Al32 26e PDF
Al32 26e PDF
Al32 26e PDF
CX 5/20.2 CL 2008/35-NFSDU
November 2008
FROM: Secretary,
Codex Alimentarius Commission,
Joint FAO/WHO Food Standards Programme, FAO,
Viale delle Terme di Caracalla,
00153 Rome, Italy
Fax: +39 06 570 54593
Email: codex@fao.org
SUBJECT: Distribution of the Report of the 30th Session of the Codex Committee on Nutrition and
Foods for Special Dietary Uses (ALINORM 09/32/26)
1. Guidelines for Use of Nutrition and Health Claims: Table of Conditions for Nutrient Contents
(Part B Provisions on Dietary Fibre) (ALINORM 09/32/26 para. 54 and Appendix II)
Governments and international organizations wishing to comment on the above text should do so in writing,
preferably by email to the above address before 1 April 2009.
2. Draft Advisory List of Nutrient Compounds for Use in Foods for Special Dietary Uses
Intended for Infants and Young Children: Section D: Advisory List of Food Additives for Special
Nutrient Forms: Provisions on Gum Arabic (Gum acacia) (ALINORM 09/32/26, para. 62 and
Appendix III)
Governments and international organizations wishing to comment on the above text should do so in writing,
preferably by email to the above address before 1 April 2009.
3. Draft Nutritional Risk Analysis Principles and Guidelines for Application to the Work of the
Committee on Nutrition and Foods for the Special Dietary Uses (ALINORM 09/32/26, para. 82 and
Appendix IV)
Governments and international organizations wishing to comment on the above text should do so in writing,
preferably by email to the above address before 1 April 2009.
The 30th Session of the Codex Committee on Nutrition and Foods for Special Dietary Uses
reached the following conclusions:
MATTERS FOR FINAL ADOPTION BY THE 32ND SESSION OF THE CODEX ALIMENTARIUS
COMMISSION:
The Committee:
- agreed to forward to the Commission the Draft Table of Conditions for Nutrient Content (Part B
Containing Provisions for Dietary Fibre) for adoption at Step 8 (ALINORM 09/32/26 para. 54 and
Appendix II);
- agreed to forward to the Commission the Draft Advisory List of Nutrient Compounds for Use in
Foods for Special Dietary Uses Intended for Infants and Young Children: Section D: Advisory List of
Food Additives for Special Nutrient Forms: Provisions on Gum Arabic (Gum acacia) for adoption at
Step 8 (ALINORM 09/32/26, para. 62 and Appendix III);
- agreed to forward to the Commission the Draft Nutritional Risk Analysis Principles and Guidelines
for Application to the Work of the Committee on Nutrition and Foods for the Special Dietary Uses
(ALINORM 09/32/26, para. 82 and Appendix IV);
- agreed to forward to the Commission the Proposed Draft Annex on Recommendations on the
Scientific Substantiation of Health Claims to the Codex Guidelines for Use of Nutrition and Health
for adoption at Step 5/8 with the recommendation to omit Steps 6 and 7 (ALINORM 09/32/26, para.
102 and Appendix V).
The Committee:
- agreed to consider how to proceed with new work on the revision of General Principles for the
Addition of Essential Nutrients to Foods (CAC/GL 9-1987); development of the separate Standard for
Cereal Based-Foods for Underweight Children; revision of the Guidelines on Formulated
Supplementary Foods for Older Infants and Young Children (CAC/GL 8-1991); and the development
of Nutrient Reference Values (NRVs) associated with increased or decreased risk of non-
communicable diseases at the next session of the Committee (paras 123-154).
The CCNFSDU refers some responses to the questions on several methods in the standard for Infant
Formula and Formulas for Special Medical Purposes Intended for Infants and the List of methods for
which advice of the CCMAS is sought (paras 17-21 and Appendix VI).
The Committee refers a level of 10 mg/kg of Gum Arabic (Gum acacia) to the CCFA for endorsement
as a coating agent for inclusion in Section D Advisory List of Food Additives for Special Nutrient
Forms in the Advisory List of Nutrient Compounds for Use in Foods for Special Dietary Use by
Infants and Young Children (CAC/GL 10-1979) (paras 55-62 and Appendix III).
The Committee refers the Draft Table (Provisions on Dietary Fibre including the definition of dietary
fibre, Appendix II, para. 48) and the proposed draft Annex on Recommendations on the Scientific
Substantiation of Health Claims to the Guidelines for Nutrition and Health Claims, para. 102, Appendix
V) for information by the CCFL.
TABLE OF CONTENTS
Paragraphs
INTRODUCTION ..................................................................................................................................................1
OPENING OF THE SESSION .............................................................................................................................. 2-3
DIVISION OF COMPETENCE ....................................................................................................................4
ADOPTION OF THE AGENDA (AGENDA ITEM 1) .............................................................................................. 5-8
MATTERS REFERRED BY THE CODEX ALIMENTARIUS COMMISSION AND/OR OTHER
CODEX COMMITTEES (AGENDA ITEM 2): .................................................................................................... 8-26
REVIEW OF CODEX COMMITTEE STRUCTURE AND MANDATES OF THE CODEX
COMMITTEES AND TASK FORCES .................................................................................................. 10-13
AMENDMENTS TO CODEX STANDARDS AND RELATED TEXTS ...................................................... 14-16
METHODS OF ANALYSIS IN THE CODEX STANDARD FOR INFANT FORMULA
AND FORMULAS FOR SPECIAL MEDICAL PURPOSES FOR INFANTS ................................................ 17-22
APPLICABILITY OF ADIS TO INFANTS AND YOUNG CHILDREN ...........................................................23
CODEX COMMITTEE ON FOOD LABELLING..........................................................................................24
ACTIVITIES FROM FAO/WHO OF INTEREST TO THE CCNFSDU .................................................. 25-26
GUIDELINES FOR THE USE OF NUTRITION CLAIMS: DRAFT TABLE OF CONDITIONS FOR
NUTRIENT CONTENTS (PART B CONTAINING PROVISIONS ON DIETARY FIBRE) AT STEP 7
(AGENDA ITEM 3) ....................................................................................................................................... 27-54
DRAFT REVISION OF ADVISORY LIST OF NUTRIENT COMPOUNDS FOR USE IN FOODS
FOR SPECIAL DIETARY USES INTENDED FOR THE USE BY INFANTS AND YOUNG
CHILDREN: SECTION D ADVISORY LIST OF FOOD ADDITIVES FOR SPECIAL NUTRIENT
FORMS PROVISIONS ON GUM ARABIC (GUM ACCACIA) AT STEP 7 (AGENDA ITEM 4)............................... 55-62
DRAFT NUTRITIONAL RISK ANALYSIS PRINCIPLES AND GUIDELINES FOR APPLICATION
TO THE WORK OF THE COMMITTEE ON NUTRITION AND FOODS FOR SPECIAL DIETARY
USES AT STEP 7 (AGENDA ITEM 5) ............................................................................................................. 63-82
PROPOSED DRAFT RECOMMENDATIONS ON THE SCIENTIFIC BASIS OF HEALTH CLAIMS
AT STEP 4 (AGENDA ITEM 6) ..................................................................................................................... 83-102
PROPOSED DRAFT ADDITIONAL OR REVISED NUTRIENT REFERENCE VALUES FOR
LABELLING PURPOSES IN THE CODEX GUIDELINES ON NUTRITION LABELLING AT STEP 4
(AGENDA ITEM 7) ................................................................................................................................... 103-122
DISCUSSION PAPER ON THE PROPOSAL FOR NEW WORK TO AMEND THE CODEX
GENERAL PRINCIPLES FOR THE ADDITION OF ESSENTIAL NUTRIENTS TO FOODS
(CAC/GL 09-1987) (AGENDA ITEM 8) ................................................................................................... 123-134
DISCUSSION PAPER ON THE PROPOSAL FOR NEW WORK TO ESTABLISH A STANDARD
FOR PROCESSED CEREAL-BASED FOODS FOR UNDERWEIGHT INFANTS AND YOUNG
CHILDREN (AGENDA ITEM 9).................................................................................................................. 135-151
OTHER BUSINESS AND FUTURE WORK ................................................................................................... 135-151
SUMMARY OF THE PROPOSAL TO REVISE THE CODEX GUIDELINES ON
FORMULATED SUPPLEMENTARY FOODS FOR OLDER INFANTS AND YOUNG
CHILDREN (AGENDA ITEM 10 (A))............................................................................................. 135-151
MATTERS RELATED TO CONSIDERATION OF THE WHO GLOBAL STRATEGY ON
DIET, PHYSICAL ACTIVITY AND HEALTH (AGENDA ITEM 10 (B).............................................. 152-154
DATE AND PLACE OF THE NEXT SESSION .......................................................................................................155
- viii -
LIST OF APPENDICES
Page
APPENDIX I LIST OF PARTICIPANTS ................................................................................................... 21
APPENDIX II GUIDELINES FOR THE USE OF NUTRITION CLAIMS: DRAFT TABLE OF
CONDITIONS FOR NUTRIENT CONTENTS (PART B CONTAINING
PROVISIONS ON DIETARY FIBRE AT STEP 8 .................................................................... 46
APPENDIX III DRAFT REVISION OF THE ADVISORY LIST OF NUTRIENT
COMPOUNDS FOR USE IN FOODS FOR SPECIAL DIETARY USES
INTENDED FOR THE USE BY INFANTS AND YOUNG CHILDREN:
SECTION D ADVISORY LIST OF FOOD ADDITIVES FOR SPECIAL
NUTRIENT FORMS AT STEP 8 .......................................................................................... 47
APPENDIX IV DRAFT NUTRITIONAL RISK ANALYSIS PRINCIPLES AND GUIDELINES
FOR APPLICATION TO THE WORK OF THE COMMITTEE ON NUTRITION
AND FOODS FOR SPECIAL DIETARY USES AT STEP 8...................................................... 48
APPENDIX V PROPOSED DRAFT RECOMMENDATIONS ON THE SCIENTIFIC BASIS
FOR HEALTH CLAIMS AT STEP 5/8 .................................................................................. 54
APPENDIX VI METHODS OF ANALYSIS FOR INFANT FORMULA AND FORMULAS FOR
SPECIAL MEDICAL PURPOSES INTENDED FOR INFANTS.................................................. 57
ALINORM 09/32/26 1
INTRODUCTION
1. The Thirtieth Session of the Codex Committee on Nutrition and Foods for Special Dietary
Uses (CCNFSDU) was held in Cape Town, South Africa from 3 to 7 November 2008 at the kind
invitation of the Government of South Africa in cooperation with the Government of Germany. The
Session was chaired by Dr Rolf Grossklaus, Director and Professor, the Federal Institute for Risk
Assessment, Berlin and co-chaired by Mrs Lynn Moeng, Director Nutrition, the South African
National Department of Health. The Committee was attended by 240 delegates, observers and
advisors representing 52 member countries, one member organization and 27 international
organizations.
OPENING OF THE SESSION
2. Ms Barbara Hogan, Minister of Health of the Republic of South Africa welcomed the
participants to Cape Town and indicated that it was an honor for South Africa to have been selected as
co-hosting country especially since this had allowed more African delegations to participate. She said
food insecurity, high rates of malnutrition and high food prices were big threats to consumers in Africa
and that a lot of efforts had been made in South Africa to ensure equitable health services to all
citizens and drew the attention of the delegates to the fact that participation in Codex work had helped
South Africa to develop science based regulations that would help to reach this goal. She also
informed the Committee that South Africa had implemented a successful food fortification
programme. Ms Hogan acknowledged the challenges before the Committee to develop science based
guidance for both developing and developed countries to ensure safe, good food for everyone and
stressed the importance of the work on a scientific basis for health claims and also of new work on a
Standard for Processed Cereal-Based Foods for Underweight Infants and Young Children. and wished
the delegates all the best in their deliberations.
3. Mr Bernhard Kühnle, Director General for Food Safety and Veterinary Affairs – Federal
Ministry of Food, Agriculture and Consumer Protection, Germany addressed the Committee on behalf
of the German Federal Minister, Ms Ilse Aigner and expressed his gratitude to South Africa for
offering to co-host the session. He said that the CCNFSDU had the predominant task to protect
consumers and especially those most vulnerable or with special needs such as infants and small
children. He pointed out three areas in which it was particularly important to reach consensus in the
Committee: (1) the contribution of the Committee to the implementation of the WHO Global Strategy
on Diet Physical Activity and Health; (2) the adoption on Nutritional Risk Analysis Principles for the
CCNFSDU; and (3) the work on a scientific basis for health claims to avoid that consumers can be
misled; and also stressed the responsibility of the Committee to develop new standards which would
ensure adequate nutritional supplements for underweight infants and young children.
Division of competence
4. Following Rule II.5 of the Rules of Procedure of the Codex Alimentarius Commission the
Committee was informed about CRD 11 on the division of competence between the European
Community (EC) and its Member States and noted that 14 Member States of the EC were present at
the current session.1
ADOPTION OF THE AGENDA (Agenda Item 1)2
5. The Committee agreed to the proposal to considered items 9 and 10 together as they were
closely interlinked.
6. The Committee also agreed to consider the outcome of the Physical Working Group held prior
to the session on issues related to the implementation of the WHO Global Strategy on Diet, Physical
Activity and Health under Agenda Item 10 “Other Business and Future Work”.
1
CRD 11 (Annotated Provisional Agenda on the Division of Competence between the European community
and its Member States according to Rule II paragraph 5 of the Codex Alimentarius Commission.
2
CX/NFSDU 08/30/1.
ALINORM 09/32/26 2
7. The Committee noted the considerable amount of comments received on the Draft Nutritional
Risk Analysis Principles and Guidelines for Application to the Work of the Committee on Nutrition
and Foods for Special Dietary Uses and agreed to establish a physical in-session working group led by
Australia and working in English only with the mandate to consider the text in square brackets and to
provide a revised document for consideration by the Committee.
8. With these modifications the Committee adopted the Provisional Agenda as the Agenda for
the Session.
MATTERS REFERRED BY THE CODEX ALIMENTARIUS COMMISSION AND/OR
OTHER CODEX COMMITTEES (Agenda Item 2)3
9. The Committee noted the matters referred by the 31st session of the Commission for
information and in particular the adoption of standards and related texts submitted by the CCNFSDU
as well as the approval of new work on the revision of nutrient reference values of vitamins and
minerals in the Guidelines on Nutrition Labelling (CAC/GL 2-1985).
