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Draft discussion paper 29.10.2009

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Draft discussion paper 29.10.2009 Powered By Docstoc
					   JOINT FAO/WHO FOOD STANDARDS PROGRAMME

           CODEX COMMITTEE ON FOOD LABELLING
                  THIRTY-EIGHTH SESSION
              QUEBEC CITY, CANADA, MAY 2010




  DRAFT DISCUSSION PAPER FROM THE ELECTRONIC
 WORKING GROUP ON LABELLING PROVISIONS DEALING
 WITH THE FOOD INGREDIENTS IDENTIFIED IN THE WHO
 GLOBAL STRATEGY ON DIET, PHYSICAL ACTIVITY AND
                    HEALTH




October 2009                              Page 1 of 31
DRAFT DISCUSSION PAPER ON LABELLING PROVISIONS DEALING WITH
THE FOOD INGREDIENTS IDENTIFIED IN THE GLOBAL STRATEGY ON DIET,
PHYSICAL ACTIVITY AND HEALTH

The 37th Session of the Codex Committee on Food Labelling decided to continue the
electronic working group (eWG) on labelling provisions dealing with the food ingredients
identified in the Global Strategy on Diet, Physical Activity and Health (CL 2006/44-CAC).

According to paragraph 76 in the report from the 37th Session of the CCFL (ALINORM
09/32/22), the mandate of the working group is as follows:

Considering the food ingredients identified in paragraph 22 of the Global Strategy on Diet,
Physical Activity and Health, i.e., fruits and vegetables and legumes, whole grains and nuts,
and free/added sugars and salt (sodium), the electronic working group will:
    review and revise the list of proposed actions in CRD 1 in order to focus on those
       ingredients identified in the Global Strategy as mentioned above
    identify paragraphs in existing Codex texts on food labelling under which food
       ingredients identified in the Global Strategy can be addressed; and
    prepare a discussion paper for consideration by the 38th session of the CCFL.

An invitation to participate in the eWG was sent to all Codex members in September 2009.
The list of participants can be found in Annex IV.

The objectives of this first correspondence to the members of the eWG are to:

1.     outline the proposed process and time frame;
2.     outline the goals of the working group;
3.     provide a first draft of the discussion paper; and
4.     solicit comments from the electronic working group.

1. Proposed Process and Time Frame
The following table outlines the proposed timeline and key activities to meet the objectives
of the eWG:

Timeline               Key Activity                                            Duration
September 2009         Circulate the invitation to participate in the eWG      Two weeks
October 30, 2009-      Circulate the proposed time frame and draft             six weeks
December 15, 2009      discussion paper to e-wg members for comments.
December 15, 2009      Revision of the draft discussion paper by Norway        four weeks
to January 15, 2009    and Canada, based on the comments received.
January 15, 2009 to    Distribution of the revised discussion paper to eWG     four weeks
February 17, 2009      members for a final review.
February 18 to         Final revision of the draft paper by Norway and         four weeks
March 16, 2009         Canada, based on comments received.
March 16, 2009         Circulation of the revised discussion paper to eWG
                       members and the Codex Secretariat.




October 2009                                                                 Page 2 of 31
2. Goal of the Electronic Working Group

The goal of the working group is to prepare a discussion paper that further elaborates on the
work proposed at the 37th session of the CCFL (ALINORM 09/32/22). This discussion paper
will be presented at the 38th session of the CCFL in May 2010.

3. Draft Discussion Paper

A draft discussion paper has been prepared for the eWG‟s review and comments and is
available in Annex I.

4. Comments and Contact Information:

Comments on the proposed time frame and the draft discussion paper, and answers to the 4
questions at the end of the draft discussion paper are requested by December 15, 2009.
When reviewing the document, please specifically identify any information that should be
added, deleted or modified. eWG members are kindly requested to submit one consolidated
response per participant country or member organization. Please send your comments and
input to:

Ms. Heidi Bugge
Norwegian Food Safety Authority
E-mail: Heidi.Bugge@mattilsynet.no
Tel. +47 23 21 65 25

and

Ms. Charmaine Kuran
Canadian Food Inspection Agency
Email: charmaine.kuran@inspection.gc.ca
*After November 20, 2009: charmaine_kuran@hc-sc.gc.ca
Telephone: 011 (613) 773-5497

Your contribution to the success of the working group is appreciated.




October 2009                                                                 Page 3 of 31
                                        Annex I
                                 Draft Discussion Paper
1)      In preparing the draft discussion paper, the Co-Chairs first reviewed the proposed list
of 14 actions listed in CRD 1 at the 37th Session of CCFL in the table to Annex II. A
proposed conclusion to retain or remove the proposal from the discussion paper from the co-
chairs is presented therein. The Co-Chairs have worked through the 7 retained proposals and
have developed new proposed actions which are discussed in this paper.

Background

2)      The Global Strategy on Diet, Physical Activity and Health has four main objectives,
three of which can be linked in part to the work of CCFL:

      Reduce risk factors for chronic diseases that stem from unhealthy diets and physical
       inactivity through public health actions.
      Increase awareness and understanding of the influences of diet and physical activity
       on health and the positive impact of preventive interventions.
      Develop, strengthen and implement global, regional, national policies and action
       plans to improve diets and increase physical activity that are sustainable,
       comprehensive and actively engage all sectors.

3)      The eWG has been asked to examine labelling provisions dealing with the food
ingredients identified in the Global Strategy. Paragraph 22 of the Global Strategy identifies
that for diets, recommendations for populations and individuals should include the manners
in which to increase the consumption of fruits and vegetables, and legumes, whole grains and
nuts and limit the intake of free sugars and the consumption of salt (sodium) from all sources.
The term “free sugars” are used in the Report from the Expert Consultation and refers to all
monosaccharides and disaccharides added to food by the manufacturer, cook or consumer,
plus sugars naturally present in honey, syrups and fruit juices.

4)       Paragraph 59 of the Global Strategy states: Public health efforts may be strengthened
by the use of international norms and standards, particularly those drawn up by the Codex
Alimentarius Commission. Areas for further development could include could include:
labelling to allow consumers to be better informed about the benefits and content of foods;
measures to minimize the impact of marketing on unhealthy dietary patterns; fuller
information about healthy consumption patterns, including steps to increase the consumption
of fruit and vegetables…. Involvement of governments and nongovernmental organizations
as provided for in Codex should be encouraged.

5)      At the 36th session of the CCFL, the Committee considered comments received on
Agenda Item 2(B) Items Referred by FAO and WHO: Implementation of the WHO Global
Strategy on Diet, Physical Activity and Health (CX/FL 08/36/3) on Proposed Action 3.1:
Include paragraph 5.1.1 (e) “is the subject of an express or implied claim about the presence
of any fruits, vegetables, whole grains or added sugars” in any of the requirements for the
quantitative declaration of ingredients”.

6)     As noted in CX/FL 08/36/3, Paragraph 11, the great majority of member states did
not support this proposal in their written comments. They noted that this section was not
necessary because requirements to declare the quantities of emphasized ingredients already



October 2009                                                                  Page 4 of 31
exists, that the presence of these ingredients would not necessarily make a food healthful and
the list of healthful ingredients was not complete. It was suggested that express or implied
claims regarding the presence of healthful ingredients should be considered in relation to the
Codex Guidelines on Claims and the Codex Guidelines on Use of Nutrition and Health
Claims. There was no discussion of this proposal during the discussions on the
implementation of the Global Strategy.

7)      During discussions at the 36th CCFL, it was proposed to convene an eWG in order to
not lose sight of the ingredients identified in the Global Strategy and broaden the mandate of
the requested work to evaluate revisions needed to Codex texts on food labelling in light of
the Global Strategy; to consider the food ingredients identified in the Global Strategy; and
identify and recommend work to be undertaken by the CCFL with regard to these action
items. An intersession eWG led by Norway solicited comments from member states and
organizations which were presented in a preliminary report, CRD 1, at the 37th session of the
CCFL. There was general agreement by the Committee to reconvene the electronic working
group, co-chaired by Norway and Canada, to continue and complete its work. The terms of
reference for the eWG were outlined as follows:

       Considering the food ingredients identified in paragraph 22 of the Global Strategy on
       Diet, Physical Activity and Health, i.e., fruits and vegetables and legumes, whole
       grains and nuts, and free/added sugars and salt (sodium), the electronic working
       group will:
           o review and revise the list of proposed actions in CRD 1 in order to focus on
               those ingredients identified in the Global Strategy as mentioned above
           o identify paragraphs in existing Codex texts on food labelling under which
               food ingredients identified in the Global Strategy can be addressed; and
           o prepare a discussion paper for consideration by the 38th session of the CCFL.

Proposed Actions

   I. Proposed Actions Related to Fruits, Vegetables, Whole Grains, Nuts and Legumes

       8)      Based on the proposals received as part of the first round of work completed
       by the eWG between the 36th and 37th sessions of CCFL, the Co-Chairs suggest
       combining several of the concepts from the proposed actions from the 2008-2009
       eWG together related to claims on the content of fruits, vegetables, whole grains, nuts
       and legumes.

       9)      Two suggestions retained by the Co-Chairs suggested that: (a) Develop
       requirements for conditional claims related to the ingredients mentioned in the
       Global Strategy (fruits, vegetables, legumes, whole grains and nuts). The conditional
       requirements could be related to the amount of the ingredient present in the food and
       other nutritional characteristics (proposed action 4) and (b) Develop specific criteria
       or claim s to foods that have an adequate amount of the ingredients identified in the
       Global Strategy (proposed action 7) (see Annex II).

