The debate on Botanical Health Products is one of the most discussed topic at European Union level. It represents the core issue for the food supplements industry and, therefore, a priority for EHPM – European Federation of Associations of Health Product Manufacturers, that represents health-product manufacturers and their instances in the European Institutions.
We talk about it with Michel Horn, President of EHPM since September 2016.
For more than 40 years, Michel Horn has been the CEO of a Belgian food Supplements Company with longstanding experience in the field of Botanical Health Products. Co-founder and Vice President of NAREDI, the Belgian food supplement Federation, he has been one of the driving forces behind the development of industry best practice standards such as the EHPM quality guide.
President Horn, you assumed the new office at EHPM in a controversial period for the food supplements industry. The sector, in fact, is looking forward a breakthrough on botanicals and probiotics which are two of most relevant current issues at EU level. What are the objectives of your mandate?
Botanicals: the Juncker Commission’s policy states: less regulation for better regulation. Despite the statement of the Health Commissioner in 2015, it seems that we cannot expect a new dedicated legal set for botanicals during this legislative period. The on-hold situation for physiological claims allows operators to work but this offers no middle-term security. For probiotics, we are still confronted with the illogical approach which prohibits to identify the products using the appropriate descriptive term which allows the consumer to understand what the product is made of. In some member states like Italy, with a high level of competence in the category, it is on the contrary accepted. For both botanicals and probiotics, the mutual recognition rule is not applied by some member states: Belgium for example wouldn’t grant a notification number for an italian product carrying the term probiotic. Or the UK considers supplements containing sennosides even at low dosages as a medicine by function while it is a notified food supplement in Belgium, France and Italy.
EHPM keeps is objective to obtain a harmonised dedicated legal frame addressing 1. the status – a non medicinal health supporting product- 2. the quality- to guarantee the safety and the effectiveness of the products and 3. the condition under which physiologically constructed claims, also based of a well-documented history of use- are permitted.
But in the absence of harmonisation, we are also supporting by any means the fact that member states apply the mutual recognition principle for products which have not been foreseen in their legislative scope but are largely authorised in others.
Since the beginning of 2017, the Federation has been committed with events, workshops and meetings involving also European Institutions’ representatives, in order to clearly point out the relevant issues of the food supplements market and the needs of companies and consumers. What progresses have been made and what are the plans for the coming months?
We have participated in various ways (interviews, providing requested information and responding to online consultation) to the study into the botanicals situation that is being carried on behalf of the Commission. The results of this study should be known by the end of this year.
We have also been able to invite european opinion leaders to visit food supplement manufacturers. This has been a first discovery for the majority of them. It changes in a positive way the understanding of supplements which are perceived by some as not qualitative. Seing hands-on how the EHPM guidelines are implemented makes a difference. This is certainly something to be continued and to be propagated in other member states. Consumer organisations, which are often critical, should also be invited to see how our industry works. And all possible contacts at the european parliament level are welcome. We have to continue to seed reputational seeds in order to being able to use the resulting good reputation when we will need support once the legislative process will have been engaged again.
It may take more a few years before the food supplements industry met a breakthrough in the field of botanicals. What should we look forward in the future and how should companies get ready?
Our best ally is our credibility. Credibility has to be built step by step and roots in an impeccable behaviour. itself based on quality. Our processes must be perfect from the conception of an innovative product through the production, ending by the marketing messages used when they are put on the market.
Our worst ennemies are outlaw companies. One or two of them are enough to tarnish our image and by this reduce our capacity to influence in an ethical way. Therefore, we should let no room for cow-boys in our industry and on the contrary help those willing to do it better to join our club of ethical and quality-conscious professionals.
FederSalus is actively working for the institutional recognition of a food supplements’ High-Quality Supply Chain. In your opinion, what are the steps that industry’s National Associations should follow to define high-quality standards at National and European level?
The two main issues of all consumption products are
a) their safety and b) the truth of the promises made about them. This is a question not only of legal obligation but also of respect for the consumer. Any quality system for any type of product should apply these two filters at every stage, from the conception of the product until it is put on the market. For products within the FS category, which on top carry a health improving message, it is even more important. Any quality system should therefore address these two filters. An example for this is provided in the scheme at page 10 of the EHPM quality guide1 (picture). EHPM has developed and published this Quality Guide to instruct all members on how to implement a correct quality process for the manufacturing of food supplements. The guide is available for download via the EHPM website so all companies activie in our sector have access to it.