Review of Codex Committee Structure and Mandates of Codex Committees and Task Forces
10. The Committee noted that the 60th Session of the Executive Committee4 and the 31st Session
of the Commission5 had discussed the work on nutrition in Codex when reviewing the Codex
committee structure and mandates of Codex committees and task forces and had found that the current
structure allowed tasks related to nutrition to be adequately covered in the CCFL and the CCNFSDU.
11. The Committee noted further the information given by FAO and WHO to the Executive
Committee and the Commission on discussions on a mechanism to provide scientific advice to the
CCNFSDU.
12. Regarding the update on progress of developing mechanisms for providing scientific advice to
the CCNFSDU, the Representative of WHO indicated that FAO and WHO were not yet in a position
to inform on a definitive joint mechanism, given the need for high-level policy decision and legal and
administrative process clearance within each Organization to establish a joint expert body. Both
Organizations indicated that they were very much committed to strengthen their roles in providing
scientific advice on nutrition-related matters and efforts were being made in WHO to strengthen its
present structure and capacity to provide scientific advice to Member States and to the Codex.
13. The Representative of FAO informed the Committee that the establishment of a joint
FAO/WHO Expert body could be expedited if CCNFSDU would request such a committee to provide
scientific advice. ustralia indicated its strong support for the establishment of such a body.
Amendments to Codex standards and related texts
14. The Committee noted that when adopting the Proposed Draft Code of Hygienic Practice for
Powdered Formulae for Infants and Young Children it had also revoked the Recommended
International Code of Hygienic Practice for Foods for Infants and Children (CAC/RCP 21-1979)
which had contained end-product microbiological specifications of advisory nature for a number of
products which are not contained in the new code.
15. This had created an inconsistency as the section on food hygiene in the Guidelines on
Formulated Supplementary Foods for Infants and Young Children (CAC/GL 08-1991) contains a
reference to the revoked CAC/RCP 21-1979.
3
CX/NFSDU 08/30/2-Rev; CX/NFSDU 08/30/2-Add.1 (Report of the electronic working group on methods of
analysis for infant formula and formulas for special medical purposes (CODEX STAN 72-1981), CX/NFSDU
08/30/2-Add.2 (Summary of activities from FAO/WHO of interest to the CCNFSDU), CRD 2 (Comments from
Malaysia and ISDI), CRD 12 (WHO/UNICEF/WFP/UNHCR Informal consultation on the management of
moderate malnutrition in under-5 children) and CRD 15 (Comments from the United States).
4
ALINORM 08/31/3, paras 27-38.
5
ALINORM 08/31/REP, paras 162-163.
ALINORM 09/32/26 3
16. The Committee noted that this matter was outside its mandate and decided to refer it to the
Committee on Food Hygiene for appropriate action.
Methods of Analysis in the Codex Standard for Infant Formula and Formulas for Special
Medical Purposes for Infants
17. The Committee recalled that the 29th Session of the Committee had agreed to establish an
electronic working group led by New Zealand to prepare a list of methods of analysis for infant
formulae for consideration by this session of the Committee.
18. The Delegation of New Zealand introduced the report of the electronic working group and
recalled that in preparing the list of methods of analysis it had been requested to review the methods of
analysis for provisions listed in Section 3.1 of the Standard for Infant Formula and Formulas for
Special Medical Purposes for Infants (CODEX STAN 72-1991) and to follow the Principles for the
Establishment of Codex Methods of Analysis in the Codex Procedural Manual, including the General
Criteria for the Selection of Methods of Analysis.
19. The electronic working group recommended that the Committee:
• Submit the methods contained in Table 1 of the report of the electronic working group to the
Committee on Method of Analysis and Sampling (CCMAS) for endorsement and inclusion in
the Recommended Methods of Analysis and Sampling (CODEX STAN 234) in the section
titled “Foods for Special Dietary Uses” with the description “Infant Formula” in the column
titled “Commodity Standard” with notes to explain that some methods are for specific forms
of the provisions in section 3.1 and that methods should include the units of expression when
it was part of the provision (see Appendix VI).
• Request advice from the CCMAS on the criteria for selecting Type II methods from a list of
Type III methods because the working group had not found an agreement on such selection
criteria. As an interim measure the working group had proposed some of the methods as Type
III for endorsement until clarification was received from the CCMAS how to select the
appropriate Type II methods; these methods are indicated as III* in the Appendix.
• Periodically review the methods in the proposed infant formula list in CODEX STAN 234 to
keep them updated.
• Consider whether to recommend methods for moisture content, total solids and ash which
were not in the original scope of the working group but which were needed to calculate
carbohydrates and calories.
20. In response to the questions raised by the 28th and 29th Session of the Committee on Methods
of Analysis and Sampling the working group proposed to reply that:
• Methods using microbioassay had been reviewed and more updated methods for total
carbohydrates (AOAC 986.25, determination by difference) and for fats (AOAC 989.05 and
ISO 8381│IDF 123:2008 or ISO 8262-1│IDF 124-1:2005) were being recommended;
• Vitamin C was expressed as ascorbic acid and the difference between the proposed methods
for Vitamins K, B12 and B6 was provided in the list of methods submitted for endorsement;
and
• A method for dietary fibre was not necessary to calculate the total energy as there was
insignificant indigestible carbohydrate in infant formula.
21. The Committee expressed its appreciation to the Delegation of New Zealand and the working
group for their work and after some discussion, agreed to follow the recommendations of the working
group and also to provide the responses to the questions posed by CCMAS as recommended by the
Working Group. It was noted that the method for total fats had been published as ISO 8381│IDF 123-
2008 and amended the list of methods accordingly. It was clarified that comments on the proposed
methods could be submitted to CCMAS for their consideration during the endorsement process.
ALINORM 09/32/26 4
22. The Committee considered the need to re-establish the electronic working group but decided
to first await a reply from the CCMAS.
Codex Committee on Food Additives
Applicability of ADIs to Infants and Young Children
23. The Committee noted the response by the Committee on Food Additives regarding questions
from the CCNFSDU on the applicability of an ADI for infants below 12 weeks of age. The
Committee also noted that WHO had no plan to update the scientific opinion on an ADI for infants
below 12 weeks at present. The Committee noted the report of the CCFA and also noted that it would
be desirable that WHO should update the Committee on this matter as new information became
available.
Codex Committee on Food Labelling (CCFL)
24. The Committee noted the work of the CCFL on the implementation of the WHO Global
Strategy on Diet, Physical Activity and Health and that this would be taken into account when
discussing the issue of nutrient reference values (Agenda Item 7) and the WHO Global Strategy
(Agenda Item 10b)
Activities from FAO/WHO of Interest to CCNFSDU
25. The Representative of the WHO referring to document CX/NFSDU 08/30/2-Add.2, informed
the Committee of the reports of scientific work undertaken and of several on-going and future work to
be completed in 2009 including the development of a FAO/WHO Procedural Manual for the
formulation and implementation of regional and country-specific food-based dietary guidelines
(FBDG) (scheduled for completion June 2009), and a joint WHO/UNICEF consultation to update the
guidelines for vitamin A supplementation with new scientific evidence (expected in 2009).
26. The Representative of the FAO added information on the FAO/WHO Expert consultation on
Fat and Fatty Acids in Human Nutrition which will be held in Geneva on 10 – 14 November 2008
where experts will develop recommendations on requirements for infants, children, adults and women
during pregnancy and lactation and review scientific evidence related to inadequate and excess intakes
of fats and fatty acids to health risks and benefits. The report of this consultation will be available in
early 2009. The Representative indicated that an expert consultation on Biodiversity and food
consumption and an expert consultation on risk-benefit-analysis is planned in 2009 and that the Food
Composition Study Guide to be published in 2009 is a distance learning tool and will allow learners to
acquire and evaluate their knowledge in food composition.
GUIDELINES FOR THE USE OF NUTRITION CLAIMS: DRAFT TABLE OF CONDITIONS
FOR NUTRIENT CONTENTS (PART B CONTAINING PROVISIONS ON DIETARY FIBRE)
AT STEP 7 (Agenda Item 3)6
27. The Committee recalled that its last session had agreed to return the Draft Table of Conditions
for Claims (dietary fibre) to Step 6 asking for comments and additional input on the definition,
conditions for claims and methods of analysis for dietary fibre in the light of the results of the
FAO/WHO scientific update of carbohydrates in human nutrition.
28. The Representative of WHO drew the attention of the Committee to the fact that following the
request for scientific advice, FAO/WHO had provided a recommendation on the definition of dietary
fibre derived from the Joint FAO/WHO expert consultation and the Joint FAO/WHO scientific update
on carbohydrates in human nutrition. However, in order to facilitate progress of the discussion the
Representative of WHO informed the Committee that Professor J. Cummings, as scientist participating
in the FAO/WHO carbohydrate consultation and scientific update, would suggest alternative wording
6
CL 2007/43-NFSDU; ALINORM 08/31/26, Appendix II, CX/NFSDU 08/30/3 (comments from Australia,
Costa Rica, Guatemala, New Zealand, AAF, AIDGUM, IDF, ILSI, ISDI); CX/NFSDU 08/30/3- Add.1
(comments of Brazil, South Africa); CX/NFSDU 08/30/3-Add. 2 (comments from Mali, Thailand, IFAC); CRD
3 (comments from Canada, European Community, India, Indonesia, Kenya, Philippines, United States of
America, CIAA).
ALINORM 09/32/26 5
for the definition, taking into account the new work and reports published by some Member States
since the 29th Session of the Committee.
29. Prof Cummings indicated that when considering the definition of dietary fibre, the expert
groups had reviewed existing definitions, including the currently proposed definition by this
Committee and that of the US National Academy of Sciences (Institute of Medicine 2005).
30. Recognising the need to move to an agreed definition of fibre by the Committee, Professor
Cummings noted three main areas where the proposed Codex definition and that of the Scientific
Update differed. The Codex definition includes the phrase “neither digested nor absorbed in the small
intestine”, a concept also incorporated into two other existing definitions of fibre, that of the US
National Academy of Sciences and of the European Community. Having pointed out that digestibility
is poorly defined and very difficult to measure, especially in the human small intestine, professor
Cummings stated that intrinsic plant cell wall polysaccharides were essentially not digested in the
human small intestine, and that this historical concept could remain as part of the definition.
31. However, included in the category of non-digestibility are the non α-glucan oligosaccharides
(DP 3-9) (non digestible oligosaccharides, NDO). The Scientific Update had felt strongly that NDO
should not be included in the definition of dietary fibre. This was because the Codex definition
includes the assertion that “Dietary fibre generally has properties such as: decrease intestinal transit
time and increase stools bulk; fermentable by colonic microflora; reduce blood total and/or LDL
cholesterol levels; reduce post-prandial blood glucose and /or insulin levels”. It was felt that there was
no convincing evidence that NDO had a significant effect on gut transit time or stool weight, on blood
lipids in healthy people, since they are not glycaemic carbohydrates, nor on the control of blood
glucose and insulin. Whilst they are fermented this was felt to be part of normal digestive physiology
and not something that conferred a specific health benefit. Therefore, inclusion of these water-soluble
low molecular weight carbohydrates was potentially misleading for the consumer. Nevertheless the
Joint FAO/WHO Scientific Update had acknowledged that NDO were important carbohydrates with
unique properties, likely to be shown of importance to other aspects of health after further research. In
such case, NDO should be recognized on its own right, but not as dietary fibre.
32. Professor Cummings indicated that the use of the terms “intrinsic”, “extrinsic”, “functional”
and “synthetic” in existing definitions, and the incorporation of this categorization of dietary fibre into
the Committee’s proposed definition as “carbohydrate polymers, which have been obtained from food
raw material by physical, enzymatic or chemical means” and “synthetic carbohydrate polymers”. The
Joint FAO/WHO Scientific Update had wanted the definition to be closely linked to health and felt
that the established epidemiological support for the health benefits of dietary fibre was based on diets
that contain fruits, vegetables and whole grain foods, which are rich in intrinsic plant cell wall
polysaccharides. Although isolated or extracted fibre preparations have been shown to have
physiological effects experimentally, these have not been translated into health benefits directly
because of a lack of epidemiological and longer term evidence. He therefore suggested that the
inclusion of categories of dietary fibre other than those intrinsic to the plant cell wall should be
required to show “a beneficial physiological effect demonstrated by generally accepted scientific
evidence” as specified in the definition of the European Community.
33. The Committee considered proposed changes and made the following comments and
conclusions.
34. The Delegation of South Africa indicated that in order to protect consumers from misleading
claims carbohydrate polymers obtained from raw materials by enzymatic or chemical means and
synthetic carbohydrate polymers could be allowed only if beneficial physiological effects were
demonstrated by scientific evidence to provide a ‘long-term’ benefit to health.
35. The Delegation of Canada supported to link the definition for dietary fibre to physiological
effects and explained that the fact that a substance was not digested or absorbed in the small intestine
did not necessarily mean that it had the properties of a dietary fibre. Therefore the inclusion of such
compounds needed to be justified by data on physiological efficacy. The delegation also proposed to
ALINORM 09/32/26 6
move the text on fermentability by colonic microflora from the section on properties to the definition
section as this was a defining characteristic of dietary fibre.
36. Some delegations from developing countries were of the view that their dietary
recommendations were designed to promote consumption of fruits, vegetables and whole grain cereal
foods which were naturally rich in dietary fibre and that inclusion of the concept of synthetic and
isolated fibres might mislead consumers regarding potential health benefits and supported the
approach proposed by the WHO.
37. Some observers were of the view that the concept of independent scientific evaluation or
review to obtain or validate scientific data for health benefits of fibre should be stressed.
38. The Delegation of the European Community proposed to simplify and clarify the draft Codex
definition as proposed in CRD 3 so that Dietary fibre means carbohydrate polymers with three or
more monomeric units, which are neither digested nor absorbed in the small intestine and belong to
the following categories as described in the Codex definition, to add “edible” to more precisely
characterize the nature of carbohydrate polymers and also to add ‘beneficial” before “physiological
effect” and to move the section on properties as preamble to the definition and that the criteria to
quantify physiological effects or evaluate demonstrated scientific evidence should be left to national
competent authorities to decide. Some delegations and observers supported this proposal as a
pragmatic way forward.
