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Total Diet Meal Replacements Europe

TDMR Europe

Total Diet Meal Replacements Europe (formerly known as the European Very Low Calorie Diet Industry Group) is the European trade body for manufacturers and distributors of total diet replacement and meal replacement products which provide weight loss programmes for the overweight and obese.

Lobbying Activity

Response to EU cardiovascular health plan

15 Sept 2025

Please find attached Total Diet & Meal Replacements Europe (TDMR Europe) submission to the EU cardiovascular plan initiative. TDMR Europe is the European trade body for manufacturers and distributors of formula diet products, including total diet replacements (TDRs) and meal replacements (MRPs) which provide weight loss and weight management programmes for the overweight and obese.
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Meeting with Aurelijus Veryga (Member of the European Parliament)

21 Nov 2024 · Towards an EU Strategy on Obesity: Prevention and Management Challenges

Meeting with András Tivadar Kulja (Member of the European Parliament)

20 Nov 2024 · Total diet replacement products

Response to Setting of nutrient profiles

3 Feb 2021

Total Diet & Meal Replacements Europe is grateful for the opportunity to comment on the Inception Impact Assessment concerning a revision of Regulation (EU) No 1169/2011 on the provision of food information to consumers. Whilst TDMR Europe welcomes the Farm to Fork Strategy and the Commission’s efforts with regard to providing better food information to consumers, the specific nature of total diet replacements (TDRs) and meal replacements (MRPs) and their specific composition must be considered before applying labelling schemes designed with regular food products in mind. In light of the specialist nature of these products, TDMR Europe asks the Commission to consider an exemption when setting nutrient profiles or any mandatory front of pack nutrition labelling. Please find our comments attached.
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Response to Farm to Fork Strategy

13 Mar 2020

TDMR Europe is the European trade body for manufacturers and distributors of formula diet products, including total diet replacements (TDRs) and meal replacements (MRPs), which provide weight loss and weight management programmes for overweight and obese people. TDMR Europe welcomes the Commission efforts on fighting obesity and related diseases, but wishes to make the following recommendations with regards to the F2F Strategy: - Support a science-based approach towards obesity management and evidence-based nutrition to provide consumers with healthy and effective weight loss options. - Ensure consumer safety by increasing controls on unregulated or non-compliant products that are easily accessed despite potential risks to health. - Review all available options not only to prevent but also to tackle obesity, including formula foods which have proven effective in tackling obesity and reversing type-2 diabetes. Support of research and science-based nutrition The formula diet industry is committed to supporting nutrition science and ensuring evidence-based formulation for its products. By consistently investing in scientific research and development there has been a wealth of recent evidence demonstrating the safety of TDRs and MRPs for consumers and their effectiveness in tackling obesity and related diseases. The F2F strategy must support an evidence-based approach to meeting the nutritional needs of obese individuals and must ensure appropriate research and innovation across the food chain. Food safety MRPs and TDRs are the most regulated, effective weight loss solution for overweight people looking to manage their weight in a healthy way that is proven to produce results. This is demonstrated in the extensive portfolio of scientific studies that have used TDRs and MRPs. TDMR Europe commends the Commission’s renewed commitment to food safety and would like to highlight that the safety of formula diet products is particularly relevant when compared with many other weight loss alternatives currently available – such as illegal products sold on the internet or nutritionally unsound diets. Although the EU has the highest food safety standards in the world, better enforcement of EU regulations is needed to ensure consumer safety. Reversal of the obesity epidemic Obesity prevalence has tripled in many European countries since the 1980s, and the number of those affected continues to rise at an alarming rate. Based on the latest estimates, up to 70% of the entire population is overweight, with 10 to 30% of the European adult population being obese. Over 40 serious health conditions are linked to obesity, ranging from type-2 diabetes to cardiovascular disease, osteoarthritis and an increased risk of cancer. Weight management through a healthy and sensible diet and healthy lifestyle choices is a commendable goal that should be a pillar of the F2F strategy, however, the strategy must also ensure that the focus remains on supporting the larger part of the EU population that is already obese and overweight, taking into account their different needs and circumstances. Public health initiatives have often focused on preventing obesity and have placed much less emphasis on those individuals who are already obese. While TDMR Europe supports regulators and the wider food industry’s efforts to make food products healthier, it is known that individuals find it exceedingly difficult to achieve weight loss with conventional foods while maintaining nutritional requirements, once daily consumption falls below 1200kcal. TDRs and MRPs are nutritionally complete and proven in high-quality scientific studies to deliver the amount of weight loss and weight maintenance needed for health benefits including diabetes remission. The Commission must review all available options proven to reduce obesity, including formula foods and ensure consumer knowledge and access to these programmes as an effective method to lose weight.
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Response to Specific rules concerning food replacing the whole daily diet for weight reduction purposes