       10)     It is suggested that in order to make a claim about the effect attributed to the
       content of fruits, vegetables, whole grains, nuts or legumes on a food label that a
       minimum content of these be present in the food. Foods labelled with claims about
       the health benefits of the consumption of and claims related to dietary guidelines or



October 2009                                                                   Page 5 of 31
      healthy diets that relate to the consumption of fruits, vegetables, whole grains, nuts or
      legumes should contain at least a minimum amount of the named ingredient. It is
      suggested that the minimum content of fruits, vegetables, whole grains, nuts or
      legumes be equivalent to the amount contained in a serving of these as defined by
      National dietary guidelines.

       SUGGESTED ACTION:

       Add section 7.3.1 to the Guidelines for Use of Nutrition and Health Claims
       (CAC/GL 23-1997): If the claimed effect is attributed to the consumption of fruits,
       vegetables, whole grains, nuts or legumes, the food must contain at least one
       serving of the named ingredient as defined by National dietary guidelines per 100
       g or per serving of the food.


      11)     Further, it may be desirable for Codex to work towards developing a system
      that would identify the types of ingredients or number of servings through an easily
      recognized and consistent symbol system. This may assist people with lower literacy
      levels or children to choose foods that contain ingredients identified in the Global
      Strategy.

      12)     This is a result of proposed action 5 (see Annex II): Highlight this ingredients
      that show a benefit from a nutrition point of view, using standardized symbologies
      based on equivalency systems that allow consumers to identify them easily.

       13)     SUGGESTED ACTION:

       It is recommended that this be discussed and further explored by the CCFL at the
       38th Session. If there is consensus on the concept, a separate eWG could be
       formed to further develop this idea.


      14)     The Committee may wish to further discuss the possibility of adding a
      positive list of standard health claims to the Guidelines on Nutrition and Health
      Claims that are based on generally accepted science and that have been validated by
      an acceptable authoritative body. This could be initiated by asking the Codex
      Committee on Nutrition and Foods for Special Dietary Use (CCNFSDU) to examine
      claims related to the consumption of fruits, vegetables, whole grains, nuts or legumes
      and their role in the prevention of certain types of chronic disease. An example of this
      type of claim might be: “A healthy diet rich in a variety of vegetables and fruit may
      reduce the risk of certain types of cancer”.

        15)    SUGGESTED ACTION:

        It is recommended that this be discussed and further explored by the CCFL at the
        38th Session. If there is consensus on the concept, a separate eWG could be formed
        to further develop this idea.




October 2009                                                                  Page 6 of 31
   II.      Proposed Actions Related to Salt (Sodium) and Added Sugar

         16)     Where salt (sodium) and/or sugar have been added to a food that could be
         considered by a consumer to be a single ingredient food, the addition of the salt
         (sodium) and/or sugar should be indicated in close proximity to the common name of
         the food. So for instance, nuts which contain added salt would be required to state
         “salted nuts” or juice which contains added sugar would be required to state
         “sweetened apple juice”.

         17)     This proposal could expand on the current principles listed in the General
         Standard for the Labelling of Prepackaged Foods (GSLPF) (CODEX STAN 1-1985).
         This principle is covered in sections 4.1.1 and 4.1.1.3 of the GSLPF which states that
         “the name (of the food) shall indicate the true nature of the food and normally be
         specific and not generic” and “in the absence of (a prescribed common name), either
         a common or usual name existing by common usage as an appropriate descriptive
         term which was not misleading or confusing to the consumer shall be used”.

         18)     Section 4.1.2 of the GSLPF also states “there shall appear on the label either
         in conjunction with, or in close proximity to, the name of the food, such additional
         information or phrases as necessary to avoid misleading or confusing the consumer in
         regard to true nature and physical condition of the food including but not limited to
         the type of packing medium, style, and the condition or treatment it has undergone;
         for example: dried, concentrated, reconstituted, smoked.”

          19)     SUGGESTED ADDITION:

          4.1.3 (GSLPF) In accordance with sections 4.1.1 and 4.1.2, where the addition of
          salt or sugars* has occurred to a food normally considered to be a single ingredient
          food, an appropriate descriptive term shall be added to the common name. For
          example: salted roasted peanuts; sweetened apple juice; canned kidney beans with
          added salt, peaches packed in juice, etc.

          *Sugars are defined as “free sugars” in the Report from the Expert Consultation as
          “all monosaccharides and disaccharides added to food by the manufacturer, cook
          or consumer, plus sugars naturally present in honey, syrups and fruit juices”.

         20)     In discussions during the 37th session of CCFL, the Committee agreed to
         include sodium (salt) and total sugars in the list of nutrients for nutrition labelling.
         There continues to be debate with respect to terminology for sodium versus salt and
         for the inclusion of added sugars (still in square brackets). (Ref paragraphs 30 and 36
         in the Report (ALINORM 09/32/22)). In addition, the debate whether nutrition
         labelling should be mandatory or voluntary remains to be resolved. In the event that
         the Committee reaches the conclusion that nutrition labelling should not become
         mandatory as a general rule, it is proposed that this eWG consider the option to
         require nutrition labelling, including the declaration of sodium (salt) and total
         sugars/added sugar, if a food contains added sodium (from all sources) and/or added
         sugar. This would include if the sodium and/or sugar was declared in the list of
         ingredients or if a specific statement or claim was made for sodium (salt) and/or
         sugar.




October 2009                                                                    Page 7 of 31
        21)      SUGGESTED ACTION:

        A new section be inserted following 3.1.1 in the Guidelines on Nutrition Labelling
        (CAC/GL 2-1985) which states “Nutrient declaration should be mandatory for foods
        which contain added sodium and/or added sugar.”

        Sodium would include the ingredient salt (NaCl2) and all forms of sodium salts
        added to foods for food additive purposes, as flavour enhancers and for all other
        purposes.

      22)     The Committee should consider establishing new nutrient content claims in
      the Guidelines for Use of Nutrition and Health Claims for the non-addition of salt
      and/or sugars so that these claims are made in a manner that is truthful and not
      misleading.

       23)       SUGGESTED ADDITION:

       Table of conditions for nutrient contents
           Component        Claim                        Conditions (absence of addition)
           Sugars*          No added sugar, no           The food contains no added sugars, no
                            sugar added,                 ingredients containing added sugars or
                            without added sugar          ingredients that contain sugars that
                                                         functionally substitute for added sugars.
                                                         The regular food is permitted through a
                                                         standard of identity to contain added
                                                         sugar or normally contains added sugars
                                                         for foods which do not have a standard
                                                         of identity.
               Sugars           Unsweetened              Meets the “No added sugars” conditions
                                                         above and does not contain sugar
                                                         alcohols or artificial sweeteners.
               Salt (Sodium)    No added salt,           The food contains no added salt, other
                                unsalted, without        sodium salts**, or ingredients that
                                added salt               functionally substitute for added salt.
                                                         The regular food is permitted through a
                                                         standard of identity to contain added
                                                         salt or normally contains added salt for
                                                         foods which do not have a standard of
                                                         identity.
                 **Sugars are defined as “free sugars” in the Report from the Expert Consultation as
                 “all monosaccharides and disaccharides added to food by the manufacturer, cook or
                 consumer, plus sugars naturally present in honey, syrups and fruit juices”
                 *sodium salts include those added to foods for food additive purposes or for other
                 purposes

      24)      It is suggested that the Committee also further expand on section 6 in the
      Guidelines for Use of Nutrition and Health Claims and consider explicitly setting out
      criteria for nutrient comparative claims related to the reduced addition of salt
      (sodium) or sugar to a food. The use of such claims may help to encourage the



October 2009                                                                      Page 8 of 31
      reformulation by industry of certain foods to contain less added salt and/or sugar. In
      order to make such a claim valid and to account for variation in nutrient content, it is
      suggested that a minimum reduction for such a claim by at least 25% less than the
      original food product formulation.

    25)       SUGGESTED ADDITION:

    Table of conditions for nutrient contents

    Component        Claim                   Conditions
    Sugar*           X% less added           The food contains at least 25% less added
                     sugar                   sugar than the original formulation
    Salt             X% less added salt      The food contains at least 25% less added salt
    (Sodium)**                               (sodium) than the original formulation
          *Sugars are defined as “free sugars” in the Report from the Expert Consultation as “all
          monosaccharides and disaccharides added to food by the manufacturer, cook or consumer,
          plus sugars naturally present in honey, syrups and fruit juices”
          **sodium salts include those added to foods for food additive purposes or for other purposes



III. Other Proposed Actions

      26)    The eWG heard two suggestions from member countries that suggested
      looking at ideas that expand on the principle of qualifying and/or disqualifying
      conditions for eligibility to use specific claims as outlined in section 7.2 in the
      Guidelines for Use of Nutrition and Health Claims. This paragraph states:

      27)     “Health claims should have a clear regulatory framework for qualifying and/or
      disqualifying conditions for eligibility to use the specific claim, including the ability
      of competent national authorities to prohibit claims made for foods that contain
      nutrients or constituents in amounts that increase the risk of disease or an adverse
      health-related condition. The health claim should not be made if it encourages or
      condones excessive consumption of any food or disparages good dietary practice.”

      28)    The eWG should consider this proposal and examine whether it could be
      expanded to cover other types of claims. Some arguments have been presented in
      favour or against this concept, however, the wording of the original proposed actions
      may not have been sufficiently clear for members of the eWG to fully consider this
      idea.

      29)     One idea may be to consider a requirement to place nutrition and health
      claims in the context of a healthy diet or as part of national dietary guidelines in order
      to convey to consumers that while a food may have certain nutritional or health
      properties, these need to be considered in the context of how that food fits into a
      healthy diet.




