Feedback reference
F6880
Submitted by
John POINTS
User type
Non-governmental organisation (NGO)
Organisation
Institute of Food Science and Technology
Organisation size
Micro (1 to 9 employees)
Country of origin
United Kingdom

I am responding on behalf of the Institute of Food Science and Technology (IFST) in the UK. The IFST welcome the setting of regulatory limits for glycidyl esters, closing the anomaly that 3-MCPD was regulated in a limited range of foods but that it, and related substances of similar toxicology, were unregulated in other foods where concentrations may be similar. We welcome the focus on infant foods.
We would like the Commission to carefully consider any unintended consequences of setting the same limit for GE for oils for direct sale to the consumer as for oils used as ingredients in food manufacturing. The proposed approach detracts from the risk-basis of the legislation, as manufacturing ingredients may be at very low concentration in the final product. Many manufacturing oils currently on the market will breach the proposed limit. The effect of this legislation may be to change the sourcing policy of larger manufacturers towards lower-GE oils. The Commission should consider if this would have any positive or adverse impact on ethical/sustainability goals (e.g. reduced use of palm oil, which it presumably would encourage because palm oil is higher-GE) and any impact on general public health.
If the consequence of the legislation is to drive a change in the processing of oils to lead to an overall in GE then this would be welcome. But if the consequence is that the global oils production stays the same, but that sourcing changes so that larger manufacturers buy-up the supply of lower-GE oils whilst higher-GE oils still find their way into the food chain, then the legislation would not achieve its objective to protect consumer health. The Commission should measure any such consequences in global oil production and sales as part of a post-implementation review.
The IFST believe that legislation should be based upon risk and evidence, and therefore welcome the Commission’s decision to seek more evidence before legislating on 3-MCPD. When it comes to setting the legislation, we would like it to be clear about whether any potential limits apply to whole products, or to the worst-case part of the product consumed. An example is bread, where 3-MCPD and its esters are concentrated in the crust.

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