39. Several other proposals were put forward to amend the definition, however there was no
agreement to accept any of these proposals, therefore after a long discussion the Committee decided to
ask small drafting group to find an appropriate wording on how to amend the definition.
40. The Delegation of Thailand, on behalf of this drafting group, informed the Committee that a
revised version had been prepared in which the entire section on properties was deleted and that the
definition was much simplified to specify that dietary fibre meant carbohydrate polymers which were
not hydrolysed in the small intestine of humans with degree of polymerization not lower than three
and that the decision on whether to include carbohydrates with the degree of polymerization from 3 to
10 should be left to national authorities to decide. The definition took into account that three main
categories of carbohydrate polymers were distinguished: (a) naturally occurring carbohydrate
polymers; (b) carbohydrate polymers obtained from raw material by physical, enzymatic or chemical
means and (c) and synthetic polymers with the understanding that physiological effect and benefit to
health for categories (b) and (c) should be demonstrated by generally accepted scientific evidence to
competent authorities.
41. The Delegation of the United States was of the view that before finally agreeing on a dietary
fibre definition a number of questions presented in their comments (CRD 3) should be considered.
For example the scientific evidence to indicate that a revised Codex definition was needed to improve
public health; on whether international consensus on the terms and definitions used exists; or on the
presence of validated methods or validated procedures for combining methods to measure total fibre
content based on proposed definitions should be clarified.
42. The Committee noted that the major unresolved issue was the inclusion of oligosaccharides
with a degree of polymerization from 3 to 10 and had a long discussion on this matter.
43. Some delegations were of the view that these carbohydrates should not be included in the
definition as they did not have the properties traditionally attributed to dietary fibre and felt that their
inclusion might mislead consumers.
44. Other delegations and some observers believed that these carbohydrates were naturally
associated with dietary fibre and might have some health benefits and therefore should be included in
the definition
45. After some discussion, the Committee agreed to refer to monomeric units rather than to degree
of polymerization and that the decision on whether to include carbohydrates with monomeric units
from 3 to 9 should be left to national authorities to decide. As a consequence the sentence referring to
exclusion of mono and disaccharides was deleted from the definition.
ALINORM 09/32/26 7
7
ALINORM 08/31/26, Appendix V; CX/NFSDU 08/30/4 (comments from Australia, Guatemala, AIDGUM);
CX/NFSDU 08/31/4-Add.1 (comments from the European Community); CRD 4 (comments from Brazil, India,
Indonesia, Kenya, Mali, Philippines).
ALINORM 09/32/26 9
8
ALINORM 08/31/26, Appendix VI; CX/NFSDU 08/30/5 (comments from Australia, Brazil, Costa Rica,
Ghana, Guatemala, Malaysia, New Zealand, the Philippines, South Africa, Thailand, the United States, CRN,
IDF and NHF); CX/NFSDU 08/30/5-Add.1 (comments from Argentina, the United States and IADSA); CRD 5
(comments from Canada, the European Community, India, Indonesia, Kenya, Malaysia and the Philippines);
CRD 21 (Text revised by the in-session working group)
ALINORM 09/32/26 10
72. There was a lengthy discussion on the wording of paragraph 8 on how to better describe the
food constituents of primary interest in nutritional risk analysis as well as the risk of increasing the
adverse effects of the food matrix. The Committee decided to leave the introductory phrase and the
first two bullets as originally drafted, to delete the third bullet and to insert a new paragraph to read:
“When favourable effects of the nutrient or related substance of primary interest are being assessed,
consideration should be given to whether the food matrix could increase the risk of an adverse health
effect.”
73. In paragraphs 9 and 10, the first occurrence of the term “risk analysis” was replaced with “risk
assessment” to clarify that “quantitative” only related to this part of risk analysis.
Section 4 – Definitions
74. Several proposals were made to amend definitions on intake (exposure) assessment, nutrient-
related hazard and homeostatic mechanism however after some discussion, the Committee decided to
leave them as originally drafted.
75. Concerning the proposal to delete the definition for dose response assessment because it was
not used in the text, the Committee felt that it was useful to retain it as it had been adapted from the
definition in the Codex Procedural Manual to show how it could be applied in nutritional risk analysis
and that this useful information should not be lost.
Section 5 – Principles for Nutritional Risk Analysis
76. In paragraph 17 the term “relevant route(s) of exposure” was replaced with “relevant source(s)
of intake”
77. The Committee discussed how to proceed with paragraph 29 as text related to the impact of
nutritional risk management decisions on consumers’ behaviour had been left in square brackets with
three different options proposed by the in-session working group to address the issue.
78. After some discussion, the Committee decided to insert a new paragraph after paragraph 29 to
read: “Nutritional risk management decisions should take into account their impact on dietary patterns
and consumer behaviour. Such information should be supported by relevant research.”
79. In paragraph 31 the word “Risk” was included before “Analysis”.
Section 6 – Selection of Risk Assessor by CCNFSDU
80. In paragraph 33 the words “relevant Codex subsidiary body” were replaced with
“CCNFSDU”.
Section 7 – Review Process
81. The Committee decided to delete this section as relevant guidance on this matter was included
in the Procedural Manual.
Status of the Proposed Draft Nutritional Risk Analysis Principles and Guidelines for Application
to the Work of the Committee on Nutrition and Foods for the Special Dietary Uses
82. The Committee agreed to forward the Proposed Draft Nutritional Risk Analysis Principles and
Guidelines for Application to the Work of the Committee on Nutrition and Foods for the Special
Dietary Uses as amended during the session to the Committee on General Principles (CCGP) for
endorsement and to the 32nd Session of the Codex Alimentarius Commission for adoption at Step 8
(see Appendix IV).
ALINORM 09/32/26 11
9
CX/NFSDU 08/30/6; CX/NFSDU 08/30/6-Add.1 (comments from Brazil, Guatemala, United States of
America, EHPM, IADSA, ISDI, WSRO); CRD 1 (Report of the ad hoc Physical Working Group on Health
Claims, Nutrient Reference Values and Matters Related to Consideration of the WHO Global Strategy on Diet,
Physical Activity and Health); CRD 6 (comments from European Community, India, Indonesia, Kenya,
Malaysia, Mexico, Philippines, EFLA); CRD 17 (Proposals from the ad hoc Physical Working Group on Health
Claims, Nutrient Reference Values and Matters Related to Consideration of the WHO Global Strategy on Diet,
Physical Activity and Health); CRD 19 (comments from IADSA).
ALINORM 09/32/26 12
for breastmilk substitutes, independently funded research was needed and that the reviews of the
health claims should be conducted by independent bodies.
92. The Committee was of the view that these aspects were sufficiently covered in the parent
document and by adding a reference to The Working Principles for Risk Analysis for Food Safety for
Application by Governments in a footnote to the title of the Annex.
93. The Committee agreed with other editorial amendments proposed in paragraphs 5 (b), (c), (d),
(e) and (f) (new 3.1 (a), (b), (c), (d) and (e).
3.2 Criteria for the substantiation of health claims
94. Paragraph 7(b) (new 3.2.2 (b)) was amended to ensure that epidemiological studies used as
evidence should provide a consistent body of evidence from well-designed studies, and to include
“authoritative statements” in addition to evidence-based dietary guidelines to enable all categories of
evidence generally available to be taken into account to substantiate some health claims.
95. One Observer highlighted the dilemma of scientific substantiation by human trials and the
ethical considerations relating to trials on infants under 12 weeks and possibly one year, and proposed
to include a recommendation in this paragraph that health claims should not be permitted for foods for
infants and young children because they cannot be substantiated according to the criterion.
96. The Committee however felt that these concerns were already taken into account by other
criteria in the text.
3.3 Consideration of the evidence
97. The Committee amended the second sentence of paragraph 10 (new 3.3.3) by inserting “or
mediates the effect” after “target site” for purposes of clarity and also inserted an example “forms of
the constituents” to clarify what was meant by factors that could affect absorption or utilization of a
constituent for which a health claim was made.
98. The Committee agreed to insert a new paragraph after paragraph 11 (new 3.3.5) to clarify
under what conditions studies should be excluded from further review and exclusion from relevant
scientific data.
99. One Observer proposed to include a reference also to a “special diet required for a specific
disease or condition” in addition to a balanced diet in paragraph 12 (new 3.3.6). The Committee
however was of the view that such a reference would not be appropriate as health claims were directed
to a generally healthy population and the Guidelines themselves were applicable to all foods. The
Committee agreed to amend this section to indicate that the evidence should provide information
relating to a balanced diet as it related to the target population for which the claim was intended.
5 Re-evaluation
100. The Committee agreed with the principle that health claims should be re-evaluated and agreed
to indicate that such re-evaluation should be undertaken by national competent authorities either
periodically or following emergence of significant new evidence.
Conclusion
101. In view of the considerable progress made on the document, the Chairperson proposed to
advance the document to Step 5/8 with the omission of Steps 6 and 7 for adoption by the next Session
of the Commission. The Delegation of Australia, supported by the Observer from NHF, however
expressed its concern with this proposal in view of the considerable changes made to the text and
proposed that the document be advanced for adoption at Step 5 to allow more time for its
consideration.
ALINORM 09/32/26 13
10
CX/NFSDU 08/30/7; CX/NFSDU 08/0/7-Add. 1 (comments from United States of America and South
Africa); CRD 1 (Report of the Physical Working Group); CRD 7 (comments from the European Community,
Indonesia, Kenya, Philippines); CRD 12 (WHO/UNICEF/WFP/UNHCR Information on Informal Consultation
on management of moderate malnutrition in under-5 children); CRD 13 (Summaries of the comments from
EWG members (Australia, Brazil, China, Costa Rica, European Community, Malaysia, New Zealand,
Switzerland, CRN, IADSA and NHF) and recommendations); CRD 18 (Results of the Physical Working Group
on NRVs).
11
International Harmonization of Approaches for Developing Nutrient-Based Dietary Standards, Janet King and
Cutberto Garza, Guest editors, Food and Nutrition Bulletin, vol 28, No1, 2007.
ALINORM 09/32/26 14
amendments to Option 2 to read: Individual Nutrient Level (INLX)12, the estimated nutrient intake
value that meets the requirements of most (98 percent) of an apparently healthy specific sub-group of
the population (e.g., considering the subgroup’s sex and lifestage such as age and
pregnancy/lactation). In cases where there is an absence of an established INLX for a nutrient for a
specific sub-group, it may be appropriate to consider the use of other reference values or ranges that
have been established by authoritative scientific bodies. It is necessary to review how these values
were derived on a case-by-case basis.
Consideration of different age-sex specific values
109. The Committee had a long discussion on how general population NRVs should be determined.
Some delegations indicated that they were using the Option 1 i.e. the highest values from different
age-sex groups while some other delegations were of the view that the most preferred should be
Option 2: which considers the specific sub-group population weighted means such as means of adult
males and females values.
110. Some delegations drew the attention of the Committee to their experience in arriving at NRVs
and indicated that in order to protect consumers an intermediate decision between options for some
nutrients might be required.
111. To the concerns expressed by the Delegation of China that for example different values for
vitamin A are needed, the Chairperson clarified that the calculated differences between the two
options were negligible. Generally NRVs should compare the nutrient content of the food items in the
standardised form to avoid misleading of consumer.
112. The Delegation of Australia proposed an approach to choose an average of male and female
nutrient values from FAO/WHO Vitamin and Mineral Requirements in Human Nutrition (2004) from
one population group which would reasonably represent all population groups over three years. The
following wording for Option 2 was proposed: Average mean value for chosen reference population
group that reasonably represents the general population above 3 years of age, such as means of adult
male and female values.
113. The Committee noted that practical implications of choosing one approach were not clear and
that it was difficult to decide on how this option could work in practice.
114. The Delegation of the United States requested that further consideration be given to both
options presented by the working group for age-sex specific once values were calculated to illustrate
the implications of each choice. Other delegations indicated that this information could be useful.
115. The Committee decided to put both options in square brackets for further consideration.
Consideration of upper levels of intake
116. The Committee noted the proposal to make consideration of the establishment of NRVs more
flexible, however after some discussion agreed to retain the text as proposed by the working group.
117. The Committee noted that the proposed new definitions including Upper Nutrient Level
(UNL) that appeared in this section were placed in a footnote and agreed that it would be more useful
to move the terminology from the footnote into a new section on definitions.
Selection of suitable data sources to establish NRVs
118. After some discussion the Committee agreed that recent and relevant FAO/WHO values
would be the basis for NRVs and if such FAO/WHO values are not available, relevant and recent
values from recognized authoritative scientific bodies other than FAO/WHO could be used.
119. In response to the question from the Delegation of Japan regarding the representativeness of
data used to develop the FAO/WHO Vitamin and Mineral Requirements in Human Nutrition (2nd
12
“Individual Nutrient Level (INLX)” is used as the generic term. Different countries may use other
terminologies for this concept: for example, Recommended Dietary Allowance (RDA), Recommended Daily
Allowance (RDA), Reference Nutrient Intake (RNI), Population Reference Intake (PRI), or Ingestion Diaria
Recomendada (IDR).
ALINORM 09/32/26 15
edition, 2004), the Representative of WHO informed the Committee that this document used data from
around the world which was available to the experts at that time.
120. The Committee considered whether the actual NRVs should be elaborated by FAO/WHO or
would be determined by the CCNFSDU. The Committee noted that an assessment part containing
actual human requirements for vitamins and minerals was available from FAO/WHO Vitamin and
Mineral Requirements in Human Nutrition (2004), therefore agreed that elaboration of actual NRVs
was the responsibility for the Committee.
121. The Committee noted that the General Principles for Establishing Vitamin and Mineral NRVs
especially to determine which options should be used for different age-sex groups needed more
elaboration, therefore agreed to re-establish the electronic working group lead by Republic of Korea to
prepare a revised version of the document based on decisions made at the current session with the
understanding that the Delegation of Australia would help in calculating actual values of NRVs based
on options 1 and 2 using date from FAO/WHO Vitamin and Mineral Requirements in Human
Nutrition (2004). Working group will be opened to all interested parties and work in English only.
Status of the General Principles for Establishing Nutrient Reference Values of Vitamins and
Minerals for General Population
122. The Committee agreed to return the General Principles for Establishing Nutrient Reference
Values of Vitamins and Minerals for General Population to Step 2/3 for redrafting by the above
electronic working group to prepare a revised version for circulation for comments and consideration
by the next session of the Committee.
