Dear Esther:

To calculate the protein content for labeling purposes on supplements consisting solely of amino acids, it should be more accurate to sum the mass of each amino acid in 100 grams (These supplements frequently contain other ingredients such as cellulose). Since you have only free amino acids in the product I do not consider the molecule of water that it is released every time you form a peptide bond. 
The factor 6.25 is applied to the proteins, not free amino acids. It would be a mistake to apply this number to free amino acids since some of them contain non-nitrogen side chain  (i.e, aromatic amino acids such as leucine, isoleucine, valine). The factor 6.25 is used in meat products since meat protein contains a significant number of amino acids with nitrogen side chains(lysine, arginine, glutamine, etc). 
Hope it helps,

Patricio Carvajal Rondanelli
Food Biochemist
Pontifical Catholic University of Valparaiso

2018-05-02 13:45 GMT-03:00 Anders Møller <[log in to unmask]>:

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:InFoods-Food-Comp-L@LISTSERV.FAO.ORG] On Behalf Of [log in to unmask]ADMIN.CH
Sent: Wednesday, May 2, 2018 15:05
To: [log in to unmask]FAO.ORG
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]admin.ch

Internet: www.blv.admin.ch

 

 

 


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