October 2009                                                                       Page 9 of 31
 Questions to be Addressed by the eWG

 1. Do members of the eWG agree with the proposed actions in the discussion paper? If
    not, please justify your reasons.
 2. Are there other arguments that could help strengthen the rationale behind the
    proposals? If so, please elaborate.
 3. Is the suggested text sufficient to cover the proposed action? If not, please propose
    alternate text.
 4. Do you have additional suggestions on how the ingredients identified in the Global
    Strategy can be addressed through Codex text? If so, please elaborate.




October 2009                                                                Page 10 of 31
      Annex II

      Summary of Proposed Conclusions

RETAINED PROPOSED ACTIONS
No      Proposal                                          Proposed Reference         Proposed conclusion
                                                          Standard
1       In case of an unanticipated addition of sugar     General standard for the   RETAIN It is suggested to
        to the product, it has to be mentioned on the     Labelling of               retain this suggestion for
        label next to the name of the product (sic).      Prepackaged Foods          further exploration.
                                                          (Codex stan 1-1985)        Rewording of the proposal
                                                                                     may be necessary to further
                                                                                     consider the concept.
2.      Expand the general principles, to include         General Guidelines on      RETAIN This is relevant to
        desirable claims to report the benefits and       Claims (CAC/GL 1-          the mandate of the eWG,
        content of foods, such claims could               1979)                      but the use of these types of
        encourage the consumption of fruits and                                      claims is already covered in
        vegetables (sic).                                                            the Guidelines for the Use
                                                                                     of Nutrition and Health
                                                                                     Claims. Discussion may be
                                                                                     needed if the eWG feels
                                                                                     comfortable with expanding
                                                                                     on this item.
3.      Include a ban on claims that encourage            General Guidelines on      RETAIN This proposal
        unhealthy patterns of consumption                 Claims (CAC/GL 1-          would require some
                                                          1979)                      clarification in order for
                                                                                     further exploration.
4.      Develop requirements for conditional claims       General guidelines on      RETAIN Merge with
        related to the ingredients mentioned in the       claims (CAC/GL 1-          proposal 5 and 7
        global strategy (fruits, vegetables, legumes,     1979)
        whole grains and nuts). The conditional
        requirements could be related to the amount
        of the ingredient present in the food and other
        nutritional characteristics
5.      Highlight those ingredients that show a           Guidelines on Nutrition    RETAIN Merge with
        benefit from the nutritional point of view,       labelling (CAC/GL 2-       proposal 4 and 7
        using standardized symbologies based on           1985)
        equivalency systems that allow consumers
        identify them easily. The current editorial of
        this section is not sufficiently clear to
        facilitate its implementation.
6.      Include the definition of declarations of         Guidelines for use of      RETAIN. This item needs
        properties related to dietary guidelines or       Nutrition and Health       to be focussed specifically
        healthy regimes                                   Claims (CAC/GL 23-         on the food ingredients
                                                          1997)                      identified in the strategy.
7.      Develop specific criteria or claims to foods      Guidelines for Use of      RETAIN Merge with
        that have an adequate amount of the               Nutrition and Health       proposal 4 and 5
        ingredients identified in the Global Strategy     Claims (CAC/GL 23-
                                                          1997
PROPOSED ACTIONS NOT RETAINED
8.  Voluntary front of pack information (FOP) on General Standard for the            REMOVE, as this is not
        elements in dietary recommendations given         Labelling of               relevant to the mandate of
        on international level to prevent non-            Prepackaged Foods          the eWG.



      October 2009                                                                        Page 11 of 31
       communicable diseases throughout the world.
9.     Include claims which better inform                 General Guidelines on     REMOVE Not relevant to
       consumers about the benefits and qualities of      Claims (CAC/GL 1-         the mandate.
       the product, as well as on method of               1979)
       production and processing methods that
       ensure the nutritional quality and food safety
       of them (sic).
10.    Negative nutrients such as free sugars,            Guidelines on Nutrition   REMOVE Not relevant to
       saturated fats and sodium can be more clearly      Labelling                 the mandate
       defined in nutrition labelling
11.    Purpose of the Guidelines: provide the             Guidelines on Nutrition   REMOVE This is editorial
       consumer with information about so that a          Labelling                 and not substantive.
       health-wise choice can be made (sic)
12.    Develop criteria for foods “low” in sugar,         Guidelines for Use of     REMOVE Not relevant to
       “free” of trans fat and “source of” specific       Nutrition and Health      the mandate.
       monounsaturated and polyunsaturated fatty          Claims
       acids.

       Allow the term “naturally” or “natural” as a
       prefix to the claim when the food naturally
       meets the conditions laid down in the Table
       of Conditions for Nutrient Contents
       (vitamins, minerals, and dietary fibres) (sic).
13.    Develop specific health claims considering         Guidelines for the Use    REMOVE Interesting
       the recommendations provided by the Global         of Nutrition and Health   concept and may need to be
       Strategy and the scientific substantiation         Claims                    considered in a different
       behind it.                                                                   manner for CCFL.
                                                                                    Development of health
       Develop specific qualifying and/or                                           claims is outside of scope of
       disqualifying conditions to identify foods that                              CCFL, may be under
       are eligible to use health claims related to the                             CCNFSDU‟s mandate.
       ingredients identified in the Global Strategy.
14.    Reassess the specifications of this paragraph      Guidelines for Use of     REMOVE Not relevant to
       for a food to be considered with a healthy         Nutrition and Health      the mandate.
       diet, so as to identify the nutrient that must     Claims
       meet to be considered healthy.




      October 2009                                                                       Page 12 of 31
                                                         ANNEX III

       COMMENTS FROM MEMBERS OF THE 2009-2009 WORKING
             GROUP ON THE RETAINED PROPOSALS
Proposed action 1 .................................................................................................................... 13
Proposed action 2 .................................................................................................................... 16
Proposed action 3 .................................................................................................................... 17
Proposed action 4 .................................................................................................................... 18
Proposed action 5 .................................................................................................................... 20
Proposed action 6 .................................................................................................................... 21
Proposed action 7 .................................................................................................................... 22

PROPOSED ACTION 1

This proposal could be subject to a debate. In order to improve the information of the consumer, a
solution could be to indicate the quantity of added sugar. (France)

Mentioning the addition of sugars in connection with the name of the product will facilitate more
readable and striking information to the buyer, than mentioning sugars in the list of ingredients (as
required in section 4.2 in the GSLPF). And this will better meet the goal in the Global Strategy to
limit the intake of free sugars. (Norway)

The WHO Technical Report on Diet, Nutrition and the Prevention of Chronic Diseases, Report
916/2003, recommends limiting the intake of free sugars to 10 percent of the total dietary energy
intake. The basis for this recommendation is that a higher intake of free sugars threatens the
nutritional value of diets by providing significant energy without specific nutrients. The consumption
of free sugars provides only empty calories and no other nutrients that are useful to the human body.
Increasing scientific documentation indicates that restricting free sugars is likely to help reduce the
risk of unhealthy weight gain, noting that free sugars contribute to the overall energy density of diets
and promote a positive energy balance. Furthermore, drinks rich in free sugars might increase the
overall energy intake by reducing appetite control. The term „free sugars‟ was defined in the WHO
report on Diet, Nutrition and the Prevention of Chronic Diseases (report 916/2003) as all
monosaccharides and disaccharides added to foods by the manufacturer, cook or consumer, plus
sugars naturally present in honey, syrups and fruit juices. Hence, the term includes both ingredients
and nutrients. The term „added sugars‟ could be used instead of free sugars to make it more
understandable for the consumer. Rules on labelling of added sugar are for example established in the
Codex standard for juices (Codex General Standard for Fruit Juices and Nectars 247-2005). Such an
approach might be used for other foodstuffs or better in the General Standard for Labelling (GSLPF).
The purpose of this suggestion is to draw consumer‟s attention to the addition of sugars in a product.
(Norway)

It is not necessary to amend the General Standard for the Labelling of Prepackaged Foods to state that
the unanticipated addition of sugar to the product has to be next to the name of the product. The
addition of sugar to a product would have to be included in the list of ingredients so the information
would be available to the consumer. The proposal for amendment of the Standard would be difficult
to provide legal certainty and enforcement. It would be difficult to define when the addition of sugar
is "unanticipated" by the consumer. (EC)




October 2009                                                                                                    Page 13 of 31
In the case of standardised products the labelling requirements of such products frequently require the
inclusion of information about whether a product has been sweetened or the addition of characterising
ingredients. This is the case for fruit juices where section 8.1.2.2 of the Codex Standard 247 for fruit
juices and nectars provides that in the case of fruit juices with added sugars the product name shall
include the statement “sugar(s) added” after the fruit juice or mixed fruit juice‟s name. (EC)

Clarification of the word “unanticipated” is needed; without this, inconsistent interpretation by
manufacturers and consumers could occur. Consumer confusion may also occur if consumers believe
foods containing naturally occurring sugars do not contain sugar or when sugar may be added at
different levels for taste when seasonal levels may vary. (New Zealand).

