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Subject:
From:
Anders Møller <[log in to unmask]>
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Date:
Wed, 2 May 2018 18:45:48 +0200
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Dear Esther,

 

GOOD QUESTION!

I would contact the European Food Safety Authority and/or national food
authorities to get a more clear answer.

 

I do not know if this is of much help:

 

1.       The Directive 2002/46/EC of the European Parliament and the Council
of 10 June 2002 relating to food supplements states that “Specific rules
concerning nutrients, other than vitamins and minerals, or other substances
with a nutritional or physiological effect used as ingredients of food
supplements should be laid down at a later stage”. The Commission is
investigating this, see bottom of
https://ec.europa.eu/food/safety/labelling_nutrition/supplements_en 



2.       The Regulation (EU) No 1169/2011 of the European Parliament and of
the Council of 25 October 2011 on the provision of food information to
consumers
(http://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX:32011R1169)
clearly states that the Nutrition declaration section in the Regulation
does not apply to ”Directive 2002/46/EC of the European Parliament and of
the Council of 10 June 2002 on the approximation of the laws of the Member
States relating to food supplements”

 

So where does this leave us?

 

In DK and other Member Countries it is obligatory to register a food
supplement with the national food authority, the ingredients/components
added and how the amounts are determined (calculated/analysed). It is then
up to the authority to determine (inspect/control) if the declared amounts
are determined with a plausible method and within the given range for that
component.

I also guess this is the current situation for you J

 

So, back to your questions (and my personal opinion J):

 

-          Can you just sum up the amino acids? Or only the proteinogenic
AA?
No, the sum of amino acids is NOT the same as “protein”.
However, the sum of (proteinogenic) amino acid residues, i.e. amino acid
minus an H2O molecule (surplus from the peptide bonds in the protein) would
in my judgement be correct (and the FAO recommendation, see also
http://toolbox.foodcomp.info/ToolBox_Protein.asp).



-          Or do you have to apply the general factor of 6.25? Would you
apply the factor to total N or only to N from proteinogenic AA?
The mandatory way of determining protein for food labelling in Europe is
Kjeldahl nitrogen multiplied by the “Jones’” (nitrogen-to-protein) factor
6.25 and I suspect that most authorities would “lean against” this
definition.
Using an value for nitrogen only from (proteinogenic) amino acid residues
may be more correct, but why take this “detour”?

 

I have not yet seen clear European regulations for the food supplement
nutrition declarations – maybe other members of the list have?

 

 

All the best,

Anders

 

Anders Møller

Borgediget 12

DK-4000 Roskilde, Denmark

 

 

 

 

 

From: Food Composition Discussion Group
[mailto:[log in to unmask]] On Behalf Of
[log in to unmask]
Sent: Wednesday, May 2, 2018 15:05
To: [log in to unmask]
Subject: Calculation of protein content of amino acid supplements

 

Dear All,

 

we are having an internal discussion on how to calculate the protein content
for labelling purposes based on the European legislation for supplements
consisting solely from amino acids and/or other N-containing substances.

 

Can you just sum up the amino acids? Or only the proteinogenic AA? Or do you
have to apply the general factor of 6.25? Would you apply the factor to
total N or only to N from proteinogenic AA? Or….

 

Thank you in advance for your inputs.

 

Best wishes,

Esther

 

 

 

Esther Infanger, RD, MNutr

Scientific collaborator

 

Federal Food Safety and Veterinary Office FSVO

Division Food and Nutrition

Sector Nutrition

 

Office: Schwarzenburgstrasse 155, CH-3003 Bern

Tel: +41 (0)58 469 70 88

E-Mail: [log in to unmask]

Internet:  <http://www.blv.admin.ch/> www.blv.admin.ch

 

 

 

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