DISCUSSION PAPER ON THE PROPOSAL FOR NEW WORK TO AMEND THE CODEX
GENERAL PRINCIPLES FOR THE ADDITION OF ESSENTIAL NUTRIENTS TO FOODS
(CAC/GL 09-1987) (Agenda Item 8)13
123. The Committee recalled the request of the last session of the committee that the Delegation of
Canada should prepare a revised discussion paper narrowing its scope in light of the comments made
at that session.
124. The Delegation of Canada introduced their revised discussion paper taking into account
comments made at the last session. The delegation indicated that since the adoption in 1987 of the
General Principles and their last amendment in 1991, changes in lifestyle and dietary habits have led
to an increased availability of foods with added vitamins and mineral nutrients that go beyond the
purposes set out in Section 3 – “Basic Principles” of the General Principles: restoration; nutritional
equivalence of substitute foods; fortification; and ensuring the appropriate nutrient composition of a
special purpose food.
125. The Delegation explained that there were concerns that the General Principles no longer
adequately addressed current practices, limited consumer choice and the development of new products
and could result in barriers to trade that are not justified based on safety considerations.
126. The Delegation proposed to revise the General Principles and in particular the Basic Principles
to expand their applicability to include the discretionary addition of vitamins and mineral nutrients to
foods for purposes beyond the prevention or correction of demonstrated deficiencies. The Delegation
stressed that it was not their intent to replace the Basic Principles which have a public health basis but
to extend them to also set out principles for the safe discretionary addition of vitamin and mineral
nutrients to acknowledge current practices and to ensure that they are safe.
127. The Delegation recommended using a risk-based approach including for example: restrictions
for which foods it would be prohibited to add vitamins and mineral nutrients at the discretion of the
manufacturer (e.g. beverages exceeding a certain alcoholic content, foods considered to have
negligible nutritional value; foods exceeding a certain level of risk increasing nutrients etc.); which
nutrients could be added; and maximum and minimum levels to which permitted nutrients could be
added.
13
CX/NFSDU 08/30/8; CRD 8 (Comments from the European Community).
ALINORM 09/32/26 16
128. The Delegation pointed out that in carrying out the revision, changes would be needed to the
“intent” of the General Principles and to the Basic Principles to make provision for discretionary
nutrient addition in addition to the four current purposes. Additionally a new Section to address the
prevention of the indiscriminate addition of vitamins and mineral nutrients would have to be
developed.
129. The Delegation also pointed out the need that the applicability of the General Principles to
non-traditional or indirect addition of essential nutrients should be affirmed within the General
Principles as these methods were of growing importance. Consideration should be given to the need
for any potential additional restrictions for this type of nutrient enhancement e.g., its prohibition for
certain types of foods.
130. The Delegation of the European Community warmly welcomed the suggestion to include the
concept of discretional fortification, however reiterated its position that it does not consider
appropriate at this stage to enlarge the scope of the General Principles beyond the direct addition of
nutrients to foods and that biofortification as well as other forms of indirect fortification should be
eventually addressed by a separate activity due to their complexity. The Delegation suggested a
number of changes to the draft project document in accordance with their comments in CRD 8 and
with these amendments could support initiation of new work.
131. The Delegation of New Zealand supported the revision of the General Principles as outlined
by Canada and amended by the European Community but felt that the issue of non-traditional addition
of nutrients was an area of work that needed to be addressed at some point.
132. The Delegation of the United States appreciated that Canada had made some revisions to their
proposal but noted that it had had very little time to review it. The Delegation was of the opinion that
the document as presented did not seem to be consistent with its stated purpose and still included areas
where it might not be possible to reach agreement. The Delegation did not support new work at this
moment but could support further efforts to narrow the focus so that the work was more clearly
defined and did not contradict the principles of fortification. The Delegation supported by Australia
suggested continuing to develop the proposal in an electronic working group in order to give more
time to study the issue and receive comments from more members.
133. The Delegation of Norway supported the revision of the General Principles but considered
that the primary reason for fortification should be a demonstrated need in the population and any
revision of the General Principles should take this aspect into account.
134. The Committee agreed to establish an electronic working group led by Canada and working in
English only to revise the document in line with the comments made at the Session and for
consideration by the 31st Session of the CCNFSDU.
DISCUSSION PAPER ON THE PROPOSAL FOR NEW WORK TO ESTABLISH A
STANDARD FOR PROCESSED CEREAL-BASED FOODS FOR UNDERWEIGHT INFANTS
AND YOUNG CHILDREN (Agenda Item 9)14
OTHER BUSINESS AND FUTURE WORK
SUMMARY OF THE PROPOSAL TO REVISE THE CODEX GUIDELINES ON
FORMULATED SUPPLEMENTARY FOODS FOR OLDER INFANTS AND YOUNG
CHILDREN (Agenda Item 10a)15
135. The Committee recalled its earlier decision to consider items 9 and 10 together since the two
items were interlinked (see para. 5).
14
CX/NFSDU 08/30/9; CRD 9 (comments from Mali); CRD 12 (prepared by WHO); CRD 20 (comments from
IBFAN).
15
CX/NFSDU 08/30/10; CRD 12 (prepared by WHO); CRD 14 (Technical support paper on separate Codex
Standard for Processed Cereal-based Foods for Underweight Infants and Young Children for Developing
Countries).
ALINORM 09/32/26 17
136. The Committee recalled that at its last session it had agreed that the Delegation of India with
assistance from other interested parties would revise the document presented at that session and
prepare a more structured project document for consideration by this session of the Committee.
137. The Delegation of India introduced their revised proposal (CX/NFSDU 08/30/9) and
explained that a separate standard for processed cereal-based foods for underweight infants and young
children was necessary to address the needs of the large numbers of underweight infants in developing
countries.
138. The Delegation emphasized that the problem of malnutrition was intergenerational in nature.
The problem of iron deficient anaemia was widely prevalent in both children under five years of age
and in women. In order to address this problem India is implementing a scheme of Integrated Child
Development Services (ICDS) under which around 84 million children, pregnant women and lactating
mothers are provided with supplementary nutrition, immunization and vaccination. However, 43% of
children in India are still malnourished.
139. The Delegation further explained that when complementary foods were introduced to infants
after 6 months of age, their energy requirements are not completely met by breast milk. Therefore,
adequate intake of energy, protein and other nutrients is required through complementary food of
adequate nutrient level for normal growth of children.
140. The Delegation explained that the intention of the proposed new standard was to address three
main components: 1) cereal content, 2) protein content and 3) energy density. The Delegation further
emphasized that they did not intend to reopen discussions on the already adopted Standard for
Processed Cereal-Based Foods for Infants and Young Children (CODEX STAN 74-1981).
141. The Delegation urged the Committee to consider this proposal separately from the proposal of
Ghana, which also dealt with a strategy to reduce malnutrition but with a different approach namely to
introduce a new category of fortified food supplements to the Guidelines on Formulated
Supplementary Foods for Older Infants and Young Children (CAC/GL 08-1991) as a strategy to
improve the quality of home made foods.
142. The Delegation of Ghana introduced their proposal (CX/NFSDU 08/30/10) and agreed that it
differed from the proposal from India, while also having the goal of reducing malnutrition in infants
and young children. The Delegation informed the Committee that in Ghana, infants were generally
exclusively breastfed until the age of 6 months and did generally well until that age. Problems
occurred after this period when they started receiving complementary foods which in most cases were
generally low in energy and nutrients including minerals and vitamins.
143. The Delegation explained that their proposal was to introduce a new category of foods to the
Guidelines for Formulated Supplementary Foods for Older Infants and Young Children (CAC/GL 08-
1991) to ensure the safety and efficacy of these foods and prevent their misuse. The Delegation stated
that their proposal was restricted to the revision of Section 6 of the Guidelines to reflect new
information and evidence of energy needs for breastfed children.
144. The Representative of the WHO informed the Committee of the Joint
WHO/UNICEF/WFP/UNHCR technical meeting on the management of moderate malnutrition in
children under 5 years of age held in Geneva (30 September – 3 October 2008) with the overall aim to
answer questions on the type of diets to be recommended to feed moderately malnourished children.
The Representative said further that the report of this meeting would be released in early 2009
containing recommendations on the formulation, effectiveness, and efficacy of diets and food
supplements to be given to moderately malnourished children. The Representative also informed the
Committee that WHO had been asked to form an expert advisory group in collaboration with other
agencies (UNICEF, WFP and Codex) within the next 6 months to develop specifications for food
supplements for moderately wasted children based on recommendations formulated during this
meeting which could possibly be of assistance to both Ghana and India in the development of their
proposals to the CCNFSDU.
ALINORM 09/32/26 18
145. The Representative was also of the opinion that the two proposals should be considered
separately as the Ghana proposal aimed at developing complementary food supplements that can be
made without cereals, while the India proposal was for cereal-based foods.
146. A number of delegations expressed their support for both proposals and for considering them
separately, while a number of other delegations supported considering them together.
147. The Delegation of Thailand proposed to consider developing an Annex to the Standard for
Processed Cereal-based Foods for Infants and Young Children, rather than a new separate standard to
address the proposal of India.
148. Some Observers cautioned against the development of a new standard as proposed by India,
since several standards already existed and agreed to the proposal made by Thailand. The Observers
indicated further that foods referred to in the two proposals were usually distributed by aid agencies
and were not commercially available. The Observers also expressed concern that such products if
introduced commercially could damage breastfeeding programmes and reduce the use of traditional
foods.
149. The Delegation of the European Community while acknowledging that the two proposals
intended to tackle very serious problems associated with malnutrition and under-nourishment, noted
that several questions remained on both proposals such as (a) who the intended population for the
products were, (b) that the proposal of Ghana targeted specifically breastfed infants and did not
address the situation of non-breastfed children, (c) that the true nature of these cereal-based foods or
supplements was unclear (d) that the composition requirements of these foods needed to be clarified as
well as the channels for distribution of these products (commercially available or not) and if
commercially available, how risk of confusion by potential users would be avoided and how the work
of WHO/UNICEF/WFP/UNHCR could contribute to the consideration of the proposed work. The
Delegation also asked that consideration should be given to the options available to the Committee to
take forward this work within the Codex process.
150. Some Delegations were of the view that before proceeding with the request for new work on
these two distinct proposals, implications of the above concerns should be clarified in more detail for
both proposals.
151. The Committee agreed to establish two electronic working groups, led by Ghana and India
respectively to prepare revised proposals taking into account the comments and concerns above for
consideration by the next session of the Committee. The electronic working groups will be open to all
members and observers and work in English only.
MATTERS RELATED TO CONSIDERATION OF THE WHO GLOBAL STRATEGY ON
DIET, PHYSICAL ACTIVITY AND HEALTH (Agenda Item 10b)16
152. The Committee noted the report of the ad hoc Physical Working Group and agreed with the
recommendation that the Committee should not delay consideration of new work on the development
of NRVs associated with increased or decreased risk on non-communicable diseases (CRD 1) but did
not consider how to proceed in this respect due to time constraints.
153. The Committee therefore agreed to convene a physical working group to be led by the United
States of America and Thailand, open to all members and observers and working in English, French
and Spanish that would meet prior to the next session of the Committee and:
• would develop principles and criteria for the development of NRVs for nutrients associated
with risk of non-communicable disease; and
• based on the agreed upon principles and criteria, to select and prioritize nutrients for
development of NRVs.
16
CRD 1 (Report of the ad hoc Physical Working Group on Health Claims, Nutrient Reference Values and
Matters Related to Consideration of the WHO Global Strategy on Diet, Physical Activity, and Health).
ALINORM 09/32/26 19
154. The Committee agreed that the Delegations of the United States of America and Thailand will
prepare a background paper well in advance of the next session of the Committee for circulation to
members and observers for comments. The background paper and comments will be considered by
the above physical working group in developing their proposals.
DATE AND PLACE OF NEXT SESSION (Agenda Item 11)
155. The Committee was informed that its 31st Session would take place in Germany from 2 to 6
November 2009, subject to confirmation by the Host Government and the Codex Secretariat.
ALINORM 09/32/26 20
Appendix I
LIST OF PARTICIPANTS
LISTE DES PARTICIPANTS
LISTA DE PARTICIPANTES
CHAIRPERSON/PRÉSIDENT/PRESIDENTE
Dr Rolf Grossklaus
Director and Professor
Federal Institute for Risk Assessment (BfR)
P.O. Box 33 00 13
14191 Berlin,
Germany
Tel: +49 (30) 8412 – 3230
Fax: +49 (288) 99 529 – 4965
E-Mail: ccnfsdu@bmelv.bund.de
CIAA - CONFÉDÉRATION DES INDUSTRIES AGRO- ESPGHAN - EUROPEAN SOCIETY FOR PAEDIATRIC
ALIMENTAIRES DE L'UE GASTROENTEROLOGY, HEPATOLOGY AND NUTRITION
Miss Elena Cogalniceanu Prof Dominique Turck
Manager Consumer Information, Diet and Health Professor of Pediatrics
CIAA University of Lille
43 Avenue des Arts European Society of Gastroenterology, Hepatology and
1040 Brussels Nutrition
Belgium 2. Avenue Oscar Lambret
Tel.: +32 (2) 514 1111 59037 Lille
E-Mail: e.cogalniceanu@ciaa.eu France
Tel.: +33 320446885
COUNCIL FOR RESPONSIBLE NUTRITION – CRN
fax: +33 320446134
Dr John Hathcock
E-Mail: dturck@chru-lille.fr
Senior Vice President
CRN IACFO – INTERNATIONAL ASSICIATION OF CONSUMER
1828 L St, NW Suite 510 FOOD ORGANIZATIONS
20036 Washington, DC Mrs Patti Rundall
USA Policy Director
Tel.: +1 202 204 7662 Baby Milk Action / IBFAN
Fax: +1 202 204 7701 34 Trumpington St.