It is not clear what „unanticipated‟ means, for example this could relate to unanticipated
manufacturing/processing (such as when sugar is added only sometimes/seasonally), or it could relate
to consumers‟ expectation or understanding of sugar content. (Australia)

This approach would involve significant labelling changes, and therefore cost to industry. (Australia)

The information of added sugar is already available via the list of ingredients. (France, ISDI, CEFS,
Brazil)

There is no nutritional relevance in differentiating added sugar and intrinsic sugar in food. The
description of sugar content is adequately covered in the nutrition labelling. (Japan)

This action is considered to be against Standards of identity for products. (Mexico)

No action is necessary. The existing requirements for the declaration of the name of the food are
appropriate. The mandatory declaration of additional sugar as part of the name of the food should be
worked in individual Codex standards. (Brazil)

Canada does not agree with the proposed addition of section 4.1.2.1 as currently put forward and feel
that it may already be adequately covered off in other sections of the GSLPF. Multi-ingredient food
products are already required to carry a list of ingredients under section 4.2 of the GSLPF. If a
standard of identity allows for the addition of sugar to a food, then there should be no need to identify
the addition of the ingredient as part of the common name since this is duplicating information
already found in the list of ingredients. (Canada)

If the food is normally a single ingredient food where one would not expect to find added sugar and
no standard of identity is prescribed for the food either under Codex or under national authority and it
has sugar added to it, it would be appropriate to use a descriptive common name. This should be
adequately covered in sections 4.1.1 and 4.1.1.3 of the GSLPF which states that “the name (of the
food) shall indicate the true nature of the food and normally be specific and not generic” and “in the
absence of (a prescribed common name), either a common or usual name existing by common usage
as an appropriate descriptive term which was not misleading or confusing to the consumer shall be
used”. Section 4.1.2 of the GSLPF also states “there shall appear on the label either in conjunction
with, or in close proximity to, the name of the food, such additional information or phrases as
necessary to avoid misleading or confusing the consumer in regard to true nature and physical
condition of the food including but not limited to the type of packing medium, style, and the
condition or treatment it has undergone; for example: dried, concentrated, reconstituted, smoked.”
(Canada)

If sugar is not permitted to be added to a food with a standard of identity, but it has been, then it
would be appropriate to indicate its presence through the use of a modified standardized common
name. While this change does not result in one of the nutrition claims currently recognized in the
General Standard for Nutrition and Health Claims, it does result in a change in the nutritional profile
and would need to indicate the addition of sugar through terms such as “with added sugar” or



October 2009                                                                           Page 14 of 31
“sweetened”. While not currently the specific focus, it may be worthwhile to pursue this discussion
in the context of the CCFL Electronic Working Group on Modified Standardized Name of the Food
for Purpose of Nutrition Claims. (Canada)

It should be clarified if all sugars are meant or only sucrose‟s. (France)

There are specific rules for some foods that contain such a declaration, such as the Codex standard for
juices, and should be in these specific standards where the subject of added sugar should be placed.
Moreover, given the difficulty of defining what is meant by “unanticipated addition of sugar” it is
considered that this declaration should not apply as a general rule. (Costa Rica)

The addition of sugar to food will also be reflected in the list of ingredients such as the general Codex
Stan 1-1985). (Costa Rica)

As stated in the 2007 FAO/WHO Scientific Update on Carbohydrates in Human Nutrition, there is no
convincing scientific justification to distinguish between “added” and “other” sugars as this
distinction is related to the food matrix and not to the physiological properties of sugars. The human
body makes no distinction between “added” sugars and naturally occurring ones; sugars contribute to
the same amount of calories (4 kcal/g) whether they are added or naturally occurring. Consequently,
additional information on “added” sugars content would not provide consumers with any meaningful
information as to the nutritional value or physiological influence of a food. (CEFS)

The labelling of “added” sugars is of concern from an analytical point of view. The 2007 FAO/WHO
Scientific Update on Carbohydrates recalls that there is no practical, easily enforceable analytical method
to distinguish added and “other” sugars: “While ingredient lists can be used to identify the source of sugars
in foods, analytically it is not readily possible to distinguish their origin in processed foods”. As pointed
out by the EC referring to the example of Sweden, sugars-containing ingredients such as powdered fruit
juices, ground raisins, whey powder, etc. can be used instead of adding sugars directly. (CEFS)

The term „unanticipated addition of sugar‟ does not have a defined meaning in the context of a food
product. For example, yoghurt with added fruit contains inherent sugars in the form of fructose in the
fruit portion and lactose in the milk part of the product. Therefore unanticipated additions of sugar
should not be stated as part of the name of the food labelling. (IDF)

There is no need for this action as information on the name of the food and how it should appear on
the label of prepackaged foods is already covered in section 4.1 of the Codex General Standard for
the Labelling of Prepackaged Foods (Codex Stan 1-1985). (IDF)

Countries having strict interpretation will ask for systematic labelling if sugar is added in any food
(and not only where it is “unanticipated”) and all type of products will bear the “with added sugar”
sentence. (ISDI)

As this will be indicated in the list of ingredients, such a measure will not bring added value and may
create confusion. Better educating consumers to read the ingredient list is suggested. (ICD)



PROPOSED ACTION 2

There is no benefit resulting from this action and a „desirable claim‟ depends on the end purpose of
the food i.e. a sports bar high in sugar could be deemed desirable to an athlete. There is scope to
consider this further using language to support positive claims. (New Zealand)

Any labelling to promote healthy diets, in the form of claims or symbols, in line with the goals in the
WHO strategy is a positive action, and there should be established a framework i.e. principles for this



October 2009                                                                             Page 15 of 31
kind of labelling. The current Codex Standard already provides mechanisms to deal with claims
related to dietary guidelines or healthy diets (section 8). This action could be handled with under
section 8.4: Foods which are described as part of a healthy diet, healthy balance, etc., should not be
based on selective consideration of one or more aspects of the food. They should satisfy certain
minimum criteria for other major nutrients related to dietary guidelines. Guidelines might be
established on minimum criteria for major nutrients and ingredients related to dietary guidelines in
the line of the Global Strategy, such as the whole grain content or the amount of fruit and vegetables
in foods. Claims regarding intrinsic/extrinsic sodium might also be considered as the claim “low in
added sodium” might stimulate manufacturers to product reformulation. (Norway)

 “Desirable claims to report the benefits and content of foods” is already well covered under the
Guidelines for Use of Nutrition and Health Claims (CAC/GL 23-1997). These guidelines provide the
structure and definition for making nutrition claims – which refer to the content of the food. The
benefits would fall under the category of health claims – which are “any representation that states,
suggests or implies that a relationship exists between a food or a constituent of that food and health.”
This structure is already being used in Canada to encourage the consumption of fruits and vegetables.
(Canada)

The definition of claims, presented in section 2 of the General Guidelines on Claims, is general and
covers any claim related to the ingredients identified in the Global Strategy. This definition includes
any representation which implies that a food has particular characteristics related to its composition
and any other quality. (Brazil)

The definition should not be expanded. However, if there is general support from other members,
then consideration could be given to positioning an expanded definition within section 1 – scope and
general principles, of the Guidelines. (Australia)

While there may be in recognising and acknowledging „positive‟ claims as of equal importance to
„negative‟ claims, this approach is prescriptive. (Australia)

As the CAC/GL 1-1979 is meant to define general principles, it shall not describe the precise content
of claims. “Nutritional properties” are already covered in the definitions. (Switzerland)

The current approach should not be changed. (Mexico)

It is not necessary for the general principles of the General Guidelines on Claims to explicitly refer to
desirable claims. The existing Guidelines cover all claims on foods whether they are considered
“desirable claims” or not and provide advice to prevent claims being made which would be
considered false, misleading or deceptive. If a list of permitted claims on certain characteristics of
foods were to be developed it would mean that the treatment of claims that were not specifically
included in the guidelines would be unclear. (EC)

Judgments on positive ingredients/negative ingredients or healthy consumption pattern/unhealthy
consumption pattern are not necessarily absolute, and they should be affected by dietary intake
pattern and nutritional requirement etc. in each country/ region or population. For example, the
Global Strategy recommends that salt be iodized, but this recommendation is not necessary applied to
the population consuming adequate iodine through other source such as seaweed. This comment
refers simultaneously to proposed action 5, 6, 12 and 13 (Japan).
Sometimes it can be harmful for the health to consume too much single food ingredient even if they
are generally considered “healthy”. For example, some fruits contain high level of fructose or
glucose, and also some nuts contain high level of fat. Here again, well balanced diet based on correct
knowledge about nutrition is the key, and this should be promoted through consumer education or
guidance provided by each country‟s authority or other bodies. This comment refers simultaneously
to proposed action 4 (former no 6) and 7 (former no 13) (Japan).



October 2009                                                                          Page 16 of 31
CAC/GL 1-1979 defines general principles and does not explicit the content of the claim. (ISDI)

In general when claims are made, these are to report the benefit of the food. It is not clear how a
change in the general principles will bring a change in consumption pattern and will encourage
consumption of fruits and vegetables? (ICD)



PROPOSED ACTION 3

The Guidelines for Use of Nutrition and Health Claims already states that the nutrition and health
claims should be consistent with national health policy, including nutrition policy, and support such
policies. However, this action is supported since the definition of claims, presented in section 2 of the
General Guidelines on Claims, is general and includes other claims. (Brazil)

Claims should encourage healthy patterns of consumption. (Switzerland)

Cut offs and definitions of „unhealthy patterns of consumption‟ would be very hard to determine or
enforce. Eating patterns need to be cognizant of cultural and geographical variations. (New Zealand)

It is unclear what types of claims would be covered by such a proposed prohibition. The enforcement
of the proposed action would require the determination of unhealthy patterns of consumption which
would be difficult to achieve at an international level. The guidelines on nutrition and health claims
provides the framework to ensure that claims are consistent with national nutrition policy. There is no
need for additional restrictions of the type proposed. (EC)

It may be difficult to define „unhealthy eating patterns‟, for example given that a „healthy‟ diet should
be varied and includes scope for consumption of smaller amounts of foods that could be considered
„unhealthy‟ at higher levels of consumption. Healthy patterns of consumption are already covered in
CAC/GL 23-1997, Section 8 “Claims related to dietary guidelines or healthy diets”. A „healthy‟
consumption pattern must allow scope for cultural preferences and differences. (Australia)

The action could be difficult to implement, for example would the ban apply to specific claims, or
would it assess the nutrient profile of the foods that could potentially carry claims?
It is also underpinned by the assumption that claims affect consumption behaviour, this assertion
would need to be scientifically validated. (Australia)

