11

IRISH HEALTH TRADE ASSOCIATIONIRISH HEALTH TRADE ASSOCIATIONWorking together towards a healthier IrelandWorking together towards a healthier Ireland

Annual General MeetingAnnual General Meeting

18 May 201118 May 2011

Presentation by:Presentation by:

Alan Ruth, Chief Executive Officer Alan Ruth, Chief Executive Officer

22

This is a Pan European Union war!This is a Pan European Union war!

33

LOBBYING ACTIVITY WITH MEPsLOBBYING ACTIVITY WITH MEPs

Liam Aylward, Brian Crowley and Pat the Cope Gallagher Liam Aylward, Brian Crowley and Pat the Cope Gallagher (all FF/ALDE)(all FF/ALDE)

Marian Harkin Marian Harkin (Independent/EPP)(Independent/EPP) and Mairead McGuinness and Mairead McGuinness (FG/EPP)(FG/EPP)

Gay Mitchell and Sean Kelly Gay Mitchell and Sean Kelly (both FG/EPP)(both FG/EPP)

Nessa Childers and Parliamentary Assistant Nessa Childers and Parliamentary Assistant (Lab/S&D) (Lab/S&D) and Proinsias De Rossaand Proinsias De Rossa (Lab/S&D) (Lab/S&D)

Paul Murphy Paul Murphy (Socialist Party/GUE/NGL)(Socialist Party/GUE/NGL)

Jim HigginsJim Higgins (FG/EPP) (FG/EPP)

44

Parliamentary Question Parliamentary Question for written answer 19 April 2011 (Mairead McGuinness)for written answer 19 April 2011 (Mairead McGuinness)

Subject: Full implementation of Directive 2002/46/ECSubject: Full implementation of Directive 2002/46/EC

The Commission has recently responded to numerous parliamentary questions on the implementation ofThe Commission has recently responded to numerous parliamentary questions on the implementation of ArticleArticle  5 5 of Directive 2002/46/EC, of Directive 2002/46/EC, relating to the failure of the Commission to produce a proposal on maximum amountsrelating to the failure of the Commission to produce a proposal on maximum amounts to to be included per daily portion of vitamin and mineral food supplements.be included per daily portion of vitamin and mineral food supplements.

This failure of implementation leads to confusion among consumers and increased costs for food supplement This failure of implementation leads to confusion among consumers and increased costs for food supplement manufacturers faced with different rules in different Member States.manufacturers faced with different rules in different Member States. This is contrary both to the intention of the This is contrary both to the intention of the directive and the spirit of the Single Market. The criteria for setting maximum amounts are set out in Article 5 of directive and the spirit of the Single Market. The criteria for setting maximum amounts are set out in Article 5 of the directive: ‘Upper safe levels of vitamins and minerals established by scientific risk assessment’ and ‘Intake of the directive: ‘Upper safe levels of vitamins and minerals established by scientific risk assessment’ and ‘Intake of vitamins and minerals from other dietary sources’.vitamins and minerals from other dietary sources’.

Independent scientific safety evaluations of vitamins and minerals were completed several years ago by the Independent scientific safety evaluations of vitamins and minerals were completed several years ago by the European Food Safety Authority and other international scientific bodies. European Food Safety Authority and other international scientific bodies. The Commission should therefore be in The Commission should therefore be in a position to fulfill its obligations under the directivea position to fulfill its obligations under the directive..

Are there any specific issues delaying a proposal, relating to disagreement on the upper safe levels set for Are there any specific issues delaying a proposal, relating to disagreement on the upper safe levels set for specific vitamins or minerals or the risk management methodology for setting maximum amounts? If so, can the specific vitamins or minerals or the risk management methodology for setting maximum amounts? If so, can the Commission clearly indicate what these issues are and what is being done to resolve them?Commission clearly indicate what these issues are and what is being done to resolve them?

Can the Commission provide a clear indication of when it will put forward the proposal required to secure the full Can the Commission provide a clear indication of when it will put forward the proposal required to secure the full implementation of a directive that was adopted in 2002?implementation of a directive that was adopted in 2002?