E-Mail: jhathcock@crnusa.org Cambridge CB2 1QY
Mr Mark Mansour United Kingdom
Partner Tel.: +44 01223 464420
Bryan Cave, LLC Fax. +44 01223 464417
Washington, DC E-Mail: prundall@babymilkacion.org
USA IADSA - INTERNATIONAL ALLIANCE OF DIETARY / FOOD
Tel.: +1 202 508 6019 SUPPLEMENT ASSOCIATIONS
E-Mail: mark.mansour@bryancave.com Prof David Richardson
Mr John Venardos Scientific Advisor
Herbalife International International Alliance of Dietary/Food Supplement
USA Associations (IADSA)
Tel.: +1 310 203 7146 50, Rue de l'Association
E-Mail: johnv@herbalife.com 1000 Brussels, Belgium
Mr Byran Johnson Tel.: +32 (2) 2 09 11 55
Tel.: +1 616 787 7577 Fax: +32 (2) 2 23 30 64
E-Mail: byron.johnson@amway.com E-Mail: secretariat@iadsa.be
Mr David Pineda Ereño
EHPM – EUROPEAN FEDERATION OF ASSOCIATIONS OF
Manager Regulatory Affairs
HEALTH PRODUCT MANUFACTURERS
International Alliance of Dietary/Food Supplement
Mr Xavier Lavigne
Associations (IADSA)
EHPM
Rue de l’Association 50
Rue de l’Assiciation 50
1000 Brussels
1000 Bruxelles
Belgium
Belgium
Tel.: +32 (2) 209 1155
E-Mail: pieterdhondt@ehpm.be
Fax: +32 (2) 223 3064
ENCA – EUROEAN NETWORK OF CHILDBIRTH E-Mail: secretariat@iadsa.be
Mr Joseph Voss Mr Ric Hobby
European Network of Childbirth (ENCA) Secretariat
9, Hubert Clement International Alliance of Dietary/Food Supplement
L 3444 Dudelange Associations (IADSA)
Luxembourg Rue de l’Association 50
Tel:: +352 6913 77167 1000 Brussels
Fax: +352 525291 Belgium
E-Mail: vossjos@pt.lu Tel.: +32 (2) 209 1155
ALINORM 09/32/26 40
APPENDIX II
*
Conditions for nutrient content claims for dietary fibre in liquid foods to be determined at national
level.
**
Serving size and daily reference value to be determined at national level.
Definition:
Dietary fibre means carbohydrate polymers1 with ten or more monomeric units2 , which are not hydrolysed
by the endogenous enzymes in the small intestine of humans and belong to the following categories:
• Edible carbohydrate polymers naturally occurring in the food as consumed,
• carbohydrate polymers, which have been obtained from food raw material by physical, en-
zymatic or chemical means and which have been shown to have a physiological effect of
benefit to health as demonstrated by generally accepted scientific evidence to competent
authorities,
• synthetic carbohydrate polymers which have been shown to have a physiological effect of
benefit to health as demonstrated by generally accepted scientific evidence to competent
authorities
Methods of Analysis for Dietary Fibre
→ To be agreed.
1
When derived from a plant origin, dietary fibre may include fractions of lignin and/or other compounds when
associated with polysaccharides in the plant cell walls and if these compounds are quantified by the AOAC gra-
vimetric analytical method for dietary fibre analysis : Fractions of lignin and the other compounds (proteic frac-
tions, phenolic compounds, waxes, saponins, phytates, cutin, phytosterols, etc.) intimately "associated" with plant
polysaccharides are often extracted with the polysaccharides in the AOAC 991.43 method. These substances are
included in the definition of fibre insofar as they are actually associated with the poly- or oligo-saccharidic frac-
tion of fibre. However, when extracted or even re-introduced into a food containing non digestible polysaccha-
rides, they cannot be defined as dietary fibre. When combined with polysacchrides, these associated substances
may provide additional beneficial effects (pending adoption of Section on Methods of Analysis and Sampling).
2
Decision on whether to include carbohydrates from 3 to 9 monomeric units should be left to national authorities.
ALINORM 09/32/26, Appendix III 47
APPENDIX III
DRAFT ADVISORY LIST OF NUTRIENT COMPOUNDS FOR USE IN FOODS FOR SPECIAL
DIETARY USES INTENDED FOR INFANTS AND YOUNG CHILDERN
Maximum Level in
INS no. Additive/ Carrier Ready-to-use Food for
infants and young children
(mg/kg)
APPENDIX IV
SECTION 1 – BACKGROUND
1. The Working Principles for Risk Analysis for Application in the Framework of the Codex Alimentarius
(hereafter cited as “Working Principles”) has established general guidance on risk analysis to Codex
Alimentarius. These Working Principles were adopted in 2003 and published in this Procedural
Manual.
2. The objective of the Working Principles is “to provide guidance to the Codex Alimentarius Commission
and the joint FAO/WHO expert bodies and consultations so that food safety and health aspects of Codex
standards and related texts are based on risk analysis”. By its reference to health aspects in addition to
food safety, the objective provides clearer direction for risk analysis to apply to nutritional matters that
are within the mandate of the Codex Alimentarius Commission and its subsidiary bodies.
3. The Nutritional Risk Analysis Principles are established to guide the Codex Alimentarius Commission
and its subsidiary bodies - primarily but not exclusively the Codex Committee on Nutrition and Foods
for Special Dietary Uses (CCNFSDU) - in applying nutritional risk analysis to their work. This guidance
may be used for the work of other Committees since CCNFSDU is also mandated, in accordance with its
4th term of reference, “to consider, amend if necessary, and endorse provisions on nutritional aspects” of
foods including those resulting from application of nutritional risk analysis that are developed by other
Codex subsidiary bodies.
SECTION 2 – INTRODUCTION
4. Codex nutritional risk analysis addresses nutrients1 and related substances2 and the risk to health from
their inadequate and/or excessive intake. Nutritional risk analysis applies the same general approach as
traditional food safety risk analysis to consideration of excessive intakes of nutrients and related
substances. However, unlike many constituents of food that are the subject of traditional food safety
risk analysis (such as food additives, chemical (pesticide and veterinary drug) residues, microbiological
pathogens, contaminants and allergens) nutrients and related substances are biologically essential (in the
case of essential nutrients) or in other ways potentially favourable to health. Nutritional risk analysis
therefore adds a new dimension to traditional risk analysis by also considering risks directly posed by
inadequate intakes.
5. The Nutritional Risk Analysis Principles and Guidelines for Application to the Work of the Committee
on Nutrition and Foods for Special Dietary Uses presented in this document (hereafter cited as
“Nutritional Risk Analysis Principles”) are subsidiary to and should be read in conjunction with the
Working Principles.
1
Nutrient is defined by Codex General Principles for the Addition of Essential Nutrients to Foods (CAC/GL 09-1987)
to mean: any substance normally consumed as a constituent of food:
(a) which provides energy; or
(b) which is needed for growth and development and maintenance of healthy life; or
(c) a deficit of which will cause characteristic biochemical or physiological changes to occur.
Essential nutrient means any substance normally consumed as a constituent of food which is needed for growth and
development and the maintenance of healthy life and which cannot be synthesized in adequate amounts by the body.
2
A related substance is a constituent of food (other than a nutrient) that has a favourable physiological effect.
ALINORM 09/32/26, Appendix IV 49
6. These Nutritional Risk Analysis Principles are framed within the three-component structure of the
Working Principles, but with an added initial step to formally recognize Problem Formulation as an
important preliminary risk management activity.
7. Nutritional risk analysis considers the risk of adverse health effects from inadequate and/or excessive
intakes of nutrients and related substances, and the predicted reduction in risk from proposed
management strategies. In situations that address inadequate intakes, such a reduction in risk through
addressing the inadequacy might be referred to as a nutritional benefit.
8. The food constituents of primary interest in nutritional risk analysis are inherent components of food
and/or intentionally added to food and are identified as:
• nutrients that may reduce the risk of inadequacy and those that may increase the risk of adverse
health effects; and/or
• related substances2 that may increase the risk of adverse health effects at excessive intake and may
also reduce the risk of other adverse health effects at lower intake.
9. When favourable effects of the nutrient or related substance of primary interest are being assessed,
consideration should be given to whether the food matrix could increase the risk of an adverse health
effect.
10. Where appropriate, the application of quantitative nutritional risk assessment may guide decision
making on quantitative content provisions for nutrients and related substances in certain Codex texts.
11. Nutritional risk assessment should be as quantitative as possible, although a qualitative risk-based
approach drawing on the principles of nutritional risk analysis could assist the development of Codex
texts in such situations as:
• formulating general principles related to nutritional composition (e.g. principles for the addition of
nutrients to foods);
• formulating general principles for assessing or managing risks related to foods for which a nutrition
or health claim has been requested;
• advising on risk-risk analysis (e.g. risk associated with a significantly reduced or entirely avoided
consumption of a nutritious, staple food in response to a dietary hazard such as a contaminant
present in that food.
SECTION 4 – DEFINITIONS
12. The Definitions of Risk Analysis Terms Related to Food Safety in this Procedural Manual provide
suitable generic definitions of risk analysis, risk assessment, risk management, risk communication and
risk assessment policy. When applied in a nutritional risk analysis context, these high-level risk analysis
terms should be prefaced by ‘nutritional’ and their existing definitions appropriately adapted by
replacement of relevant existing terms and definitions with those listed below.
3
For the purpose of these Nutritional Risk Analysis Principles, the descriptive term ‘nutrient-related’ refers to one or
more nutrients and/or related substances, as the case may be.
ALINORM 09/32/26, Appendix IV 50
13. However, other Definitions of Risk Analysis Terms Related to Food Safety have been modified to
reference inadequate intake as a nutritional risk factor. Some new terms also have been defined to
provide further clarity. The modified or newly developed subsidiary definitions are as follows:
Nutritional risk – A function of the probability of an adverse health effect associated with inadequate
or excessive intake of a nutrient or related substance and the severity of that effect, consequential to a
nutrient-related hazard(s) in food.
Adverse health effect4 – A change in the morphology, physiology, growth, development, reproduction
or life span of an organism, system, or (sub)population that results in an impairment of functional
capacity, an impairment of the capacity to compensate for additional stress, or an increase in
susceptibility to other influences.
Nutrient-related3 hazard – A nutrient or related substance in food that has the potential to cause an
adverse health effect depending on inadequate or excessive level of intake.
Dose response assessment – The determination of the relationship between the magnitude of intake of
(or exposure to) (i.e. dose) a nutrient or related substance and the severity and/or frequency of
associated adverse health effects (i.e. response).
Upper level of intake4 – the maximum level of habitual intake from all sources of a nutrient or related
substance judged to be unlikely to lead to adverse health effects in humans.
Highest observed intake4 – the highest level of intake observed or administered as reported within a
stud(ies) of acceptable quality. It is derived only when no adverse health effects have been identified.
Intake (Exposure) assessment – The qualitative and/or quantitative evaluation of the likely intake of a
nutrient or related substance from food as well as intake from other relevant sources such as food
supplements.
Bioavailability5 – The proportion of the ingested nutrient or related substance that is absorbed and
utilised through normal metabolic pathways. Bioavailability is influenced by dietary factors such as
chemical form, interactions with other nutrients and food components, and food processing/preparation;
and host–related intestinal and systemic factors.
4
A Model for Establishing Upper Levels of Intake for Nutrients and Related Substances. Report of a joint FAO/WHO
technical workshop 2005, WHO, 2006.
5
Gibson R.S. The role of diet- and host-related factors in nutrient bioavailability and thus in nutrient-based dietary
requirement estimates. Food and Nutrition Bulletin 2007;28 (suppl): S77-100.
ALINORM 09/32/26, Appendix IV 51
14. Nutritional risk analysis comprises three components: risk assessment, risk management and risk
communication. Particular emphasis is given to an initial step of Problem Formulation as a key
preliminary risk management activity.
15. Preliminary nutritional risk management activities should have regard to the particular sections in the
Working Principles titled General Aspects of Risk Analysis, and Risk Assessment Policy.
16. Nutritional Problem Formulation is necessary to identify the purpose of a nutritional risk assessment and
is a key component of preliminary nutritional risk management activity because it fosters interactions
between risk managers and risk assessors to help ensure common understanding of the problem and the
purpose of the risk assessment.
17. Such considerations should include whether a nutritional risk assessment is needed and if so:
• who should conduct and be involved in the nutritional risk assessment, nutritional risk management
and nutritional risk communication processes;
• how the nutritional risk assessment will provide the information necessary to support the nutritional
risk management decision;
18. Specific information to be gathered for nutritional problem formulation may include:
• identification of the (sub)populations to be the focus for the risk assessment, geographical areas or
consumer settings to be covered;
19. The risk assessment section of the Codex Working Principles for Risk Analysis for Application in the
Framework of the Codex Alimentarius is generally applicable to nutritional risk assessment. Additional
nutritional risk assessment principles to consider within the Codex framework are identified below.
ALINORM 09/32/26, Appendix IV 52
20. These two steps are often globally relevant because they are based on available scientific and medical
literature that contribute data from diverse population groups. This global relevance for characterization
of hazard does not, however, preclude the possibility of a (sub)population-specific hazard.
21. Nutritional risk assessment should take into consideration the nutrient-related hazard(s) posed by both
inadequate and excessive intakes. This may include consideration of hazard(s) posed by excessive
intakes of accompanying risk-increasing nutrients in the food vehicle(s) under consideration.
22. Nutrient-related hazard identification and characterization should recognize current methodological
differences in assessment of nutritional risk of inadequate and excessive intakes, and scientific advances
in these methodologies.
23. Nutrient-related hazard characterization should take into account homeostatic mechanisms for essential
nutrients, and limitations in the capacity for homeostatic adaptations. It may also take into account
bioavailability including factors affecting the bioavailability of nutrients and related substances such as
different chemical forms.
24. Nutrient reference standards that may be used to characterize nutrient-related hazard(s) related to
adequacy include measures of average requirement. Some globally applicable nutrient reference
standards for average requirement have been published by FAO/WHO. Official regional and national
nutrient reference standards are also available and have been periodically updated to reflect scientific
advances. These are more likely to relate to nutrients than to related substances.
25. Nutrient reference standards that may be used to characterize nutrient-related hazard(s) related to
excessive intakes include upper levels of intake. Some globally applicable reference standards of upper
level of intake have been published by FAO/WHO. In addition, the establishment of international upper
levels of intake and highest observed intake that build on recommendations4 may be considered in the
future. Some periodically-updated nutrient reference standards are available from regional and national
authorities. For some related substances, such standards developed from a systematic review of the
evidence are available only in the peer-reviewed scientific literature.
26. The assessment of inadequate and excessive levels of intake of particular nutrients and related
substances should take into account the availability of all such scientifically determined reference
sources, as appropriate. When using such reference standards for nutrient and related substances in
nutritional risk assessment, the basis for their derivation should be explicitly described.