Insertion not agreed. This sentence implies that claims could encourage unhealthy patterns of
consumption; however, a product in itself cannot be a factor of unbalanced or unhealthy pattern of
consumption. Healthy patterns of consumption are already covered in the CAC/GL 23-1997, section 8
“claims related to dietary guidelines or healthy diets”. (Switzerland)

The current recommendation in proposed action number 4 is too vague. It may be very difficult to
determine that the use of a single claim would encourage a person to undertake an unhealthy pattern
of consumption. Claims that encourage the excessive consumption of a food should not be permitted,
but in general, claims currently do not blatantly do this. The Guidelines for the Use of Nutrition and
Health Claims (CAC/GL 23-1997) currently generally provide for claims that are positive in terms of
promoting the nutritional or health benefits of foods, including through the consumption of a healthy
diet. As well, the preamble to these Guidelines state that the impact of health claims on consumers‟
eating behaviours and dietary patterns should be monitored in general by competent authorities.
Unless there is other evidence supporting that these types of claims exist and in fact contribute to an
unhealthy dietary pattern, Canada believes that Section 8 on Claims Related to Dietary Guidelines or
Healthy Diets are sufficient and the use of these types of claims should be encouraged in Member
Countries in order to promote the consumption of healthy foods. (Canada)




October 2009                                                                          Page 17 of 31
The current Guidelines do already address this concerns and the proposal would be repetitive.
(Mexico)

Food labelling is factual information about the product; it can‟t replace the education of the
consumer. (France)

Further examples of this proposed action would be appreciated. (Japan)

A product in itself can not be a factor of unbalanced or unhealthy pattern of consumption. (ISDI)

This sentence implies that claims could encourage unhealthy patterns of consumption, which is false.
(ISDI)

It is not so clear which concrete examples are behind this proposal and examples are requested.
(ISDI)

A product on its own can not be considered as a factor of unhealthy pattern of consumption. It is the
excess consumption of a product which can lead to an unhealthy pattern, i.e. a behaviour. Nutrition
labelling and consumer education are better approach to address the problem. (ICD)




PROPOSED ACTION 4

This action could provide guidance in the elaboration of claims that are intended to highlight the
presence of fruits, vegetables, legumes, whole grains and nuts in processed foods. (Brazil)

The eWG may wish to proceed with the development of criteria for when a food label or
advertisement emphasizes the presence of ingredients mentioned in the Global Strategy such as fruits,
vegetables, whole grains, legumes and nuts. Canada would support further exploration of this
proposal when there is emphasis put on the presence of these specific ingredients provided that the
requirements which are already set out in section 5.1 of the GSLPF on the Quantitative Labelling of
Ingredients are also considered. The eWG may also wish to consider other nutritional characteristics
which may be desirable or undesirable in a food which may also place a condition on the food in
order to carry such a claim. However, this would require a proposal for new work and much
consideration would need to be given as to how this could be workable, given past debate in the
Committee on QUID. (Canada)

See comments under proposed action 2 (former no 3) and 5 (former no 8). (Norway)

There is no specific prohibition in the General Guidelines on Claims around claims relating to the
specific ingredients under consideration; currently the only constraint under these Guidelines is that
claims must not be not described or presented such as to be false, misleading or deceptive (section
1.2). There is no nedd to develop specific, prescriptive conditions for claims of this type. (New
Zealand).

The guidelines on nutrition and health claims provides the framework to ensure that claims are
consistent with national nutrition policy. The inclusion of requirements for conditional claims related
to the ingredients in the global strategy could potentially have an impact on general labelling
requirements or specific labelling requirements for certain products regarding the information to be
provided. The current approach should not be changed. (EC)




October 2009                                                                          Page 18 of 31
There is no specific prohibition in the Codex General Guidelines on Claims around claims relating to
the specific ingredients under consideration; currently the only constraint under these Guidelines is
that claims must not be not described or present such as to be false, misleading or deceptive (section
1.2). It has to be clarified whether it is necessary to develop specific, prescriptive conditions for
claims of this type. (Australia)

Development of these conditions would be complex and lengthy, given they would require
assessment of both the amount of ingredient (the subject of the claim) and the profile of the food to
carry the claim (nutritional characteristics). It is noted that characterising ingredient requirements
already provide an avenue for information around the amount of (key) ingredient present in a food,
including fruits, vegetables etc. (Australia)

The current Guidelines do already address this concerns and the proposal would be repetitive.
(Mexico)

Comment from Japan under proposed action 2 (former no 3).

Insertion not agreed. CAC/GL 1-1979 only defines general principles and the amount of the
ingredient has not to be mentioned there. The related amount is already given in the quantitative
ingredient declaration (QUID) with percentage of ingredients. Some standards have already
ingredient compositional requirements. Therefore, developing specific conditions would not be
necessary. Any attempt to define quantitative requirements for each foodstuff would be difficult and
time consuming. (Switzerland)

CAC-GL 1-1979 defines general principles only and the amount of the ingredient has not to be
mentioned there. (ISDI)

The related amount is already given in the quantitative ingredient declaration (QUID) with percentage
of ingredients. (ISDI)

Some standards have already ingredient compositional requirements: developing specific conditions
is not needed. (ISDI)

Any attemt to define quantitative requirements would be very time consuming for each foodstuff
since a lot of standards would have to be considered. (ISDI)



PROPOSED ACTION 5

Further discussion of this action is requested as well as some examples. It could be helpful to review
section 4 in order to make it sufficiently clear. (Brazil)

It is unclear how the addition of this proposal to section 4 fits with the purpose of the Guidelines on
Nutrition Labelling. The highlighting of the presence of nutritionally beneficial ingredients does not
fit with the purposes of nutrition labelling which is to present information on specific nutrients rather
than on individual ingredients. The eWG may wish to consider this under the GSLPF under section
5.1 as an additional optional way indicating the presence of an emphasized ingredient or as part of the
proposed action number 5 above. (Canada)

The text in section 4 could be revised in order to make it more explicit. (Switzerland)

We support discussions on the possibility of establishing a common framework for using symbols
taking into account the amount of ingredients and nutrients identified in the Global Strategy. In line
with item 41.1 in the Global Strategy on diet, physical activity and health, reading: “Promotion of



October 2009                                                                          Page 19 of 31
food products consistent with a healthy diet: … Governments could consider additional measures to
encourage the reduction of the salt content of processed foods, the use of hydrogenated oils, and the
sugar content of beverages and snacks.” Therefore this proposed action is in line with Guidelines on
establishing symbols to help consumers by visualising healthy foods in a manner that is simple and
easy to understand. Also setting requirements regarding the amount of ingredients outlined in the
Global Strategy might stimulate manufacturers toward developing healthier products. See also
comments under action 3. (Norway)

The rationale for the proposed amendment is unclear. It would be useful to know whether there are
examples of national measures in Codex Member Countries that have harmonised the use of symbols
for specific ingredients. (EC)

It is not clear from the description given whether this action intends to focus on ingredients or
nutrients – refer to Section 2 above. There is overlap between this action and proposed action number
5, and suggest further clarification. It is not clear what is envisaged by the suggested „symbology‟,
for example colouring the relevant ingredients in the ingredients list, using symbols, or other.
(Australia)

The labelling should not be considered as the only tool for the Global Strategy. A thorough program
should be considered. Qualifying the food by symbols, can be misleading to the consumer, since it
must be addressed different diets for different populations, and might interfere in international trade.
(Mexico)

Food labelling is factual information about the product; it can‟t replace the education of the
consumer. (France)

The wording and aim of this sentence are not very clear. What should the consumer identify? In order
to avoid the development of symbols, the text in section 4 could simply be amended to facilitate its
implementation. (Switzerland)

The issue of presentation of labelling or using standardised symbols should be better handled by the
other e-WG on legibility and readability of nutrition labelling. (Japan)

The wording and aim of this proposal need to be clarified (it is to develop symbols for people who
can not read?). To avoid the development of symbols, the text of section 4 could simply be enhanced
to facilitate its implementation. (ISDI)

The rules laid down in sec. 4 of the guidelines on nutrition labelling are sufficient and clear. There is
no need for additional standardized symbols. (IDF)



PROPOSED ACTION 6

Agreement with the proposed action. The definition could also contain examples of such claims. This
proposed action could clarify and help national authorities in the elaboration of claims related to
dietary guidelines or healthy regimes. (Brazil)

While section 2 of the Guidelines does not specifically address dietary guideline claims, they are
addressed in section 8 of the Guidelines. There is a trend towards “healthy eating labelling programs”
in various jurisdictions internationally which do not necessarily follow the pattern of eating contained
in the dietary guidelines officially recognized by the appropriate national authority of the country
where the food is sold. Commonly many of these programs are amalgams of criteria derived form
dietary guidelines from various authorities and assorted nutrient content levels set by individual




October 2009                                                                          Page 20 of 31
programs. The eWG may wish to consider proposing new work in this area which may be of benefit
to countries currently trying to address this issue. (Canada)

A definition for “declaration of properties related to dietary guidelines or healthy regime” would be
useful for clarification. (New Zealand).

Examples are requested. This action is already covered in particular in paragraph 8.1.