55

Parliamentary Question for Written Answer (5 April 2011) Parliamentary Question for Written Answer (5 April 2011) Liam Aylward (ALDE), Pat the Cope Gallagher (ALDE) Liam Aylward (ALDE), Pat the Cope Gallagher (ALDE)

and Brian Crowley (ALDE)and Brian Crowley (ALDE)

Subject: Regulation (EC) No 1924/2006 on nutrition and health claims made on foodsSubject: Regulation (EC) No 1924/2006 on nutrition and health claims made on foods

The implementation of Regulation (EC) No 1924/2006 on nutrition and health claims made on The implementation of Regulation (EC) No 1924/2006 on nutrition and health claims made on food is causing significant problems for producers working in the natural products industry. There food is causing significant problems for producers working in the natural products industry. There are concerns that the European Food Safety Authority (EFSA) is applying an unsuitable are concerns that the European Food Safety Authority (EFSA) is applying an unsuitable pharmaceutical assessment model for the assessment of generic health maintenance claims. pharmaceutical assessment model for the assessment of generic health maintenance claims. Can the Commission outline the methodology used by the EFSA to evaluate Article 13.1 health Can the Commission outline the methodology used by the EFSA to evaluate Article 13.1 health claims under this Regulation?claims under this Regulation?

In the absence of a Commission conducted impact assessment on the consequences of the In the absence of a Commission conducted impact assessment on the consequences of the model applied, sectors of the industry (European Health Claims Alliance) have conducted their model applied, sectors of the industry (European Health Claims Alliance) have conducted their own pan-EU impact assessment on the economic consequences of the current EFSA approach own pan-EU impact assessment on the economic consequences of the current EFSA approach to the assessment of Article 13 health claims. This study concluded that the non-vitamins and to the assessment of Article 13 health claims. This study concluded that the non-vitamins and minerals section of the EU market for food supplements may decrease in size by about 25% minerals section of the EU market for food supplements may decrease in size by about 25% threatening the viability of many EU businesses. Customers would also loose out because of threatening the viability of many EU businesses. Customers would also loose out because of reduced choice and potentially higher prices. reduced choice and potentially higher prices.

What is the response of the Commission to this industry impact assessment? What measures What is the response of the Commission to this industry impact assessment? What measures does the Commission have in place to ensure that this Regulation does not result in the closure does the Commission have in place to ensure that this Regulation does not result in the closure of businesses and the loss of jobs in this sector? Furthermore, how can the Commission ensure of businesses and the loss of jobs in this sector? Furthermore, how can the Commission ensure that this Regulation does not result in consumers having less choice?that this Regulation does not result in consumers having less choice?

66

LOBBYING NORTHERN IRISH MEPsLOBBYING NORTHERN IRISH MEPs

Jim Jim NicholsonNicholson UUP/EPPUUP/EPP

BairbreBairbre de de BrunBrun (SF/GUE/NGL) (SF/GUE/NGL)

DianeDiane Dodds Dodds (DUP/NA)(DUP/NA)

77

IRELANDIRELAND PUNCHES WELL ABOVE ITS WEIGHT PUNCHES WELL ABOVE ITS WEIGHT

European Health Claims Workshop for MEPs and their Parliamentary Assistants on 20 April 2011European Health Claims Workshop for MEPs and their Parliamentary Assistants on 20 April 2011

Co-chaired by: Marian Harkin MEP (Ireland) and Boguslaw Sonik (Poland)Co-chaired by: Marian Harkin MEP (Ireland) and Boguslaw Sonik (Poland)

MEPs and PAs attendance league table:MEPs and PAs attendance league table:

Joint 1Joint 1stst:: Ireland = 4 UK (including N. Ireland) = 4 Italy = 4 Ireland = 4 UK (including N. Ireland) = 4 Italy = 4

Joint 4Joint 4thth France = 3 Poland = 3 France = 3 Poland = 3

66thth Czech Republic = 2 Czech Republic = 2

Joint 7Joint 7thth Finland = 1 Bulgaria = 1 Netherlands = 1 Finland = 1 Bulgaria = 1 Netherlands = 1

All other Member StatesAll other Member States = 0 MEP/PA attendees = 0 MEP/PA attendees

88

THERE ARE MORE QUESTIONS THAN ANSWERS!THERE ARE MORE QUESTIONS THAN ANSWERS!