27. These two steps are generally specific to the (sub)population(s) under consideration for risk assessment.
The populations relevant to Codex consideration are populations at large in Codex member countries or
particular subpopulation groups in these countries defined according to physiological parameters such as
age or state of health.
28. Nutrient-related intake assessment and risk characterization should be applied within a total diet context.
Where feasible, it would typically involve the evaluation of the distribution of habitual total daily
intakes for the target population(s). This approach recognizes that nutrient-related risks are often
associated with total intakes from multiple dietary sources, including fortified foods, food supplements6,
and in the case of certain minerals, water. It may also take into account the bioavailability and stability
of nutrients and related substances in the foods consumed.
6
Codex Guidelines for Vitamin and Mineral Food Supplements (CAC/GL 55 – 2005) define food supplements as
sources in concentrated forms of those nutrients or related substances alone or in combinations, marketed in forms such
as capsules, tablets, powders solution, etc., that are designed to be taken in measured small unit quantities but are not in
a conventional food form and whose purpose is to supplement the intake of nutrients or related substances from the diet.
ALINORM 09/32/26, Appendix IV 53
29. The risk management section of the Codex Working Principles for Risk Analysis for Application in the
Framework of the Codex Alimentarius is generally applicable to nutritional risk management.
Additional nutritional risk management principles to consider within the Codex framework are
identified below.
30. Nutritional risk management can be effected through quantitative measures or qualitative guidance
elaborated in Codex texts. Such risk management could involve decisions about nutrient composition,
consideration of the suitability of foods containing risk-increasing nutrients for certain purposes or (sub)
populations, labelling advice intended to mitigate nutritional risks to public health, and formulation of
relevant general principles.
Nutritional risk management decisions should take into account their impact on dietary patterns and
consumer behaviour. Such information should be supported by relevant research.
31. Nutritional risk assessment policy should be articulated as appropriate for the selected risk assessor
prior to the conduct of the nutritional risk assessment.
32. The risk communication section of the Codex Working Principles for Risk Analysis for Application in
the Framework of the Codex Alimentarius is generally applicable to nutritional risk communication.
33. Consistent with their important role in providing scientific advice to the Codex Alimentarius
Commission and its subsidiary bodies, FAO and WHO are acknowledged as the primary source of
nutritional risk assessment advice to Codex Alimentarius. This acknowledgement however, does not
preclude the possible consideration of recommendations arising from other internationally recognised
expert bodies, as approved by the Commission.
34. All requests for risk assessment advice should be accompanied by terms of reference and where
appropriate risk assessment policy to provide guidance to the risk assessor. These parameters should be
established by CCNFSDU.
ALINORM 09/32/26, Appendix V 54
APPENDIX V
DRAFT ANNEX TO THE CODEX GUIDELINES FOR USE OF NUTRITION AND HEALTH
CLAIMS: RECOMMENDATIONS ON THE SCIENTIFIC SUBSTANTIATION OF HEALTH
CLAIMS1
1. SCOPE
1.1 These Recommendations are intended to assist competent national authorities in their evaluation of
health claims in order to determine their acceptability for use by the industry. The recommendations focus
on the criteria for substantiating a health claim and the general principles for the systematic review of the
scientific evidence. The criteria and principles apply to the three types of health claims as defined in Section
2.2 of the Guidelines for use of nutrition and health claims.
1.2 These recommendations include consideration of safety in the evaluation of proposed health claims, but
are not intended for the complete evaluation of the safety and the quality of a food, for which relevant
provisions are laid out by other Codex Standards and Guidelines or general rules of existing national
legislations.
2. DEFINITIONS
2.1 Food or food constituent refers to energy, nutrients, related substances, ingredients, and any other
feature of a food, a whole food, or a category of foods on which the health claim is based. The category of
food is included in the definition because the category itself may be assigned a common property of some of
the individual foods making it up.
2.2 Health effect refers to a health outcome as defined in sections 2.2.1 to 2.2.3 of the Guidelines.
The systematic review of the scientific evidence for health claims by competent national authorities takes
into account the general principles for substantiation. Such a process typically includes the following steps:
(a) Identify the proposed relationship between the food or food constituent and the health effect;
(b) Identify appropriate valid measurements for the food or food constituent and for the health
effect;
(d) Assess the quality of and interpret each relevant scientific study;
(e) Evaluate the totality of the available relevant scientific data, weigh the evidence across studies
and determine if, and under what circumstances, a claimed relationship is substantiated.
1
Note: This document is intended as an annex to the Codex Guidelines for the Use of Nutrition and Health
Claims (CAC/GL 23-1997, Rev. 1-2004) and should be read in conjunction with the Working Principles for
Risk Analysis for Food Safety for Application by Governments (CAC/GL 62-2007)
ALINORM 09/32/26, Appendix V 55
3.2.1 The following criteria are applicable to the three types of health claims as defined in section 2.2 of
the Guidelines for use of nutrition and health claims:
(a) Health claims should primarily be based on evidence provided by well-designed human intervention
studies. Human observational studies are not generally sufficient per se to substantiate a health
claim but where relevant they may contribute to the totality of evidence. Animal model studies, ex
vivo or in vitro data may be provided as supporting knowledge base for the relationship between the
food or food constituent and the health effect but cannot be considered as sufficient per se to
substantiate any type of health claim.
(b) The totality of the evidence, including unpublished data where appropriate, should be identified and
reviewed, including: evidence to support the claimed effect; evidence that contradicts the claimed
effect; and evidence that is ambiguous or unclear.
(c) Evidence based on human studies should demonstrate a consistent association between the food or
food constituent and the health effect, with little or no evidence to the contrary.
3.2.2 Although a high quality of scientific evidence should always be maintained, substantiation may take
into account specific situations and alternate processes, such as:
(a) ‘Nutrient function’ claims may be substantiated based on generally accepted authoritative statements
by recognised expert scientific bodies that have been verified and validated over time.
(b) Some Health claims, such as those involving a relationship between a food category and a health
effect, may be substantiated based on observational evidence such as epidemiological studies. Such
studies should provide a consistent body of evidence from a number of well-designed studies.
Evidence-based dietary guidelines and authoritative statements prepared or endorsed by a competent
authoritative body and meeting the same high scientific standards may also be used.
3.3.1 The scientific studies considered relevant for the substantiation of health claim are those addressing the
relationship between the food or food constituent and the health effect. In case of a claimed health effect that
cannot be measured directly, relevant validated biomarkers may be used (e.g. plasma cholesterol
concentrations for cardiovascular disease risk).
3.3.2 The scientific data should provide adequate characterization of the food or food constituent considered
as responsible for the health effect. Where applicable, the characterization includes a summary of the studies
undertaken on production conditions, batch-to-batch variability, analytical procedures, results and conclusions
of the stability studies, and the conclusions with respect to storage conditions and shelf-life.
3.3.3 The relevant data and rationale that the constituent for which the health claim is made is in a form that
is available to be used by the human body should be provided where applicable. If absorption is not
necessary to produce the claimed effect (e.g. plant sterols, fibres, lactic acid bacteria), the relevant data and
rationale that the constituent reaches the target site or mediates the effect are provided. All available data on
factors ( e.g. forms of the constituents) that could affect the absorption or utilisation in the body of the
constituent for which the health claim is made should also be provided.
3.3.4 The methodological quality of each type of study should be assessed, including study design and
statistical analysis.
(a) The design of human intervention studies should notably include an appropriate control group,
characterize the study groups’ background diet and other relevant aspects of lifestyle, be of an
adequate duration, take account of the level of consumption of the food or food constituent that
ALINORM 09/32/26, Appendix V 56
can be reasonably achieved in a balanced diet, and assess the influence of the food matrix and
total dietary context on the health effect.
(b) (b) Statistical analysis of the data should be conducted with methods recognized as appropriate
for such studies by the scientific community and with proper interpretation of statistical
significance.
3.3.5 Studies should be excluded from further review and not included in the relevant scientific data if they
do not use appropriate measurements for the food or food constituent and health effect, have major design
flaws, or are not applicable to the targeted population for a health claim.
3.3.6 By taking into account the totality of the available relevant scientific data and by weighing the
evidence, the systematic review should demonstrate the extent to which:
(c) the claimed effect of the food or food constituent is beneficial for human health;
(d) a cause and effect relationship is established between consumption of the food or food
constituent and the claimed effect in humans such as the strength, consistency, specificity, dose-
response ,where appropriate, and biological plausibility of the relationship;
(e) the quantity of the food or food constituent and pattern of consumption required to obtain the
claimed effect could reasonably be achieved as part of a balanced diet as relevant for the target
population for which the claim is intended;
(f) the specific study group(s) in which the evidence was obtained is representative of the target
population for which the claim is intended.
3.3.7 Based on this evaluation and the substantiation criteria, competent national authorities can determine
if, and under what circumstances, a claimed relationship is substantiated.
4.1 When the claim is about a food or food constituent, the amount should not expose the consumer to
health risks and the known interactions among constituents should be considered.
4.2 The expected level of consumption should not exceed relevant upper levels of intake for food
constituents.
4.3 The exposure assessment should be based on an evaluation of the distribution of usual total daily intakes
for the general population2,3 and, where relevant, those for vulnerable population groups. It should account
for the possibility of cumulative intake from all dietary sources, and of nutritional imbalance due to changes
in dietary patterns in response to information to consumers that lays emphasis on the food or food
constituent.
5. RE-EVALUATION
Health claims should be re-evaluated. Competent national authorities should re-evaluate health claims
either periodically or following the emergence of significant new evidence that has the potential to alter
previous conclusions about the relationship between the food or food constituent and the health effect.
2
Food and Nutrition Board, Institute of Medicine, National Academy of Sciences. Dietary Reference Intakes: A Risk
Assessment Model for Establishing Upper Intake Levels for Nutrients. Washington, D.C. National Academy Press,
1998, p. 8.
3
European Commission, Scientific Committee on Food. Guidelines of the Scientific Committee on Food for the
Development of Tolerable Upper Intake Levels for Vitamins and Minerals. SCF/CS/NUT/UPPLEV/11 Final. 28
November 2000. p.4.
ALINORM 09/32/26, Appendix VI 57
APPENDIX VI
METHODS OF ANALYSIS FOR INFANT FORMULA AND FORMULAS FOR SPECIAL MEDICAL PURPOSES INTENDED FOR INFANTS,
CODEX STAN 72-1981
Table.1 Methods of analysis recommended for endorsement
Type III* method recommendations which are suitable for consideration as the Type II Reference Method using the guidance on selection criteria requested from
CCMAS.
Provision Requirement Method Principle Type
Calories (by Minimum 60kcal Method described in Calculation Type III
calculation) (250kJ), maximum CAC/Vol IX-Ed.1, Part method Notes
70kcal (295kJ), per III
1. Currently adopted as a Type III method for Special foods in CODEX
100ml prepared ready
STAN 234-1999, amended 2007.
for consumption.
2. The references in this method (methods of analysis and conversion
Compositional factors for specific food ingredients) need to be updated.
provisions are generally
specified per 100 kcal
or 100 kJ.
Total fat Minimum 4.4g/100kcal AOAC 989.05 Gravimetry Type I. This method should apply to milk-based infant formula containing
(1.05g/100kJ); (Röse-Gottlieb) ≤ 5% starch or dextrin,
maximum 6.0g/100kcal Notes
ISO 8381|IDF 123:2008
(1.4g/100kJ).
1. Validated for milk-based infant formulae, except formulae containing
starch or dextrin. Reference: Bulletin of the IDF (1988), N°235, J
Eisses, Methods for the determination of the fat content, part 3, Infant
foods, edibles ices, milk and milk products (special cases),
Determination of the fat content according to Röse-Gottlieb or Weibull-
Berntrop
2. Normally regarded as a defining method (Type I).
ALINORM 09/32/26, Appendix VI 58
Total fat Minimum 4.4g/100kcal ISO 8262-1 |IDF 124-1: Gravimetry Type I, this method should apply to milk-based infant formula
(1.05g/100kJ); 2005 (Weibull- Notes
maximum 6.0g/100kcal Berntrop)
1. Validated. References:
(1.4g/100kJ).
Schuller, P.L. Report of the collaborative study of CX/MAS on
fat determination in infant foods. Codex Committee on Methods
of Analysis and Sampling, CX/MAS 75/10,1975
Bulletin of the IDF (1988), N°235, J Eisses, Methods for the
determination of the fat content, part 3, Infant foods, edibles
ices, milk and milk products (special cases), Determination of
the fat content according to Röse-Gottlieb or Weibull-Berntrop
2. Normally regarded as a defining method (Type I).
Fatty acids Lauric and myristic AOAC 996.06 Gas Type III*
fatty acids combined chromatography Notes
<20% total fatty acids.
1.
Erucic acid <1% total 2. Validated (but not for infant formulas). References: J.AOAC Int. 80:
fatty acids. 555 - 563 (1997). J.AOAC Int. 82: 1146 - 1155 (1999).
LA1 minimum 3. Adopted as Type II for determination of saturated fat for nutrition
300mg/100kcal labelling purposes.
(70mg/100kJ); no 4. Information should be adequate for listing as a reference method (Type
maximum; GUL II), or if not, a tentative method (Type IV).
1400mg/100kcal
(330mg/100kJ).
ALA23 minimum
50mg/100kcal
(12mg/100kJ); no
maximum limit nor
GUL specified.
PUFA4 is needed for
calculation of α-TE
content (see vitamin E).
1
Linoleic acid
2
Guidance Upper Level
3
Alpha-linoleic acid
4
Polyunsaturated fatty acids
ALINORM 09/32/26, Appendix VI 59
Trans fatty acids ≤ 4% of total fatty acids AOCS Ce 1h-05 Gas liquid Type III*, for infant formulae not containing milkfat
chromatography Notes
1. Method for Determination of cis, trans, Saturated, Monounsaturated
and Polyunsaturated Fatty Acids in Vegetable or Non-Ruminant Animal
Oils and Fats.
2. Validated (but not for infant formula). Performance statistics were
extracted from the collaborative study report and are included with the
method.
3. Adopted as Type II for the purposes of the Guidelines for Nutrition
Labelling
4. The method states “The method is not suitable for the analysis of dairy,
ruminant, marine, long chain polyunsaturated (PUFA) fats and oils, or
products supplemented with conjugated linoleic acid (CLA).” The
method should therefore be endorsed for infant formulae not containing
milkfat.