The current Guidelines do already adress this conserns and the proposal would be repetitive. (Mexico)

The addition of some examples could improve the understanding of the goal of this proposed action.
Nonetheless, this action is already covered in paragraph 8.1., section 8. (Switzerland)

More clarification on the reason for the proposal and its benefits it would be expected to deliver is
requested. Claims about properties related to national dietary guidelines or healthy regimes which
refer to food categories can already be addressed by the current guidelines (section 8), and are best
dealt with at national level. (EC)

It is not clear whether this comment (number 51) is intended to be put forward as a proposed action –
in the General Overview to the paper it is classified in the group of comments that are not within the
mandate of CCFL, however it subsequently appears in the proposed actions. (Australia)

As the nature and the characters of claims related to dietary guidelines or “healthy diets” are fully
described in Section 8 of CAC/GL 23, it is not considered necessary to define a new word. (Japan)



PROPOSED ACTION 7

Specific criteria would be helpful for the implementation of the WHO Global Strategy. The wording
for this action should be revised. Only criteria would be necessary, since additional claims could be
more difficult to understand. (Switzerland)

This action is a repeat of action Nr 4 (former no 6) and not supported. (New Zealand)

This proposal appears to be in line with the proposal made in Proposed Action Number 6 above. The
Proposed Action Number 4 (former no 6) refers to the General Guidelines on Claims where this type
of claim may be more appropriate as it deals with the ingredient content rather than nutrition or health
claims. See our comments above. (Canada)

The reason for the proposal and the benefits it would be expected to deliver need to be clarified to
then assess whether it warrants further consideration. (EC)

Research should be focused on determining adequate contents, however, considering the differences
among countries (nutrient needs, genetic deficiencies, etc.), a consensus on adequate levels might not
be feasible. (Mexico)

Further clarification is required on how this action differs from proposed action number 4 (former no
6). (Australia)
Comment from Japan under proposed action 2.

Insertion not agreed, referring to comments under proposal 4 (former no 6) (ISDI)

The provisions of the current Guidelines of Use of Nutrition and Health Claims are appropriate to
ensure consumers have truthful and non-misleading information on which to make informed dietary



October 2009                                                                         Page 21 of 31
decisions. Changes to these Guidelines as a means for implementing the WHO Global Strategy on
Diet are not warranted. (CEFS)



General Comments

The current Codex Standard for the Labelling of Prepackaged Foods already provides sufficient
mechanisms to assist the consumer to identify the presence and relative content of the food
ingredients under consideration. Changing the Codex texts under consideration is not supportet
(Australia).
The labelling of free/added sugar in the context of mandatory labelling of prepackaged food is not
supported. This issue could be considered in the Guidelines on Nutrition Labelling. (Australia).

A prescriptive approach for information around specific food ingredients, such as via a mandatory
quantitative declaration of the ingoing percentage of any ingredient that is subject of an expressed or
implied claim is not supported. (Australia)

Clarification is required around the use of the terms „ingredients‟ and „nutrients‟ regarding proposed
actions numer 2 (former no 3), 4 (former no 6), and 5(former no 8). (Australia)

There are sufficient mechanisms within this standard to provide consumer information, including:
mandatory ingredients list, NIP and mandatory characterising ingredients. (Australia)

New Zealand supports in principle the intent of the Global Strategy on Diet, Physical Activity and
Health and welcomes consideration of the Strategy at CCFL. However, with respect to food
ingredients amendments of existing labelling provisions dealing specifically with this issue should not
be focus of CCFL. The Codex Standard for the Labelling of Pre-packaged Foods already provides
appropriate mechanisms to help consumers identify ingredients in the food. (New Zealand)

It is our basic opinion that it is of utmost importance to consumers to have access to appropriate
information about the elements in their food which are unbeneficial to their health. (Norway)

It is considered that the labelling by itself is not a solution to the health problems related with
overweight and obesity, but a possible tool. It is important to indicate that the education of the
consumer just through the labelling is difficult to carry out, and not feasible. The non-transmissible
chronic diseases derive from multiple factors, so the nutritional labelling by itself would not attack all
the other factors related to those diseases. (Mexico)

The modification of Codex General Standard for the Labelling of Prepackaged Foods, and its
Guidelines, does not seem sufficient to attack the problem, and the proposals are not adequate for
addressing the problem and its solution. The obesity should be attack by a public policy involving
education to consumers (such as orientation on how to read a label, and how this information can be
applied on making a correct choice of diet, education on early stages, promotion of healthy diets,
research in nutrient needs), physical activity at schools, promotion of different lifestyles, etc.
(Mexico)

The Global Strategy particularly stresses the importance of consuming foods such as fruits,
vegetables and whole grains, and recommends reducing the intake of trans-fatty acids, added sugar
etc. The situation of nutrient intake varies from country to country and each country has its own
problems. These problems should be solved through well balanced diet based on each country‟s
nutrition policy and the recommendations of the Global Strategy. Labelling with too simplified
messages as if consumers can improve their diet by simply choosing one specific product may rather




October 2009                                                                           Page 22 of 31
be misleading. A strong necessity to revise the current Codex texts on food labelling for the purpose
of implementing the WHO/FAO strategy is not seen. (Japan)

We do not believe that there is a need to consider general and broad amendments to the scope or
definitions of Codex labeling texts for the purposes of the work assigned to this electronic working.
We also do not believe that there is a need to consider amendments to the General Standard for the
Labelling of Prepackaged Foods. We believe that requirements related to the appropriate use of
claims, including claims related to food ingredients, should be addressed in Codex texts other than the
General Standard for the Labelling of Prepackaged Foods and the Guidelines on Nutrition Labelling.
In this respect, we note the conclusions of the physical working group at the last CCFL Session
(please see para. 41 of Alinorm 08/31/22). (US)

The electronic working group may consider the need for any provisions related to express or implied
claims about the content of health-related ingredients such as fruits, vegetables, or whole grains
within the Codex General Guidelines on Claims or the Guidelines for Use of Nutrition and Health
Claims. As concluded at the physical working group at the last CCFL, we further note that this issue
could be appropriately addressed under Section 8 of the Codex Guidelines for Use of Nutrition and
Health Claims (para. 41, Alinorm 08/31/22). (US)

With respect to added sugars, the United States notes that Section 3.2.4 of the Codex Guidelines on
Nutrition Labelling currently provides for mandatory declaration of the amount of total sugars, which
includes added sugars, when a claim is made regarding the amount and/or type of carbohydrate. We
do not support further work related to added sugars. (US)

Careful consideration needs to be given to promoting a balanced view on foods and how they fit into
an overall diet, and its potential impact on labelling. (IDF)

The on-going Codex considerations with regard to the Implementation of the WHO Global Strategy
on Diet, Physical Activity and Health should not result in discrimination or inappropriate positioning
of individual food products or groups of food products that are known to contribute significant
amounts of essential and valuable nutrients to the overall diet, even if some of these may also contain
nutrients thought to be linked to increased health risks for certain groups and people. (IDF)

The impact of nutrients should be related to the quantity in relation to the total diet and not in relation
to a particular food. For example, nutrient-dense foods like some milk products and fruits contain
saturated fat and sugars respectively, but are at the same time they also provide significant amounts of
important nutrients such as protein, calcium, fiber, vitamins and micronutrients. Most countries have
national guidelines that promote the intake of milk and fruit. (IDF)

Some of the food ingredients in question are essential for the production and preservation of certain
foods (for example: salt in cheeses, sugar in condensed milk) and in some cases for enhancing flavor.
(IDF)

All labelling rules should be based on an “informed consumer” reading the labels prudently. This
should in principle be kept in mind when discussing where specific information has to be mentioned.
(IDF)

Any actions related to the Implementation of the Global Strategy on Diet, Physical Activity and
Health should not restrict innovation, where such innovation can provide a diet driven benefit to
human health. For example the combination of nutrients/ingredients or modification of foods proven
to provide additional health benefits. (IDF)

In the approach to labelling, it is important to make a differentiation between the nutritional risk of a
single food product and the risk of an unhealthy diet due to imbalance in the diet and over exposure to




October 2009                                                                           Page 23 of 31
certain products or ingredients. It is to remembered that health is defined as “a state of complete
physical, mental and social well-being and not merely the absence of disease or infirmity (WHO)”.
Thus, many food products eaten moderately will contribute to health (social well being or mental
health), even if they contain ingredients such as “salt, sugar”. They are not necessarily part of an
unhealthy product. (ICF)
Many of the recommended actions are not very clear and it would have helped if the
recommendations were illustrated with some examples of situations. (ICF)

The requirement for mandatory information on the label should be specific to the product in question,
e.g. its nutritional composition, safe preparation and storage. Considering nutrition education,
promotion of healthy diet through the label may be misleading as the limited space may not be
sufficient to provide full information on a complex subject. (ICF)

The Codex documents are structured so as to ensure that consumers have the necessary information to
make informed decisions about diet and health. There is no justification with proceeding with the
proposed Discussion Paper. If one is presented it is essential that the various positions that have been
presented in these two rounds of comments be reflected. (ICBA)

Other comments relating to several of the proposals above

Some of the comments received were general and some were repeated under many of the proposed
actions. This concerns among others the definition of “free sugars” and the relevance of discussing
labelling of single ingredients while the health effects are resulting of all the ingredients in the total
diet.


Ingredients in the WHO Strategy should be dealt with in Codex
   - it is of utmost importance to consumers to have access to appropriate information about the
       elements in their food which are unbeneficial to their health.
   - It is considered that the labelling by itself is not a solution to the health problems related with
       overweight and obesity, but a possible tool.