What do you want me to do? – Gay MitchellWhat do you want me to do? – Gay Mitchell

What do you want me to do? – Sean KellyWhat do you want me to do? – Sean Kelly

What should I do? – Nessa Childers to her Parliamentary AsstWhat should I do? – Nessa Childers to her Parliamentary Asst

What do you want us to do? – What do you want us to do? – Mairead McGuinness & Marian HarkinMairead McGuinness & Marian Harkin

For example, would you like me to make an appointment to see Commissioner Dalli?For example, would you like me to make an appointment to see Commissioner Dalli?- Marian Harkin- Marian Harkin

John Dalli – Commissioner for Health & Consumer PolicyJohn Dalli – Commissioner for Health & Consumer Policy

Máire Geoghegan-Quinn – Commissioner for Research, Innovation & ScienceMáire Geoghegan-Quinn – Commissioner for Research, Innovation & Science

Antonio Tajani – Commissioner for Industry & Entrepreneurship Antonio Tajani – Commissioner for Industry & Entrepreneurship (former President of the EPP) (former President of the EPP)

99

EVOLUTION OF KEY IHTA ACTIVITIESEVOLUTION OF KEY IHTA ACTIVITIES

Greater focus (input from SIT) for CEO >>>>>>>>>>>>Greater focus (input from SIT) for CEO >>>>>>>>>>>>

Further relationship building & influencing MEPs, IMB, FSAI , DoHC Further relationship building & influencing MEPs, IMB, FSAI , DoHC >>>>>>>>

Influencing & pushing EHPM >>>>>>>>Influencing & pushing EHPM >>>>>>>>

Sharing information internationally Sharing information internationally >>>>>>>>

>>>>>>>>>> RaisingRaising the the IHTAIHTA profile & impact profile & impact Informing members Informing members >>>>>>>>

1010

SOME THINGS I’VE PUSHED EHPM ONSOME THINGS I’VE PUSHED EHPM ON

Becoming more goal and objective oriented in relation to ‘key issues’Becoming more goal and objective oriented in relation to ‘key issues’

Getting inactive national association EHPM members to take action on key issuesGetting inactive national association EHPM members to take action on key issues

Developing and agreeing an EHPM European StrategyDeveloping and agreeing an EHPM European Strategy

Being more forceful in communications with the Commission and EFSA officialsBeing more forceful in communications with the Commission and EFSA officials

Ensuring that the Health Claims Impact Assessment was carried out using a sound methodologyEnsuring that the Health Claims Impact Assessment was carried out using a sound methodology

Getting IASDA to alert member associations to both + ve and - ve research news and issue Getting IASDA to alert member associations to both + ve and - ve research news and issue rebuttals, much more quickly.rebuttals, much more quickly.

Getting eminent scientists to challenge EFSA’s approach to evaluating health claimsGetting eminent scientists to challenge EFSA’s approach to evaluating health claims

Encouraging the sharing of information between the national associations which constitute EHPMEncouraging the sharing of information between the national associations which constitute EHPM

Development of an EHPM botanical supplements strategyDevelopment of an EHPM botanical supplements strategy

1111

AFTER ABOUT 3 YEARS OF PUSHINGAFTER ABOUT 3 YEARS OF PUSHING

From: Elodie LebastardFrom: Elodie Lebastard

E-mail dated 17 December 2010E-mail dated 17 December 2010

To: All Members EHPMTo: All Members EHPM

Subject: EHPM Strategic Plan 2011-2014Subject: EHPM Strategic Plan 2011-2014

Dear Members,Dear Members,

Earlier this year, the EHPM Board decided that it was necessary to develop a Strategic Programme for Earlier this year, the EHPM Board decided that it was necessary to develop a Strategic Programme for the organisation. This was subsequently developed by the Board and presented for comments at the the organisation. This was subsequently developed by the Board and presented for comments at the EHPM Council of Presidents meeting in September in Brussels. Further to that discussion, amendments EHPM Council of Presidents meeting in September in Brussels. Further to that discussion, amendments were made and the programme was adopted this week by the Board.were made and the programme was adopted this week by the Board.