Trans fatty acids ≤ 3% of total fatty acids AOAC 996.06 Gas Type IV, with optimisation for the determination of TFAs
chromatography Notes
1. Method for quantitation of individual fatty acids, including trans
2. A publication describing an improved procedure for the determination
of trans fatty acids is available under "Proposed Modifications to
AOAC 996.06, Optimizing the Determination of Trans Fatty Acids:
Presentation of Data; Rozemat at.: J. AOAC Int'l, VOL. 91, NO. 1,
2008"
3. Validated (but not for infant formulas). References: J.AOAC Int. 80:
555 - 563 (1997). J.AOAC Int. 82: 1146 - 1155 (1999).
Total ≤ 300mg/100kcal AOCS Ja7b-91 Gas liquid Type IV with suitable extraction and preparation procedures
phospholipids (72mg/100kJ) chromatography Notes
1. The method is applicable to oil-containing lecithins, deoiled lecithins,
lecithin fractions; not applicable to lyso-PC and lyso-PE.
2. Validated. Reference Pure Appl. Chem. 64: 447 - 454 (1992). A
summary of statistics from the IUPAC phospholipid collaborative study
is included with the method.
3. Suitable extraction and preparation procedures applicable to infant
formulae are needed in conjunction with this method. The Walstra &
de Graaf procedure for the extraction of the fat is suitable. Reference:
ALINORM 09/32/26, Appendix VI 60
infant formula, whether preformed or derived from supplemental acetate and/or palmitate forms. It does not make sense to exclude vitamin A added for
nutrient purposes from this provision and it seems at the least, that “preformed’ should be removed from the standard
Minimum AOAC 992.04 (retinol High performance Type III*
Vitamin A 60µg/100kcal isomers) liquid Notes
(14µg/100kJ); Vitamin A (both natural + chromatography
1. Currently adopted as Type II method for follow-up formula in CODEX
maximum supplemental ester forms) STAN 234-1999 rev 2007 and previously listed for infant formula in
180µg/100kcal aggregated and quantified rev 2006.
(43µg/100kJ). as individual retinol 2. Validated: Study matrices included powdered infant formula,
isomers (13, cis and all- powdered milk, and liquid infant formula
trans) 3. Reference: J.AOAC Int. 76.
Vitamin A Minimum AOAC 992.06 (retinol) High performance Type III*
60µg/100kcal Vitamin A (both natural + liquid Notes
(14µg/100kJ); supplemental ester forms) chromatography
1. Currently adopted as Type II method for follow-up formula in CODEX
maximum aggregated and quantified STAN 234-1999, amended 2007.
180µg/100kcal as individual retinol 2. Reference: J. AOAC Int. 76: 300-414 (1993).
(43µg/100kJ). isomers (13, cis and all-
trans)
12823-1:2000
Vitamin A Minimum EN 12823-1:2000 (all- High performance Type III
60µg/100kcal trans-retinol and 13-cis- liquid Notes
(14µg/100kJ); retinol) chromatography
1. Validated. Precision data for various foods is in CCNFSDU 29th session
maximum Vitamin A (both natural + CRD 15.
180µg/100kcal supplemental ester forms) 2. Collaboratively tested according to ISO 5725, among others an
(43µg/100kJ). aggregated and quantified enriched milk powder was included in the validation. In accordance
as individual retinol with the EU MAT Certification Study Guidelines, the parameters for
isomers (13, cis and all- margarine (CRM 122) and milk powder (CRM 421) have been defined
trans) in an interlaboratory test. The study was organised by the Institute of
Food Research, Norwich, United Kingdom.
3. Reference: Finglas, P.M., van den Berg, H. & de Froidmont-Gortz, I.,
1997. The certification of the mass fractions of vitamins in three
reference materials: margarine (CRM 122), milk powder (CRM 421),
and lyophilized Brussels sprouts (CRM 431). EUR-Report 18039,
Commission of the European Union, Luxembourg.
Vitamin D Note on the form of Vitamin D in Codex Standard 72
Footnote from Codex Stan 72, 3.1 Essential Composition, Vitamin D
ALINORM 09/32/26, Appendix VI 62
are specified.
GUL cis and trans forms C30 column to feed, and powdered) containing > 1 microgram vitamin K1/100 g
27µg/100kcal depending on LC column. separate the cis- and solids).
(6.5µg/100kJ) Can also discriminate and the trans- 2. Reference: J. AOAC Int. 83: 121- 130 (2000).
measure dihydro-K1 and K vitamins 3. Measures either aggregated cis + trans K1 or can measure individual cis
menaquinones). and trans forms depending on LC column. Can also discriminate and
measure dihydro-K1 and menaquinones.
Proposed by CCNFSDU 28. CCMAS 28 asked for clarification of the
differences from AOAC 992.27.
Consideration needs to be given to i) ability to discriminate the cis and trans-
forms of K1 which can be accomplished with a C30 column, ii) whether the
menaquinones (K2) be included.
AOAC 999.15 is a more specific fluorescence method than AOAC 999.27 and
has a better sample preparation with enzyme instead of a labor-intensive
multistep procedure.
AOAC 995.15 & EN 14148 are based on a joint AOAC/EN collaborative
study. The main weakness with this procedure is that both cis- and trans- K1
(total K1) are determined. The cis-form is inactive. To overcome this problem,
the C18 HPLC column must be replaced by a C30 HPLC column which
separates the two vitamers.
Vitamin K Minimum EN 14148:2003 (vitamin High performance Type III*
4µg/100kcal K1) liquid 1. Precision data for various foods including a range of infant formulae is
(1µg/100kJ); no (Measures either chromatography in CCNFSDU 29th session CRD 15.
maximum limit; aggregated cis + trans K1 2. Validated. The precision data have been defined in an international
GUL or can measure individual collaborative study:
27µg/100kcal cis and trans forms 3. Reference: Indyk, H. E. and Woollard, D. C.: Vitamin K in Milk and
(6.5µg/100kJ) depending on LC column.) Infant Formulas by Liquid Chromatography: Collaborative study. J.
AOAC intern. 83, 2000, 121-130.
4. Measures either aggregated cis + trans K1 or can measure individual
cis and trans forms depending on LC column.
(14µg/100kJ); no ( Measures all vitamin B1 1. Currently adopted as Type II method for Special foods in CODEX
maximum limit; forms and aggregates as STAN 234-1999, rev 2007.
GUL thiamine) 2. Validated on many food matrixes, but not infant formula or similar
300µg/100kcal food matrixes.
(72µg/100kJ) 3. The method has been used traditionally
4. The method is not applicable in presence of materials that adsorb
thiamin or which contain extraneous materials which affect thiochrome.
5. References: JAOAC 25: 456- 458 (1942);
JAOAC 27: 534 - 537 (1944) ; JAOAC 28: 554 - 559 (1945); JAOAC 31:
455 - 459 (1948); JAOAC 43: 45 - 46 (1960); JAOAC 43: 55 - 57 (1960);
AND
JAOAC 64: 1336 - 1338 (1981).
6. Measures all vitamin B1 forms and aggregates as thiamine. Subject to
significant spectral interference.
Minimum AOAC 986.27 Fluorimetry Type III*
Thiamin 60µg/100kcal (Measures all vitamin B1 1. Validated
(14µg/100kJ); no forms as thiamine) 2. Reference: JAOAC 69: 777 - 785 (1986).
maximum limit; 3. Measures all vitamin B1 forms as thiamine. Subject to significant
GUL spectral interference.
300µg/100kcal
(72µg/100kJ)
Thiamin Minimum EN 14122:2003 High performance Type III*
60µg/100kcal (Measures all vitamin B1 liquid 1. Validated. Precision data for various foods is in CCNFSDU 29th
(14µg/100kJ); no forms (natural and added chromatography session CRD 15
maximum limit; free, bound and with pre-or post 2. Collaboratively tested according to ISO 5725, among others, an
GUL phosphorylated) following column enriched milk powder was included in the validation.
300µg/100kcal extraction and conversion derivatization to In accordance with the EU SMT Certification Study guidelines, the
(72µg/100kJ) to thiamine) thiochrom data given for CRM 121 (wholemeal flour), CRM 421 (milk
powder), CRM 485 (mixed vegetables) and CRM 487 (pig’s liver)
have been defined in an interlaboratory test. The Institute of Food
Research, Norwich, UK on behalf of the EU Community Bureau of
Reference, conducted the study.
Reference: Finglas, P. M., Scott, K. J., Witthoft, C. M., van den
Berg, H. and de Froidmont-Gortz, I.: The certification of the mass
fractions of vitamins in four reference materials: Wholemeal flour
ALINORM 09/32/26, Appendix VI 68
500µg/100kcal aggregated and measured The parameters on CRM 421 (milk powder) and CRM 487 (pig
(119µg/100kJ) as riboflavin.) liver) of different methods for the determination of riboflavin
(Vitamin B2) have been defined in an international comparison
study organised by the European Commissions Standard,
Measurement and Testing programme. Reference: Finglas, P. M.,
Scott, K. J., Witthoft, C. M., van den Berg, H. & de Froidmont-
Gortz, I.: The certification of the mass fractions of vitamins in four
reference materials: Wholemeal flour (CRM 121), milk powder
(CRM 421), lyophilised mixed vegetables (CRM 485) and
lyophilised pig’s liver (CRM 487). EU Report 18320, Office for
Official Publications of the European Communities, Luxembourg,
1999.
3. Both natural and supplemental forms, free, bound and phosphorylated
(FMN and FAD) aggregated and measured as riboflavin.
Niacin Note on the form of Niacin in Codex Standard 72.
Niacin refers to preformed niacin.
Comment; Niacin is the generic descriptor for two vitamers, nicotinic acid and nicotinamide. However terminology differs between the USA and Europe
for this vitamin and this standard needs to be unambiguous. Other forms also exist, eg NAD, NADH etc. It is therefore unclear what is meant by
“preformed niacin”.
Niacin Minimum AOAC 985.34 (niacin Microbioassay and Type III
300µg/100kcal (preformed) and turbidimetry 1. CCMAS recommended review and replacement with a more modern
(70µg/100kJ); no nicotinamide) method.
maximum limit;
GUL 2. Validated
1500µg/100kcal 3. AOAC 985.34 Niacin and Niacinamide (Nicotinic Acid and
(360µg/100kJ) Nicotinamide) in Ready-to-Feed Milk-Based Infant Formula;
Microbiological-turbidimetric method. First Action 1985; Final Action
1988. Official Methods of AOAC Int. (18th ed., 2005): 50.1.19.
4. Reference: JAOAC 68: 514 - 522 (1985).
5. The method is applicable to baby foods (meat based), beverages, juices,
cereal products, cheese, dairy products, fruits and potato products.
6. Free and bound forms aggregated and measured as nicotinic acid.
Niacin Minimum prEN 15652:2007 High performance Type III* when published as EN method
300µg/100kcal (Free and bound and liquid 1. Validated. Precision data for various foods is in CCNFSDU 29th session
(70µg/100kJ); no phosphorylated forms chromatography CRD 15
maximum limit; measured either as 2. Collaboratively tested according to ISO 5725, among others, an
ALINORM 09/32/26, Appendix VI 70
GUL aggregate of nicotinic acid enriched milk powder was included in the validation.The precision data
1500µg/100kcal + nicotinamide, or as for the determination of niacin were established according to ISO 5725-
(360µg/100kJ) individual forms) 2 in 2002 by an international collaborative study organised by AéRIAL
(CRT: Centre de Ressources technologiques) and the CGd’UMA
(Commission Générale d’Unification des Méthodes d’Analyses)
according to ISO 5725-2 in 1999 by a French collaborative study
organized by CGd’UMA,
3. Reference:
• To be published: Bergantzlé M., Validation study on the
determination of niacin by HPLC in several matrices;
• Lahély S., Bergantzlé M., Hasselmann, C.: Fluorimetric
determination of niacin in foods by highperformance liquid
chromatography with post-column derivatization Food chem., 65,
129-133 (1999)
4. Free and bound and phosphorylated forms measured either as aggregate
of nicotinic acid + nicotinamide, or as individual forms
Vitamin B6 Note on the form of Vitamin B6 in Codex Standard 72.
The standard provides no qualification on the form of vitamin B6.
Comment: This means all forms are potentially included, i.e. pyridoxine, pyridoxal, pyridoxamine and the related phosphorylated forms. Vitamin B6 is
generally enhanced through supplementation with pyridoxine, and could be expressed as either the free base or hydrochloride salt. Methods for vitamin
B6 can therefore measure and report single or aggregate forms.
Minimum AOAC 985.32 Microbioassay Type III
Vitamin B6 35µg/100kcal (Aggregates free and 1.
(8.5µg/100kJ); no bound pyridoxal, 2. CCMAS 28 states in general, methods using microbioassay as a
maximum limit. pyridoxine and principle should be reviewed in order to replace them with more
GUL pyridoxamine and modern methods, and asked for clarification of the differences from
175µg/100kcal measures as pyridoxine.) AOAC 961.15.
(45µg/100kJ). 3. Validated
AOAC Method 985.32. (Pyridoxine, Pyridoxal, Pyridoxamine) in Ready-to
Feed Milk-Based Infant Formula Microbiological Method. First Action 1985;
Final Action 1988.
maximum limit; free, unbound natural as Type IV when another method can be recommended as Type II or III.
GUL folates, aggregated and 1.
50µg/100kcal measured as folic acid.) 2. CCMAS 28 states in general, methods using microbioassay as a
(12µg/100kJ) principle should be reviewed in order to replace them with more
modern methods.
3. Validated. Results of the interlaboratory study supporting acceptance of
the method (milk-based, ready-to-feed) are listed in the method.
Reference: J. AOAC Int. 76: 399 - 413 (1993).
4. Measures free folic acid + free, unbound natural folates, aggregated and
measured as folic acid.
Folic acid Minimum EN 14131:2003 Microbioassay Type III In line with the CCMAS 28 request to review methods using
10µg/100kcal (Total folate (free + microbioassay as a principle, this method which has been used traditionally
(2.5µg/100kJ); no bound), aggregated and should currently be endorsed as Type III and recommended as Type IV when
maximum limit; measured as folic acid.) another method can be recommended as type II or III
GUL 1.
50µg/100kcal 2. Validated. Precision data for various foods is in CCNFSDU 29th session
(12µg/100kJ) CRD 15
The precision of the method was established by interlaboratory tests
conducted within the European Union’s Standards, Measurement
and Testing (EU SMT) programme, and carried out in accordance
with ISO 5725.