Ingredients in the WHO Global Strategy should not be dealt with in Codex
   - that the education of the consumer just through the labelling is difficult to carry out, and not
       feasible
   - the non-transmissible chronic diseases derive from multiple factors, so the nutritional
       labelling by itself would not attack all the other factors related to those diseases
   - the proposals are not adequate for addressing the problem and its solution.
   - obesity should be attack by a public policy involving education to consumers (such as
       orientation on how to read a label, and how this information can be applied on making a
       correct choice of diet education on early stages, promotion of healthy diets, research in
       nutrient needs), physical activity at schools, promotion of different lifestyles, etc
   - the situation of nutrient intake varies from country to country and each country has its own
       problems. These problems should be solved through well balanced diet based on each
       country‟s nutrition policy and the recommendations of the Global Strategy. Labelling with
       too simplified messages as if consumers can improve their diet by simply choosing one
       specific product may rather be misleading.
   - some of the food ingredients in question are essential for the production and preservation of
       certain foods (for example: salt in cheeses, sugar in condensed milk) and in some cases for
       enhancing flavor




October 2009                                                                             Page 24 of 31
Already covered
   - the current Codex Standard for the Labelling of Prepackaged Foods already provides
        sufficient mechanisms to assist the consumer to identify the presence and relative content of
        the food ingredients under consideration.
   - there are sufficient mechanisms within this standard to provide consumer information,
        including: mandatory ingredients list, NIP and mandatory characterising ingredients
   -
Not in the mandate or dealt with in other eWG
   - labelling of free/added sugar could be considered in the Guidelines on Nutrition Labelling
   - some proposed actions are covered within the scope of the three electronic working groups
        led by Australia, New Zealand, and the United States, respectively, dealing with mandatory
        nutrition labeling, nutrients that are always declared, and criteria for legibility of nutrition
        labeling.


Other comments

    -   this work should not result in discrimination or inappropriate positioning of individual food
        products or groups of food products that are known to contribute significant amounts of
        essential and valuable nutrients to the overall diet, even if some of these may also contain
        nutrients thought to be linked to increased health risks for certain groups and people.
    -   the impact of nutrients should be related to the quantity in relation to the total diet and not in
        relation to a particular food. For example, nutrient-dense foods like some milk products and
        fruits contain saturated fat and sugars respectively, but are at the same time they also provide
        significant amounts of important nutrients such as protein, calcium, fibre, vitamins and
        micronutrients.
    -   all labelling rules should be based on an “informed consumer” reading the labels prudently.
        This should in principle be kept in mind when discussing where specific information has to
        be mentioned
    -   actions related to the Implementation of the Global Strategy on Diet, Physical Activity and
        Health should not restrict innovation, where such innovation can provide a diet driven benefit
        to human health. For example the combination of nutrients/ingredients or modification of
        foods proven to provide additional health benefits
    -   many of the recommended actions are not very clear and it would have helped if the
        recommendations were illustrated with some examples of situations
    -   guidelines might be established on minimum criteria for major nutrients and ingredients
        related to dietary guidelines in the line of the Global Strategy, such as the whole grain content
        or the amount of fruit and vegetables in foods. Claims regarding intrinsic/extrinsic sodium
        might also be considered as the claim “low in added sodium” might stimulate manufacturers
        to product reformulation
    -   clarification is required around the use of the terms „ingredients‟ and „nutrients‟ regarding
        proposed actions number 4 (former no 6) and 5 (former no 8).
    -   it is suggested merging the proposed actions no. 2, 4 (former no 6) and 5 (former no 8). and 7
        (former no 13).
    -   judgements on positive ingredients/negative ingredients or healthy consumption
        pattern/unhealthy consumption pattern are not necessarily absolute, and they should be
        affected by dietary intake pattern and nutritional requirement etc. in each country/ region or
        population. For example, the Global Strategy recommends that salt be iodized, but this
        recommendation is not necessary applied to the population consuming adequate iodine
        through other source such as seaweed. This comment refers simultaneously to proposed
        action 4 (former no 6) and 7 (former no 13).
    -   sometimes it can be harmful for the health to consume too much single food ingredient even
        if they are generally considered “healthy”. Well balanced diet based on correct knowledge
        about nutrition is the key, and this should be promoted through consumer education or



October 2009                                                                          Page 25 of 31
      guidance provided by each country‟s authority or other bodies. This comment refers
      simultaneously to proposed action 4 (former no 6) and 5 (former no 8).




October 2009                                                           Page 26 of 31
                                               Annex IV
                                          List of Participants

Co-Chairs:       Ms. Heidi Bugge                         Ms. Charmaine Kuran
                 Senior Advisor                          National Manager, Nutrition and Health
                 Norwegian Food Safety Authority         Canadian Food Inspection Agency
                 Norway                                  Canada
                 Tel. +47 23 21 65 25                    Tel.: 011 (613) 773-5497
                 E-mail: Heidi.Bugge@mattilsynet.no      E-mail : charmaine.kuran@inspection.gc.ca
                                                         After Nov 20 : charmaine_kuran@hc-sc.gc.ca



Australia
                                                       Mrs. Kathy Twardek
Ms. Jane Allen                                         National Manager
Manager, Labelling                                     Consumer Protection Division
Food Standards Australia New Zealand                   Canadian Food Inspection Agency
55 Blackall St., Barton                                1400 Merivale Road, T2-6C
Canberra BC 2600, AUSTRALIA                            Ottawa, Ontario, K1A 0Y9
Tel.: +61 2 6271 2678                                  Email: Kathy.twardek@inspection.gc.ca
Fax: +61 2 6271 2222
E-mail: jane.allen@foodstandards.gov.au                Ms. Christina Zehaluk
                                                       Head, Special Purpose Foods
                                                       Bureau of Nutritional Sciences
Argentina                                              Health Canada
                                                       251 Sir Frederick Banting Driveway, Tunney's
Ing. Gabriela Catalani: codex@minprod.gov.ar           Pasture
                                                       Ottawa, Ontario K1A 0K9
Lic. Alicia Menéndez: codex@anmat.gov.ar               Telephone : 613-957-1739
                                                       Email: Christina_zehaluk@hc-sc.gc.ca
Armenia
                                                       Chile
Ms. Sofik Khachatryan
Leading Specialist of National and International       Mr. Emilio Matas Abellá
Standards Research and Application Forecasting         Coodinador Etiquetado de Alimentos
Department, National Institute of Standards of         Codex Alimentarius Chile
Armenia                                                Servicio Nacional del Consumidor
tel: 0037410 234778                                    Teatinos 50 Segundo Piso Santiago de Chile
E-mail: sof_Khachatryan@mail.ru                        Fono: (56-02) 3519549
                                                       Email : ematas@sernac.cl
Ms. Margarita Babayan
Head of Food Safety Division, State Hygienic and       Costa Rica
Anti-Epidemiological Inspectorate of the Ministry
of Health of Armenia                                   Marcela Rojas Gómez
tel: 0037410650305                                     Amanda Lasso Cruz
E-mail: food@ph.am                                     Technical Secretariat of the Codex in Costa Rica.
                                                       Email:mrojas@meic.go.cr
Canada                                                 alasso@meic.go.cr

Mrs. Johanne Beaulieu
Director
Consumer Protection Division
Canadian Food Inspection Agency
1400 Merivale Road, T2-6C
Ottawa, Ontario K1A 0Y9
Email: johanne.beaulieu@inspection.gc.ca




October 2009                                                                          Page 27 of 31
Croatia                                                Dr. Mary A. T. Flynn,
                                                       Chief Specialist, Public Health Nutrition,
Ms. Lea Pollok                                         Food Safety Authority of Ireland,
Croatian National Institute of Public Health           Abbey Court, Lower Abbey Street, Dublin 1,
Food Supplements and Dietetic Products Unit            Ireland
Rockefellerova 7                                       TEL: +353 1 8171346
HR-10000 Zagreb, Croatia                               E-mail: mflynn@fsai.ie
phone: +385/1/4863 266
e-mail: lea.pollak@hzjz.hr                             Kenya

Ms. Sanja Katalenic                                    Ms. Alice Okelo Onyango
Croatian National Institute of Public Health           Kenya Bureau of Standards
Food Quality Control Unit                              P.O.BOX 54974 00200 POPO ROAD
Rockefellerova 7                                       OFF MOMBASA ROAD
HR-10000 Zagreb, Croatia                               TEL: 254 20 605490/6948303
phone: +385/1/4863 254                                 FAX: 254 02 604031/609660
e-mail: sanja.katalenic@hzjz.hr                        CELL: 254 722268225
                                                       E-mail: akothe@kebs.org
France
                                                       Ms. Alice Mithamo
M. Emmanuel-Chrys LARGE                                Kenya Bureau of Standards
Ministère de l'économie, des finances et de l'emploi   P.O.BOX 54974 00200 POPO ROAD
DGCCRF - Bureau C3                                     OFF MOMBASA ROAD
59, boulevard Vincent Auriol                           TEL: 254 20 605490
75703 PARIS CEDEX 13                                   FAX: 254 02 604031/6096605
tél: +33 1 44 97 32 24                                 E-mail: info@kebs.org
fax: +33 1 44 97 30 37
E-mail: emmanuel-                                      Ms. Edna Warentho
chrys.large@dgccrf.finances.gouv.fr ;                  Kenyatta National Hospital, Nutrition Department
E-mail: sgae-codex-fr@sgae.gouv.fr                     Kenya
                                                       P.O.Box 67367 Nairobi
Germany                                                E-mail ewarentho@yahoo.com