1212

EHPM COMPLAINT TO EUROPEAN OMBUDSMAN (EO)EHPM COMPLAINT TO EUROPEAN OMBUDSMAN (EO)

In July 2010 EHPM issued a complaint to the EO against the Commission & EFSA In July 2010 EHPM issued a complaint to the EO against the Commission & EFSA

The complaint challenged the decision of the EC and EFSA in relation to a batch-wise approach to the Community list of The complaint challenged the decision of the EC and EFSA in relation to a batch-wise approach to the Community list of permitted Article 13.1 claims.permitted Article 13.1 claims.

The complaint called upon the EO to issue a formal recommendation that the Commission should wait for EFSA to deliver The complaint called upon the EO to issue a formal recommendation that the Commission should wait for EFSA to deliver all of its evaluations on the Article 13.1 claims, on grounds that the batch-wise approach being used was all of its evaluations on the Article 13.1 claims, on grounds that the batch-wise approach being used was ‘maladministration’.‘maladministration’.

In late September the EC announced that it had revised the way it will adopt rulings on Article 13 health claims into law.In late September the EC announced that it had revised the way it will adopt rulings on Article 13 health claims into law.

EHPM decided to withdraw its complaint because the goal of remedying batch-wise adoption of claims by the EC had EHPM decided to withdraw its complaint because the goal of remedying batch-wise adoption of claims by the EC had been achievedbeen achieved

>>>>>>> >>>>>>> Avoidance of the distortion of the market that would have followed a batch-wise approach Avoidance of the distortion of the market that would have followed a batch-wise approach>>>>>>> >>>>>>> New time-line provided a significant amount of time for industry to continue discussions with EC & MSs New time-line provided a significant amount of time for industry to continue discussions with EC & MSs

About a year before EHPM issued its complaint to the Ombudsman, I proposed such action at an EHPM Board meeting. About a year before EHPM issued its complaint to the Ombudsman, I proposed such action at an EHPM Board meeting. My proposal was rejected. It was also thought not to be a good idea by Jean Savigny (EHPM’s main legal advisor)!My proposal was rejected. It was also thought not to be a good idea by Jean Savigny (EHPM’s main legal advisor)!

1313

Raising the IHTA profile in EuropeRaising the IHTA profile in Europe

1414

Raised IHTA profile within EuropeRaised IHTA profile within Europe

IHTA’s CEO re-elected to second term on EHPM BoardIHTA’s CEO re-elected to second term on EHPM Board

Proposal/discussion document for EHPM botanical supplements strategyProposal/discussion document for EHPM botanical supplements strategy

Complaint to European Ombudsman eventually made & was successfulComplaint to European Ombudsman eventually made & was successful

In April 2010, the EP Petitions Committee agreed to keep open, the IHTA’s petition questioning In April 2010, the EP Petitions Committee agreed to keep open, the IHTA’s petition questioning the Commission’s proposal to limit maximum levels. the Commission’s proposal to limit maximum levels.

Leading scientists (from Europe & U.S.) now “challenging” EFSA ‘s approach to evaluating Leading scientists (from Europe & U.S.) now “challenging” EFSA ‘s approach to evaluating Article 13.1 claims. I pushed EHPM to use U.S. scientists over a year previously.Article 13.1 claims. I pushed EHPM to use U.S. scientists over a year previously.

