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: www.blv.admin.ch
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