I am contacting you regarding an
important development of which you are almost certainly unaware, but that may be
of considerable relevance to any of your
Members who are engaged in food preparation, manufacture and retailing in the
UK. This concerns the final full implementation of a European Community
Regulation (Reg. No. 1925.2006) governing the use of chemicals as source
materials for minerals used in the preparation of foods. Only two weeks ago, the
last loophole permitting the continued use of any unauthorised source material
not included in the official register (Annex II of the Regulation, now amended
without modification) was finally closed.
Since the 1960's 10% of the UK's
drinking water supplies has been fluoridated. The British Government
requires that fluorosilicic acid be used
for this process, but this chemical is now a prohibited substance for adding
fluoride to any human food product. The English law is therefore in conflict
with the prohibition imposed on the use of such substances under EC food
law.
However, additional EC legislation
establishes that medicinal law should take precedence over food law in the
regulation of products such as this, and
this extends to a ban on the exportation of any food products prepared with such
a medicinal ingredient to any other Member State. Whilst your Members export
trade in food products to other EC States may be insignificant, this ban also
applies to retailers importing prepared foods from countries such as Australia
and New Zealand where public water supplies are also fluoridated. Supermarket
chains operating in the UK could find this problematic.
The following notes provide a
background to this issue, and some detailed information that will be of interest
to your legal advisers. Please understand
that this material emerges as the result of many years studying relevant
legislation as a Compliance Analyst, but that I am not qualified to provide any
legal opinion or advice. This document should be regarded solely as identifying
an issue that may be relevant to the interests of Members of the Chambers of
Commerce. Should they consider that this development might constitute a
potential obstacle to their business interests, then they should seek immediate
advice from a legally qualified professional.
Our latest information is from Ireland
(under the same EU regulations as the UK), in the Cork area many restaurants and
cafes are installing reverse osmosis to filter out fluoride in their food and
drinks for their customers at a cost of £700 to
themselves.
Please feel free to pass this on to
interested parties, and to contact me for any further assistance if you
wish.
Douglas Cross BSc, CSci. CBiol, FSB,
Environmental Compliance Analyst
Croft End, Lowick Bridge, ULverston,
Cumbria LA12 8EE
Tel 01229 885420
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