More strategic thinking by EHPM – “strategy’ is now in the “inner circle’s” vocabularyMore strategic thinking by EHPM – “strategy’ is now in the “inner circle’s” vocabulary

Invitation to dinner from Marjan Willaert (President, NAREDI, Belgium) to discuss common Invitation to dinner from Marjan Willaert (President, NAREDI, Belgium) to discuss common concernsconcerns

Request from Massimiliano Carnassalle, Secretary General, FEDERSALUS to place IHTA Request from Massimiliano Carnassalle, Secretary General, FEDERSALUS to place IHTA Briefing Notes on their websiteBriefing Notes on their website

Request from Camil Rodino (Secretary General, Afepadi, Spain) to visit Ireland to meet with meRequest from Camil Rodino (Secretary General, Afepadi, Spain) to visit Ireland to meet with me

Regular communication and assistance from: a Spanish Professor of Food Law, a Spanish Food Regular communication and assistance from: a Spanish Professor of Food Law, a Spanish Food Law Consultant, and other European colleagues.Law Consultant, and other European colleagues.

1515

ACTIVITIES WITH THE IMBACTIVITIES WITH THE IMB

1616

ACTIVITIES WITH THE IMBACTIVITIES WITH THE IMB

2 IHTA Herbal sub-committee meetings (August & September) 20102 IHTA Herbal sub-committee meetings (August & September) 2010

- To formulate an IHTA ‘consolidated’ response to 3 documents published on IMB website i.e.- To formulate an IHTA ‘consolidated’ response to 3 documents published on IMB website i.e.

(1) List of plant substances not permitted in foods or food supplements (draft guide)(1) List of plant substances not permitted in foods or food supplements (draft guide)

(2) List of herbal substances which may be acceptable for inclusion in food supplements (draft (2) List of herbal substances which may be acceptable for inclusion in food supplements (draft guideline)guideline)

(3) Herbal medicines on the Irish market 2010(3) Herbal medicines on the Irish market 2010

IHTA submission presented to IMB on 29/9/10 requested 49 substances be added to “positive” listIHTA submission presented to IMB on 29/9/10 requested 49 substances be added to “positive” list

IMB revised “positive” list had 99 substances addedIMB revised “positive” list had 99 substances added

IMB revised “negative” list had 54 substances addedIMB revised “negative” list had 54 substances added

1717

ACTIVITIES WITH THE IMBACTIVITIES WITH THE IMB

On 28 March – sent request/submission to IMB to add 21 herbal/plant substances to IMB revised On 28 March – sent request/submission to IMB to add 21 herbal/plant substances to IMB revised list dated 1 March of Herbal substances which may be acceptable in FSslist dated 1 March of Herbal substances which may be acceptable in FSs

Cited ‘Homeostasis Model’ and dosageCited ‘Homeostasis Model’ and dosage

Cited Belgian Royal Decree of 29 August 1997Cited Belgian Royal Decree of 29 August 1997

Cited Hungary as going the dosage routeCited Hungary as going the dosage route

Cited & provided link to ‘It’s the Dosage, Stupid …..’ articleCited & provided link to ‘It’s the Dosage, Stupid …..’ article

Provided evidence for the food/culinary use of the 21 substancesProvided evidence for the food/culinary use of the 21 substances

1818

Dr. Mike Morris’s replyDr. Mike Morris’s reply

I have had a look at your proposals and would not necessarily disagree with them. I intend to seek I have had a look at your proposals and would not necessarily disagree with them. I intend to seek opinion of our expert sub-committee in this regard. opinion of our expert sub-committee in this regard.

I cannot see a problem with substances that are clearly culinary herbs.I cannot see a problem with substances that are clearly culinary herbs.

However, I do have a problem with the whole concept at this stage. The lists were established to However, I do have a problem with the whole concept at this stage. The lists were established to try to distinguish medicinal from food herbs, and as you say, there is often not a clear separation try to distinguish medicinal from food herbs, and as you say, there is often not a clear separation because the outcome is product specific.because the outcome is product specific.

Furthermore, the positive list is very much open ended, since there are potentially thousands of Furthermore, the positive list is very much open ended, since there are potentially thousands of herbal substances which can be, and are, used in foods.herbal substances which can be, and are, used in foods.

My biggest concern is that the IMB does not regulate foods, and it becomes the responsibility of My biggest concern is that the IMB does not regulate foods, and it becomes the responsibility of the FSAI. I would like to see them take over this list and will be suggesting this to them. the FSAI. I would like to see them take over this list and will be suggesting this to them.

