: Chlorine-disinfected water is used for washing fresh products, cleaning facilities and at various stages of the production of fresh milk from which many ingredients are manufactured; - At material production level: water is used for cleaning, peeling, extracting and processing of raw materials into ingredients. Chlorinated water is used to maintain the hygiene status of the ingredients; - For (finished) food production: water from the municipalities is used by industry as an ingredient and also for processing. Additionally chlorinated water is used for cleaning, disinfection and hygiene maintenance; - At the consumer level: consumers use potable water to drink, reconstitute some powdered foods and cook at home; - Chlorate accumulates along the food production chain and cannot be removed from infant, follow-on formulae or processed foods for infants and young children. Taking these facts into consideration, SNE considers that the reduction of the levels of chlorate in drinking water is a necessary step prior to the setting of maximum levels for chlorate in food. For powdered foods, SNE would like to draw particular attention to the proposed level (0.25 mg/l), which – when used for the reconstitution of powdered foods with drinking water – would lead to levels in finished foods equal to – as a minimum – the proposed value for chlorate in drinking water (0.25 mg/l) – taking into account the drinking water contribution. This level would not be in line with the approach considered by Directorate General Health and Food Safety (DG SANTE), by which chlorate residues in food are classified as pesticides. As a consequence, foodstuffs containing chlorate residues originating from treatments with legally sanitized water containing up to 0.25 mg/l chlorate could lead to complaints by enforcement authorities at national level. In June 2017, the REFIT stakeholder platform submitted its opinion on Chlorate – requesting proportionate risk management measures regarding the presence of chlorate in food (see on the following link: https://ec.europa.eu/info/sites/info/files/xi10amultiple_use_chlorate.pdf). SNE looks forward to being consulted in the forthcoming consultations planned by the European Commission on the Revision of the Drinking Water Directive.
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Response to Fitness Check of the Water Framework Directive and the Floods Directive

16 Nov 2017

Additional material attached to the SNE contribution.
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Response to Commission Regulation on maximum levels for glycidyl esters in certain foods

19 Sept 2017

FEDIOL and SNE input to DG SANTE Feedback process on Commission Regulation on maximum levels for glycidyl esters in certain foods FEDIOL, the EU vegetable oil and protein meal industry, and SNE, Specialised Nutrition Europe, welcome the Commission consultation and the possibility to provide feedback. Both entities have engaged together extensively to address the issue of 3-MCPD esters (3-MCPDE) and glycidyl esters (GE). As a result, FEDIOL and SNE members have detailed work programs in place to reduce 3-MCPD and GE in their products for the infant and follow-on formula and baby food markets to the lowest achievable levels. Achieving the levels proposed represents a substantial step for both sectors, retroactive implementation of the Regulation to products lawfully marketed prior to the entry into force of MLs is simply not possible in practice. Work is indeed still required to fine-tune quality controls for all batches, ensure the full deployment of processes at each SNE members’ site and for each food products falling under those categories. FEDIOL and SNE therefore strongly call upon the inclusion of an explicit and pragmatic transition period to cover products lawfully placed on the market before the entry into force of the Regulation and until their date of minimum durability or use-by-date. Such explicit clause will ensure appropriate legal certainty, protection of Food Business Operators at all stages of placing the products on the market, and adequate time to adapt production processes, as clearly recognized in recital 7. FEDIOL and SNE can support the proposed maximum levels (MLs) for GE for infant and follow-on formulas and foods for special medical purposes intended for infants and young children until June 2019, and for vegetable oils and fats destined for the production of processed cereal-based foods and baby food for infants and young children. As regards GE MLs as from 1 July 2019, the majority of FEDIOL and SNE members believe that they would also be achievable by this date. Industry will therefore continue researching on further mitigation measures to ensure that these levels are reached by the set date. FEDIOL and SNE also look forward to continuing to provide feedback on 3-MCPD esters as soon as discussions on regulatory measures for these substances recommence.
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Response to Specific rules concerning food replacing the whole daily diet for weight reduction purposes

9 Mar 2017

Specialised Nutrition Europe (SNE) would like to reiterate its strong concerns on the Commission delegated regulation (EU) …/… supplementing Regulation (EU) 609/2013 as regards the specific compositional and information requirements for total diet replacement for weight control (TDRs). As mentioned on the European Commission page “Share your views”, SNE hopes that this “feedback will be taken into account by the Commission when further developing the act(s)”, as it will have severe negative impacts for the sector, while SNE and another industry group have been repeatedly highlighting them over the last years. TDRs are the most (if not the only) regulated food diet option on the markets. This is a situation that we greatly welcome, and have always supported – until now, where we are faced with the bizarre scenario of legislation effectively preventing us from manufacturing such products. Indeed, we fear that this Regulation – in its current form – will drive our members’ products out of the market. As a matter of fact, the proposed rules will have a strong negative impact on consumer acceptance, and restrict information to consumers in way which encourages them to turn from proven and safe TDR to unsafe weight-loss alternatives that are not scientifically substantiated and may even be harmful (1). SNE is particularly concerned by the following provisions of the act: - The composition criteria for protein and essential fatty acids: They are based on the relevant EFSA assessments (2). However, EFSA acknowledged itself the limitations of its scientific opinions on these products, recognising gaps in the science, the use of modelling, and the theoretical nature of the calculations made with regards to obese and overweight people. SNE is therefore calling upon EU decision-makers to consider these limitations and take into account other legitimate factors for setting appropriate criteria; - The prohibition of nutrition and health claims (NHC) for weight control products: TDRs are intended for overweight and obese adults to induce a substantial energy deficit and therefore weight loss. It is therefore essential that manufacturers are able to inform consumers about the benefits of these specific products, which are scientifically designed to help them manage their nutritional needs. Without proper information, consumers may opt for alternatives which are not nutritionally appropriate. In addition, “regular foods” bear NHC and this would create unfair discrimination with regards to products not specifically designed to meet the nutritional needs of overweight and obese adults; - The scope of these products limited to “healthy overweight or obese adults”: By specifying “…intended for healthy overweight and obese adults” (Article 4.1 (a)), the Regulation would by default exclude overweight and obese adults with existing conditions from access to the important, safe and beneficial treatments; while TDRs are recommended by several national and international scientific associations for the treatment of overweight and obese adults with comorbidities (3) (4). - If this act is adopted as it currently stands, the future EU rules on TDRs will contradict the international standard (CODEX STAN 203-1995). (1) Similar concerns were shared by MEPs: Francoise Grossetete (Written question E-004254-16) & Theodoros Zagorakis (Written question E-006959-15) (2) Two recently published EFSA opinions: - EFSA NDA Panel, 2015. Scientific Opinion on the essential composition of total diet replacements for weight control. EFSA Journal 2015;13(1):3957, 52 pp. doi:10.2903/j.efsa.2015.3957; - EFSA NDA Panel, 2016. Scientific opinion on Dietary Reference Values for choline. EFSA Journal 2016;14(8):4484, 70 pp. doi:10.2903/j.efsa.2016.4484. (3) Interdisziplinäre Leitlinie der Qualität S3 zur „Prävention und Therapie der Adipositas“ (AWMF-Register No. 050/001) (4)European Guidelines for Obesity Management in Adults, Obes Facts
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