17 Mar 2017

The European Very Low Calorie Diet Industry Group (VLCD IG) reiterates its concerns with the Commission’s draft Delegated Regulation(EU) ../..of XXX supplementing Regulation (EU) No 609/2013 of the European Parliament and of the Council(FSG Regulation) with regards to the specific compositional and information requirements for total diet replacement for weight control(TDR). This act has been prepared on the basis of a Scientific Opinion from the European Food Safety Authority(EFSA) published in January 2015, and following discussion with stakeholders, the Member States and the Joint Research Centre. If this act is adopted in its current form Very Low Calorie Diets(VLCDs) as a product category will likely disappear from the market: it would no longer be neither feasible nor commercially viable for operators to deliver a range of products to the levels of nutrients suggested. This is disproportionate and goes against the main objective of the FSG Regulation: enhancing consumer safety when undertaking weight loss programmes. It also contradicts the Commission’s Better Regulation agenda, imposing an unnecessary and disproportionate burden on our sector. The EFSA opinion states that there is no good experimental evidence to support some recommendations made and that they are based on theoretical calculations rather than solid evidence. Acknowledging these limitations, EFSA also suggests the Commission consider all relevant factors when drafting this act, including technological considerations. We are concerned that the act has not done this, by failing to consider technological issues with regards to the formulation and manufacturing of these products, plus other commercial issues. Following scientific analysis and product testing of products manufactured using the new levels of protein (75g) and essential fatty acids (11g for LA and 1.4g for ALA) proposed by the Commission, a number of severe food technological and feasibility problems have been found. These include issues with the taste, smell and palatability of the products as well as their shelf life (i.e. products go rancid much more quickly under the new suggested compositional criteria). This testing has also shown that making these products will lead to a sharp increase in production costs, which would inevitably be passed on to consumers. Ultimately, this would push consumers towards potentially unsafe alternatives and unregulated food diet options sold on the internet. This is likely to have wider implications for the public health policy sphere, as tackling obesity is increasingly becoming a focus of EU policy. In addition, the draft act states that TDR products shall not contain more than 250 mg of magnesium for the total daily ration. Such an intake is known to be associated with a higher risk of developing type 2 diabetes at a time when Europe and the rest of the world is facing rising rates for this condition. Paradoxically, preliminary, peer-reviewed scientific data shows the effectiveness of TDR in reversing type 2 diabetes using currently accepted and widely used formulations. Finally, TDR products will be prohibited from making health claims on the products. This means that consumer will not be provided with the full information on the nutritional and health benefits of the products, in particular with regards to weight loss. Other food products, such as meal replacement products, are allowed to make claims, whilst TDR - specifically formulated for overweight or obese people with the intention of weight loss - are not. Such a lack of information, combined with the increased cost of the products and the reduced palatability, will lead to the consumer looking for potentially unsafe alternatives. The VLCD IG therefore calls upon the Commission to consider the great deal of evidence submitted by the industry and to continue allowing consumers access to safe products, of the highest quality, and in line with international standards (CODEX STAN 203-1995).
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