The IMB list does not delineate what the FSAI could accept as a food supplement.The IMB list does not delineate what the FSAI could accept as a food supplement.

Consequently, my preferred option is not to extend the positive list further since it cannot cover Consequently, my preferred option is not to extend the positive list further since it cannot cover everything, but rather to identify a list of herbal substances which might be acceptable for THMPs, everything, but rather to identify a list of herbal substances which might be acceptable for THMPs, as opposed to those that would not. I would welcome your thoughts on this approach.as opposed to those that would not. I would welcome your thoughts on this approach.

1919

IHTA Submission to IMB re vitamin B12IHTA Submission to IMB re vitamin B12

In Summer 2010, FSAI wrote to several IHTA companies re products containing ingredients In Summer 2010, FSAI wrote to several IHTA companies re products containing ingredients “considered medicinal substances in Ireland”“considered medicinal substances in Ireland”

Vitamin B12, at a daily dose of above 25 mcg, was one of theseVitamin B12, at a daily dose of above 25 mcg, was one of these

IHTA made a very detailed written submission to IMB requesting that food supplements IHTA made a very detailed written submission to IMB requesting that food supplements containing a very much higher daily dose be permitted without prescriptioncontaining a very much higher daily dose be permitted without prescription

Submission highlighted a number of international comparisons, to strongly make the point that 25 Submission highlighted a number of international comparisons, to strongly make the point that 25 mcg is a very low dose of B12 to act as a prescription threshold.mcg is a very low dose of B12 to act as a prescription threshold.

Response from Dr. Mike Morris:Response from Dr. Mike Morris:

Dear Alan,Dear Alan, Thank you for your e-mail, received also in hard copy.Thank you for your e-mail, received also in hard copy. I have sympathy with the points you raise but fundamentally the hands of IMB are tied by the I have sympathy with the points you raise but fundamentally the hands of IMB are tied by the

prescription legislation – this is the property of DoHC not IMB. prescription legislation – this is the property of DoHC not IMB.

I will revert to you as soon as I can with a more substantial response to the points you make in I will revert to you as soon as I can with a more substantial response to the points you make in your very helpful letter.your very helpful letter.

Yours sincerely,Yours sincerely, MikeMike

2020

IMB Sell-through period IMB Sell-through period for unregistered products (THMPs) come 1 May?for unregistered products (THMPs) come 1 May?

Proved to be a bit of a saga beginning mid-December, when I first raised the questionProved to be a bit of a saga beginning mid-December, when I first raised the question

Over the following months, I persevered for an answerOver the following months, I persevered for an answer

Mike Morris provided information bit by bitMike Morris provided information bit by bit

I shared this with members and the IAHS as and when it became availableI shared this with members and the IAHS as and when it became available

Eventually the IMB decided to host a meeting on 31 March – to clarify the IMB’s approach to Eventually the IMB decided to host a meeting on 31 March – to clarify the IMB’s approach to THMPs when the transition period ends on 30 April.THMPs when the transition period ends on 30 April.

The IHTA learned about this meeting on 28 March (3 days in advance) and informed members The IHTA learned about this meeting on 28 March (3 days in advance) and informed members immediately.immediately.

Notes on the meeting were made available to IHTA membersNotes on the meeting were made available to IHTA members

2121

ACTIVITIES WITH THE FSAIACTIVITIES WITH THE FSAI

2222

ACTIVITIES WITH THE FSAIACTIVITIES WITH THE FSAI

25 May 2010 – FSAI Health Claims Seminar25 May 2010 – FSAI Health Claims Seminar

Speakers (regulators):Speakers (regulators):

- Prof. Albert Flynn (EFSA), Dr. Mike Morris (IMB) Dr. Mary Flynn (FSAI), Dr. Sarah Burke (FSAI)- Prof. Albert Flynn (EFSA), Dr. Mike Morris (IMB) Dr. Mary Flynn (FSAI), Dr. Sarah Burke (FSAI)