Mr. Gerhard BIALONSKI                                  Japan
Head of Unit 314                                       Ms. Megumi Haga
Bundesministerium für Ernaehrung,                      Deputy Director
Landwirtschaft und Verbraucherschutz                   Food Labeling Division,
Rochusstr. 1 53123 Bonn Germany                        Consumer Affairs Agency
Tel. +49 (0) 228 99529-4651                            E-mail: g.foodlabeling@cao.go.jp
Fax: +49 (0) 228 99529-4947                            Telephone: +81 3 3507 9220
E-mail: Gerhard.Bialonski@bmelv.bund.de
                                                       Mr. Yuuichirou Ejima
Indonesia                                              Deputy Director
                                                       Food Labeling Division,
Tetty H Sihombing                                      Consumer Affairs Agency
Director of Food Products Standardization              E-mail: g.foodlabeling@cao.go.jp
National Agency of Drug and Food Control               Telephone: +81 3 3507 9221
Republic of Indonesia
Email: subdit_spo@yahoo.com                            Malaysia
                                                       Ms. Norrani Eksan
Ireland                                                Senior Prinicpal Assistant Director
Ms. Paula Barry Walsh,                                 Food Safety and Quailty Divison
Senior Superintending Veterinary Officer,              Department of Public Health
Department of Agriculture, Fisheries and Food,         Ministry of Health Malaysia
Agriculture House,                                     Level 3, Block E7, Parcel E
Kildare Street, Dublin 2, Ireland –                    Federal Administration Centre
TEL: + 353 1 6072648                                   62590 Putrajaya, Malaysia
E-mail: paula.barrywalsh@agriculture.gov.ie            TEL: +603 8883 3511
                                                       E-mail: norrani@moh.gov.my
                                                       E-mail : ccp_malaysia@moh.gov.my




October 2009                                                                         Page 28 of 31
Mexico                                          Spain
Atte. Michelle Vizueth Chávez
Punto de Contacto Codex México                  Mª Ángeles Ortega
Dirección General de Normas                     Subdirección General de Calidad del Consumo
Secretaría de Economía                          Instituto Nacional del Consumo.
Tel. +(52)(55) 5729-9480                        e-mail: mangeles.ortega@consumo-inc.es
Email: codexmex@economia.gob.mx                 E-mail: cioa@msps.es

Netherlands                                     United States

Ms. Inge Stoelhorst                             Barbara Schneeman, Ph.D.
Senior Policy Officer                           U.S. Delegate to CCFL
Ministry of Health,                             Director
Netherlands                                     Office of Nutrition, Labeling, and Dietary
tel. 031 70 340 5658                            Supplements
E-mail: i.stoelhorst@minvws.nl                  Center for Food Safety and Applied Nutrition
                                                5100 Paint Branch Parkway
New Zealand                                     College Park, MD 20740 USA
Ms. Jenny Reid                                  Phone: 301-436-2373
Assistant Director, Science                     Fax: 301-436-2639
New Zealand Food Safety Authority               E-mail: barbara.schneeman@fda.hhs.gov
PO Box 2835
Wellington, New Zealand                         Ritu Nalubola, Ph.D.
tel: +64 4 894 2582                             Food Labeling and Standards Staff
fax: + 64 4 894 2530                            Center for Food Safety and Applied Nutrition
E-mail: jenny.reid@nzfsa.govt.nz                5100 Paint Branch Parkway
                                                College Park, MD 20740
Poland                                          USA
Mr Krzysztof Krygier, PhD                       Phone: 301-436-1432
Professor                                       Fax: 301-436-2636
Head of Faculty of Food Technology              E-mail: ritu.nalubola@fda.hhs.gov
Warsaw University of Life Sciences
159c, Nowoursynowska St. 02-776 Warszawa,       Singapore
POLAND
Tel.: 0048 22 59 375 10                         Ms LIM Lee San
E-mail: krzysztof_krygier@sggw.pl               Agri-Food and Veterinary Authority, Singapore
E-mail: krzysztofkrygier@wp.pl                  Tel: (65) 6325 8553
                                                E-mail: lim_lee_san@ava.gov.sg
Mr Miroslaw Jarosz, PhD
Professor                                       South Africa
Head of National Food and Nutrition Institute
61/63, Powsinska St., 02-903 Warszawa, POLAND   Ms. Antoinette Booyzen
Tel.: 0048 22 55 09 677                         Email: booyza@health.gov.za
e-mail: jarosz.zaklad@izz.waw.pl                E-mail: CACPSA@health.gov.za

Ms Joanna Markowska                             Switzerland
Senior Specialist
Ministry of Agriculture and Rural Development   Awilo Ochieng Pernet, lic. In law, cert. human
The Department of of Agricultural Markets       nutr.
30 Wspolna St., 00-930 Warsaw, POLAND           Codex Alimentarius, International Nutrition and
Tel.: 0048 22 623 22 69                         Food Safety Issues
e-mail: joanna.markowska@minrol.gov.pl          Federal Department of Home Affairs FDHA
                                                Federal Office of Public Health FOPH
Mr Szymon Kaminski                              Division of International Affairs
President of Polish Association of Margarine    Schwarzenburgstrasse 165
Producers                                       CH-3097 Liebefeld
22/209 Zurawia St, 00-515 Warszawa, POLAND      Phone: +41 31 322 00 41
Tel.: 0048 22 658 68 01                         Fax: +41 31 322 95 74
E-mail: biuro@pspm.org.pl                       Email: awilo.ochieng@bag.admin.ch
E-mail: kodeks@ijhars.gov.pl




October 2009                                                                  Page 29 of 31
Thailand                                         International Alliance of Dietary/
                                                 Food Supplement Associations (IADSA)
Miss Panpilad Saikaew
Standards Officer                                David Pineda Ereño
Office of Commodity and System Standards,        Director, Regulatory Affairs
National Bureau of Agricultural Commodity and    IADSA - International Alliance of
Food Standards                                   Dietary/Food Supplement Associations
50 Phaholyothin Road, Ladyao, Chatuchak,         50, rue de l'Association
Bangkok 10900 Thailand                           1000 Brussels
Tel: (662) 561 2277 ext 1426                     Belgium
Fax: (662) 561 3373, (662) 561 3357              Tel: +32 22 09 11 55
E-mail: panpilad@acfs.go.th;                     Fax: +32 22 23 30 64
E-mail: codex@acfs.go.th                         Email: davidpineda@iadsa.be
NON-GOVERNMENTAL ORGANIZATIONS
                                                 International Chewing Gum Association
Comité Européen des Fabricants de Sucre          (ICGA)
(CEFS)                                           Rick Mann
                                                 ICGA – International Chewing Gum Association
Mrs. Camille Perrin                              Email: mann@khlaw.com
CEFS, Comité Européen des Fabricants de Sucre    CC: icga@gumassociation.org
182, av. de Tervuren
B-1150 Brussels                                  International Council of Beverages Association
BELGIUM                                          (ICBA)
camille.perrin@cefs.org
Tel. 32 2 762 07 60                              Ms. Helen Falco
                                                 Adviser - International Council of Beverages
Confederation of the Food and Drink Industries   Association (ICBA)
of the EU (CIAA)                                 3-3-3 Nihonbashi-Muromachi Chuo-Ku
                                                 103-0022 Tokyo, JAPAN
Ms. Susanne Doring                               Tel : +81 3 3270 7300
Director at the CIAA - Consumer Information,     Fax : +81 3 3270 7306
Diet & Health                                    Email : icba@j-sda.or.gp
Tel.: 00 32 2 500 87 55
E-mail: s.doring@ciaa.eu                         International Dairy Federation (IDF)

Ms. Elena Cogalniceanu                           Dr. Judith Bryans
Manager at the CIAA - Consumer Information,      Director
Diet & Health                                    The Dairy Council
Tel: 00 32 511 29 05                             93 Baker Street
E-mail: e.cogalniceanu@ciaa.eu                   London W1U 6QQ
                                                 United Kingdom
Consumers International                          Tel.: +44 20 7467 2629
                                                 Fax: +44 20 7935 3920
Bill Jeffery                                     E-mail: J.Bryans@dairycouncil.org.uk
LLB, National Coordinator
Centre for Science in the Public Interest        Ms. Sandra Tuijtelaars
Email: jefferyb@istar.ca                         Nutrition Officer
                                                 International Dairy Federation
EuSalt, the European Salt Producers'             Diamant Building, Boulevard Auguste Reyers 80,
Association                                      1030 Brussels, Belgium
                                                 Tel : +32 2 706 86 50
Wouter Lox, MD                                   Fax : +32 2 733 04 13
EuSalt aisbl                                     E-mail : STuijtelaars@fil-idf.org
avenue de l'Yser 4
B-1040 Brussels
Belgium
Phone +32 (0)2 737.10.90
Fax +32 (0)2 737.10.99
Email: wouter.lox@eusalt.com.




October 2009                                                                   Page 30 of 31
International Frozen Foods Association (IFFA)

John T. Allan, M.S.
Manager, Regulatory and International Affairs
2000 Corporate Ridge, Suite 1000
McLean, VA 22102
Tel : 703.821.0770
Fax : 703.821.1350


International Organisation of Vine and Wine
(OIV)

Ignacio SÁNCHEZ RECARTE, Ph.D.
Head of Unit Economy and Law
OIV
18, rue d'Aguesseau
F-75008 Paris - France
Tel: +33 (0) 1 44 94 80 82
Fax: +33 (0) 1 42 66 90 63
E-mail: isanchez@oiv.int

Dr Jean Claude RUF
International Organisation of Vine and Wine
OIV
Coordinator for the Scientific and Technical
Department
Phone: +33 144948094
Fax: +33 142669063
E-mail: jruf@oiv.int

World Sugar Research Organization

Dr Richard Cottrell
Director-General
World Sugar Research Organisation
70 Collingwood House, Dolphin Square, London
SW1V 3LX, UK
Tel +44 (0)20 7821 6800
Fax +44 (0)20 7834 4137
Email: rcottrell@wsro.org

WHO
Dr. Chizuru Nishida,
Department of Nutrition for Health and
Development (NHD),
WHO
E-mail: nishidac@who.int

Mrs Margaret Cheney
WHO Temporary Advisor,
E-mail: marcon@cyberus.ca

Professor John Cummings
WHO Temporary Advisor,
E-mail: j.h.cummings@dundee.ac.uk

Professor Jim Mann
WHO Temporary Advisor,
E-mail: jim.mann@stonebow.otago.ac.nz




October 2009                                    Page 31 of 31

				
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