Reference:
Finglas, P.M., et al., The certification of the mass fractions of
vitamins in four reference materials: wholemeal flour (CRM 121),
milk powder (CRM 421), lyophilized mixed vegetables (CRM 485)
& lyophilized pig's liver (CRM 487). B1, B6 & folate in CRM 121;
B1, B2, B6, B12 & folate in CRMs 421 & 487, and B1, B6, folate &
carotenoids in CRM 485. 1999, Luxembourg: Office for Official
Publications of the European Communities.
3. Equivalent to AOAC 992.05. Note that these methods quantify total
folate, including folates of natural source and not folic acid alone,
which is used as source for fortification.
4. Measures total folate (free + bound), aggregated and measured as folic
acid.
Folic acid Minimum J AOAC Int. 2000:83; Optical Biosensor Not recommended as Type III as it is not established as official
10µg/100kcal 1141-1148 Immunoassay methodology. In line with the CCMAS 28 request to review methods using
(2.5µg/100kJ); no (Measures free folic acid + microbioassay as a principle,this method which is recently introduced and
ALINORM 09/32/26, Appendix VI 75
maximum limit; proportion of free, natural currently under AOAC collaborative study should be endorsed as Type IV
GUL folate) 1. Reference: Indyk HE, Evans EA, et al. J AOAC Intl. 2000:83:1141-
50µg/100kcal 1148, Determination of Biotin and Folate in Infant Formula and Milk
(12µg/100kJ) by Optical Biosensor-Based Immunoassay.
http://www.atyponlink.com/AOAC/doi/abs/10.5555/jaoi.2000.83.5.114
1
2. Measures free folic acid + proportion of free, natural folate.
Folic acid Minimum J Chromatogr. A., 928, 77- High performance Not recommended as Type III as it is not established as official
10µg/100kcal 90, 2001 liquid methodology. In line with the CCMAS 28 request to review methods using
(2.5µg/100kJ); no (Measures total folates chromatography, microbioassay as a principle, this method which is recently introduced and
maximum limit; after conversion to, and incorporating currently under AOAC collaborative study should be endorsed as Type IV
GUL measurement as 5-Me- immunoaffinity 1. Under evaluation by CEN TC275/WG9
50µg/100kcal H4PteGlu) clean-up and 2. Measures total folates after conversion to, and measurement as 5-Me-
(12µg/100kJ) conversion to 5- H4PteGlu.
methyltetrahydrofol
ate
Vitamin C Note on the form of Vitamin C in Codex Standard 72.
“expressed as ascorbic acid”
Comment: Further clarification of form(s) of vitamin C is required, eg ascorbic acid (AA), oxidised dehydroascorbic acid (DHA), or total ascorbate (AA
+ DHA), since both forms are physiologically active. However, the enantiomeric D-forms are not antiscorbutic and need to be discriminated.
Vitamin C Minimum AOAC 985.33 2,6- Type III*
10µg/100kcal (measures ascorbic acid dichloroindophenol 1. .
(2.5µg/100kJ); no (AA)) titrimetry 2. CCMAS asked for clarification on how vitamin C was expressed.
maximum limit; Determines only L(+) ascorbic acid and not the total amount for
GUL which the amount of dehydroascorbic acid has to be included. This
70µg/100kcal method is specific for reduced ascorbic acid only
(17µg/100kJ) 3. Validated
References: J. AOAC 68: 514 - 522 (1985).
Vitamin C Minimum EN 14130:2003 High performance Type III*
10µg/100kcal (Measures ascorbic acid + liquid 1. .
(2.5µg/100kJ); no dehydroascorbic acid). chromatography 2. Validated. Precision data for various foods is in CCNFSDU 29th session
maximum limit; CRD 15. Validated
GUL Collaboratively tested according to ISO 5725, an enriched milk
70µg/100kcal powder was included in the validation.
(17µg/100kJ) The precision parameters for orange juice, liquid soup, powder milk,
ALINORM 09/32/26, Appendix VI 76
freeze-dried soup, breakfast cereals and fruits baby food have been
defined in a collaborative study
3. Reference:
Arella F., Deborde J.L., Bourguignon J.B., Hasselmann C., (1997),
Ann. Fals. Exp. Chim., 90, N°940:217-233.
4. Measures total L-ascorbate (Ascorbic acid + dehydroascorbic acid).
Biotin Note on the form of Biotin in Codex Standard 72
The standard provides no qualification on the form of biotin.
Comment: Free d-biotin is generally used as a supplement. However, endogenous biotin is mostly present as a protein-bound form, which may be
liberated as bioactive d-biocytin. Attention needs to be given to which forms are to be quantified.
Biotin Minimum EN 15607:2008 (d-biotin) High performance Type III*
1.5µg/100kcal (Measures total D-biotin liquid 1.
(0.4µg/100kJ); no (free + D-biocytin) chromatography 2. Validated. Precision data for various foods including infant milk
maximum limit. powder is in CCNFSDU 29th session CRD 15. Collaboratively tested
GUL according to ISO 5725, among others, an enriched infant milk powder
10µg/100kcal was included in the validation.
(2.4µg/100kJ) The data were obtained in an interlaboratory study organized by
CGd’UMA (Commission Générale d’Unification des Méthodes
d’Analyses) in 2000. It was organized in accordance with ISO 5725-
2.
Reference:
Arella, F., Deborde, J.L., Bourguignon, J.B., Bergaentlze, M.,
Ndaw, S., Hasselmann, C.: Liquid chromatographic determination
of biotin in foods. A collaborative study. Ann. Fals. Exp. Chim., 93,
951,193-200 (2000)
3. Measures total D-biotin (free + D-biocytin)
Iron Minimum AOAC 985.35 Atomic absorption Type II
0.45mg/100kcal spectrophotometry The method is applicable to the determination of Ca, Mg, Fe, Zn, Cu, Mn, Na,
(0.1mg/100kJ); no and K.
maximum limit.
Validated. Interlaboratory study matrices include enteral product, ready-to-
GUL footnote:
feed soy formula, soy powder and whey powder (same matrices as AOAC
"levels may need
986.24 Phosphorus). The results of the interlaboratory study supporting
to be determined
acceptance of the method are presented in the method.
by national
authorities". References: JAOAC 68: 514 - 522 (1985), J. AOAC Int. 80: 834 - 844
(1997).
ALINORM 09/32/26, Appendix VI 77
(35mg/100kJ).
Calcium to
phosphorus ratio:
minimum 1:1 and
maximum 2:1
Phosphorus Minimum AOAC 986.24 Spectrophotometry Type II
25mg/100kcal (molybdovanadate) Current Codex method for special foods. .
(6mg/100kJ); no
Validated. The collaborative study was performed with soy powder infant
maximum limit;
formula, whey powder infant formula, soy ready-to-feed formula and enteral
GUL
formula. The results of the interlaboratory study supporting acceptance of the
100mg/100kcal
method are included in the method.
(24mg/100kJ)
References: JAOAC 69: 777-785 (1986)
J. AOAC Int. 80: 834-844 (1997)
Phosphorus Minimum AOAC 984.27 ICP emission Type III
25mg/100kcal spectroscopy Calcium, Copper, Iron, Magnesium, Manganese, Phosphorus, Potassium,
(6mg/100kJ); no Sodium, and Zinc in Infant Formula.
maximum limit;
In this method, a test portion is digested in HNO3 / HClO4 and elements are
GUL
determined by ICP emission spectroscopy.
100mg/100kcal
(24mg/100kJ) Official Methods of AOAC Int. (18th ed., 2005): 50.1.15.
Reference: JAOAC 67: 985 - 992 (1984).
Magnesium Minimum ISO 8070 │ IDF 119: Flame atomic Type II
5mg/100kcal 2007 absorption Current Codex method for special foods and infant formula, Type II, for
(1.2mg/100kJ); no spectrophotometry determination of Na and K.
maximum limit.
Reference of the collaborative study: International Dairy Journal, Volume 18,
GUL
Issue 9, September 2008, Pages 899-904, Determination of sodium, potassium,
15mg/100kcal
calcium and magnesium content in milk products by flame atomic absorption
(3.6mg/100kJ)
spectrometry (FAAS): A joint ISO/IDF collaborative study, Laurent Noël,
Michael Carl, Christelle Vastel and Thierry Guérin
Magnesium Minimum AOAC 985.35 Atomic absorption Type III
5mg/100kcal spectroscopy
(1.2mg/100kJ); no
Validated for infant formula. Interlaboratory study matrices include enteral
maximum limit.
product, ready-to-feed soy formula, soy powder and whey powder (same
GUL
matrices as AOAC 986.24 Phosphorus). The results of the interlaboratory
15mg/100kcal
ALINORM 09/32/26, Appendix VI 79
(3.6mg/100kJ) study supporting acceptance of the method are presented in the method.
References: JAOAC 68: 514 - 522 (1985), J. AOAC Int. 80: 834 - 844
(1997).
Magnesium Minimum AOAC 984.27 ICP emission Type III
5mg/100kcal spectroscopy
(1.2mg/100kJ); no
Validated
maximum limit.
GUL Reference: JAOAC 67: 985 - 992 (1984).
15mg/100kcal
(3.6mg/100kJ)
Chloride Minimum AOAC 986.26 Potentiometry Type II
50mg/100kcal Validated
(12mg/100kJ);
Reference: JAOAC 69: 777 - 785 (1986).
maximum
160mg/100kcal
(38mg/100kJ); no
GUL
Manganese Minimum AOAC 985.35 Atomic absorption Type II
1µg/100kcal spectrophotometry Validated. Interlaboratory study matrices include enteral product, ready-to-
(0.25µg/100kJ); feed soy formula, soy powder and whey powder (same matrices as 986.24
no maximum phosphorus).
limit. GUL
References: JAOAC 68: 514 - 522 (1985)
100µg/100kcal
(24µg/100kJ) J. AOAC Int. 80: 834 - 844 (1997).
Manganese Minimum AOAC 984.27 ICP emission Type III
1µg/100kcal spectroscopy Validated
(0.25µg/100kJ);
Reference: JAOAC 67: 985 - 992 (1984).
no maximum
limit. GUL
100µg/100kcal
(24µg/100kJ)
Iodine Minimum AOAC 992.24 Ion-selective Type II, for milk-based formula
10µg/100kcal potentiometry Current Codex method for milk-based follow-up formula, and was listed in
(2.5µg/100kJ); no CODEX STAN 234 (2006 revision) for milk-based infant formula (Type II
maximum limit; method).
GUL 60
ALINORM 09/32/26, Appendix VI 80
be needed in these
levels for IF made
in regions with a
high content of
copper in the
water supply".
Copper Minimum AOAC 984.27 ICP emission Type III
35µg/100kcal spectroscopy Validated for infant formula
(8.5µg/100kJ); no
Reference: JAOAC 67: 985 - 992 (1984).
maximum limit.
GUL
120µg/100kcal
(29µg/100kJ).
Footnote:
“adjustment may
be needed in these
levels for IF made
in regions with a
high content of
copper in the
water supply".
Zinc Minimum AOAC 985.35 Atomic absorption Type II
0.5mg/100kcal spectroscopy Applicable to Ca, Mg, Fe, Zn, Cu, Mn, Na, and K.
(0.12mg/100kJ);
Validated. Interlaboratory study matrices include enteral product, ready-to-
no maximum
feed soy formula, soy powder and whey powder (same matrices as 986.24
limit. GUL
Phosphorus). The results of the interlaboratory study supporting acceptance of
1.5mg/100kcal
the method are presented in the method
(0.36mg/100kJ)
References: JAOAC 68: 514 - 522 (1985)
J. AOAC Int. 80: 834 - 844 (1997).
Zinc Minimum AOAC 984.27 ICP emission Type III
0.5mg/100kcal spectroscopy Validated for infant formula.
(0.12mg/100kJ);
Reference: JAOAC 67: 985 - 992 (1984).
no maximum
limit. GUL
1.5mg/100kcal
ALINORM 09/32/26, Appendix VI 82
(0.36mg/100kJ)
Choline Note on the form of Choline in CODEX STAN 72.
The standard provides no qualification on the form of choline.
Comment: Free choline is one of a number of salts used as supplement. However a number of bound forms are also present in infant formulas including
added lecithin and endogenous components of milk phospholipid. Units of expression also require definition (eg as choline hydroxide).
Choline Minimum AOAC 999.14 Enzymatic Type II, with limitations on applicability due to choline and ascorbate
7mg/100kcal Colorimetric concentration.
(1.7mg/100kJ); no Method 4. Validated.
maximum limit; 5. The method is applicable to the determination of choline in milk and
GUL infant formula containing 45-175 mg solids/100 g. The method does
50mg/100kcal not apply to powdered infant formula/milk containing more than 100
(12mg/100kJ) mg vitamin C/100 g solids because of ascorbate suppression of color
development. The results of the interlaboratory study supporting
acceptance of the method are included in the method.
6. References: J.AOAC Int. 83: 131 - 138 (2000).
JAOAC 87: 1297-1304 (2004)
Chromium Minimum EN 14082 AAS after dry Type IV
(Section B of 1.5µg/100kcal ashing Foodstuffs. Determination of lead, cadmium, zinc, copper, iron, and
STAN 72 only) (0.4µg/100kJ); no chromium by AAS after dry ashing. Infant formula was not included in the
maximum limit. validation.
GUL
10µg/100kcal
(2.4µg/100kJ)
Chromium Minimum EN 14083 Graphite furnace Type IV.
(Section B of 1.5µg/100kcal AAS after pressure Foodstuffs. Determination of lead, cadmium, chromium and molybdenum by
STAN 72 only) (0.4µg/100kJ); no digestion GF-AAS after pressure digestion. Infant formula was not included in the
maximum limit. validation.
GUL
10µg/100kcal
(2.4µg/100kJ)
Chromium Minimum AOAC 2006.03 ICP emission Type IV
(Section B of 1.5µg/100kcal spectroscopy Arsenic, Cadmium, Cobalt, Chromium, Lead, Molybdenum, Nickel, and
STAN 72 only) (0.4µg/100kJ); no Selenium in Fertilizers (Microwave Digestion and Inductively Coupled
maximum limit. Plasma-Optimal Emission Spectrometry). Infant formula was not included in
GUL the validation.
ALINORM 09/32/26, Appendix VI 83