Speakers (industry):Speakers (industry):

- Dr. Judith Bryans (The Dairy Council, UK)- Dr. Judith Bryans (The Dairy Council, UK)

- John Redman (Group MD, Merck Consumer Healthcare, UK) & Vice-Chair HFMA)- John Redman (Group MD, Merck Consumer Healthcare, UK) & Vice-Chair HFMA)

Booklets:Booklets:

- Information on Nutrition & Health Claims (April 2010)Information on Nutrition & Health Claims (April 2010)

- Guidance Notes: Food Supplements Regulations and Notifications (Revision 1)Guidance Notes: Food Supplements Regulations and Notifications (Revision 1)

2323

ACTIVITIES WITH THE FSAIACTIVITIES WITH THE FSAI

In February 2011, requested that the list of food supplements notified to FSAI be placed on FSAI In February 2011, requested that the list of food supplements notified to FSAI be placed on FSAI websitewebsite

Initial response from Dr. Mary Flynn:Initial response from Dr. Mary Flynn:

- expressed concern re protecting information confidentiality for FBOs- expressed concern re protecting information confidentiality for FBOs

- need to consider products notified as FSs which the FSAI referred to IMB- need to consider products notified as FSs which the FSAI referred to IMB

- need to explore if any downsides for FBOs by sharing list of names & products notified- need to explore if any downsides for FBOs by sharing list of names & products notified

Mary phoned me end March to say that FSAI would act on our requestMary phoned me end March to say that FSAI would act on our request

E-mailed me on 8 April – FSAI had become aware of legal issues which may prevent compliance E-mailed me on 8 April – FSAI had become aware of legal issues which may prevent compliance with our requestwith our request

2424

Position paper on to Food Information to ConsumersPosition paper on to Food Information to Consumers

Last month I sent Dr. Mary Flynn and Anne Marie Boland the IHTA’s position statement regarding Last month I sent Dr. Mary Flynn and Anne Marie Boland the IHTA’s position statement regarding the future Regulation on food information to consumers. the future Regulation on food information to consumers.

The minimum font size of respectively 1.2 mm and 0.9 mm for packages of less than 60 square The minimum font size of respectively 1.2 mm and 0.9 mm for packages of less than 60 square cms, proposed by the Council under article 13.2 and 13.s is impractical and a disproportionate cms, proposed by the Council under article 13.2 and 13.s is impractical and a disproportionate burden for manufacturers, in the case of FSs and other specialist health products.burden for manufacturers, in the case of FSs and other specialist health products.

Strongly support the amendment , already introduced by the EP at 1st reading, regarding the Strongly support the amendment , already introduced by the EP at 1st reading, regarding the exemption from providing all mandatory particulars in article 16.2 for packages/containers with exemption from providing all mandatory particulars in article 16.2 for packages/containers with the largest printable surface of the largest printable surface of < 80 square cms< 80 square cms

Should the EP adopt an approach requiring a mandatory font size, we believe that any such Should the EP adopt an approach requiring a mandatory font size, we believe that any such requirement would have to be proportionate and take due account of a number of points made in requirement would have to be proportionate and take due account of a number of points made in the IHTA position.the IHTA position.

Support was expressed for 2 proposed amendments i.e. (1) No mandatory font size labelling, (2) Support was expressed for 2 proposed amendments i.e. (1) No mandatory font size labelling, (2) Mandatory font size of 1 mm or lessMandatory font size of 1 mm or less

Opposition to any amendment requiring a mandatory font size of more than 1 mmOpposition to any amendment requiring a mandatory font size of more than 1 mm

2525

TARGETED IRISH GOVERNMENT MINISTERSTARGETED IRISH GOVERNMENT MINISTERS

Minister Roisin Shortall TD (Minister for Primary Care, Department of Health)Minister Roisin Shortall TD (Minister for Primary Care, Department of Health)

Minister John Perry (Minister for Small Business)Minister John Perry (Minister for Small Business)

2626

THANK YOU FOR YOURTHANK YOU FOR YOUR

ONGOING SUPPORTONGOING SUPPORT