FOR ACTION

FOR ACTION18 May 2015Request for an exemption for iodized salt

Dear all,

In September 2014, FoodDrinkEurope sent a letter to the Commission requesting to include iodized salt into the list of foods which are not required to bear a list of ingredients[1](FCP/INCO/085/13E-Final). The Commission has not yet sent a formal reply to FoodDrinkEuropes letter.

Thanks to the pressure made by the respective national federations, the Austrian and German authorities raised this issue in the last Commission Working Group of 20 March 2015 supporting the industrys request for exempting iodized salt (German letter attached inAnnex 3). Other Member States (e.g. Belgium, The Netherlands, Czech Republic) supported this request in the meeting. The Commission promised to come back on this by mail or in the next Commission Working Group meeting, which will take place on 10 June 2015.

As it is important that other Member States support this request, members (particularly National Federations) are invited to contact their national authorities in advance of the Commission Working Group of 10 June 2015, asking to raise the issue of iodized salt in the meeting and for their support to the concept of exempting iodized salt from the requirement to bear a list of ingredients.In more technical terms, this can be achieved via a delegated act, according to Article 19(2) and Annex VII, Part E of Regulation (EU) 1169/2011 as proposed in the German letter under Annex 3.Please find below further argumentation that can be used.

An overview of current national labelling practices/legislation on iodized salt is available underAnnex 1- Members that have any additional information to be included in the overview are invited to send this to the Secretariat.Last updated: 18 May 2015, to include information from Belgium

Furthermore,an excel table kindly shared by a member concerning the rules on iodized salt in European countries is available underAnnex 2.Please, note that this table refers to the use of iodized salt in processed foods (not to iodized salt as such intended to the final consumer).

Thank you for your co-operation.

Kind regards,

The Secretariat

The following main arguments could be used to support this request for an exemption:

According to EU labelling rules, iodized salt may be regarded as a compound ingredient; hence, the indication iodized salt followed by a list of its ingredients, i.e. [iodized salt (salt, sodium iodate)]; [iodized salt (salt, potassium iodate)] would be required.

-Such a labelling would confuse consumers, while they are not provided with any useful information (as sodium/potassium iodate are normally inter-convertible in terms of nutritional physiology[2]);-Food business operators will have to change the labelling every time the composition of iodized salt is changed by the supplier. In regard to this, the possibility of labelling[iodized salt (contains sodium iodate and/or potassium iodate)]foreseen in Annex VII, Part A, point 7 does not solve the issue, as the labelling would become even longer and more difficult to understand for consumers.-This labelling requirement will result in additional burdens for operators in countries where the use of iodized salt is mandatory (e.g. Austria, Croatia, Slovenia).In other countries, food business operators may choose to prefer normal salt instead of iodized salt, although iodized salt is regarded as important in preventing iodate deficiency in the general population in many EU Member States, according to public institutions and recent studies[3].Additional and more detailed arguments can be found in the FoodDrinkEurope letter sent to the Commission (FCP/INCO/085/13E-Final) -please, do NOT share the letter as such with Member States authorities.

[1]Iodised salt is currently regarded as a compound ingredient and must therefore be followed by a list of its ingredients, i.e. [iodized salt (salt, sodium iodate)]; [iodized salt (salt, potassium iodate)].

[2]Although sodium/potassium iodate are normally inter-convertible in terms of nutritional physiology,for certain groups of consumers, such as consumers with kidney problems/dialysis, it makes a difference if sodium or potassium is used.[3]Institutions such as the German Nutrition Society (DGE) explicitly encourage food manufacturers to use iodised salt in order to improve the supply situation of the population.

For data concerning the populations iodine status in Europe see:EFSA Scientific Opinion on Dietary Reference Values for iodine;Iodine deficiency in Europe: A continuing public health problem (WHO);Global Iodine Status in 2011 and Trends Over the Past Decade.