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Subject: EU Anti Vitamin Directive - Destruction of Health Freedom Discussed in EU/Ties in With CRN "AGENDA" How This Dovetails With the CODEX: WHAT TO DO!
From: "International Advocates for Health Freedom"
Date: Thu, 28 Sep 2000 18:42:37 -0400

LEF : Please distribute this to LEF members, and post on your site too. All Webmasters: Please post!


Please read the interesting exchange in the email below my comments between Ralph Pike, Director, National Association of Health Stores in England, and Josef Hasslberger, Nature's Plus distributor in Italy. See Josef's health freedom website in Italy, "The Lever of Archimedes" which is now in the process of being translated to English at Examine what they are up against in the EU as regulations tighten and threaten to get much more restrictive. By next year the EU will have finalized some very bad regs unless stopped by health freedom activists, who are hopefully getting better organized now in Europe. Note that a concerted, very methodical effort is being made in Europe right now to DESTROY the supplement industry through a slew of manipulative means: "positive" lists, that aren't the least bit "positive" which massively restrict allowable product ingredients, along with "Article 5" which threatens a massive restriction on product potencies. Note that these EU deliberations threaten to impinge on Codex in 2002 when all EU countries will push as a block of 16 to hasten the pharmaceutical agenda to destroy our access to supplements within the therapeutic range.

This information from the EU dovetails with a so called "CRN AGENDA FOR ACTION" report recently generated by our (alleged) "allies" Council for Responsible Nutrition, that vitamin trade association that is riddled with pharmaceutical interests, and who strongly back the NAS so called "risk assessment" paper that was designed as the alleged "solution" to the threat posed by the German Codex vitamin proposal, when it is in FACT, no "solution"- it just shows how the FDA/pharmaceutically dominated vitamin trade associations are playing "good cop/bad cop" and using the old problem/reaction/"solution" method of "herding" dietary supplements into tighter and tighter controls to the point where they hope to have complete dominance of the supplement industry, and rigid control of our access to the supplements we need. In this case, the Germans are the "bad cops" and the FDA/CRN are the "good cops", having brought us an alleged "solution" to the German Codex proposal: the pharmaceutically funded NAS so called "risk assessment" methodology as our alleged "savior". In the "CRN AGENDA FOR ACTION paper, Dr.John Hathcock announces a partnership between CRN and Cantox Health Sciences International which is led by Ian Munro, a toxicologist who chaired the NAS committee that developed the "UL" or "safe upper level" such as the unscientific, unreasonably low 35 mg "UL" on niacin, which pretty much exposes the pharmaceutical agenda to ban our access to therapeutic potency levels except by prescription.

The UL methodology they used on vitamins they're now using on herbs for the first time as CRN has announced that it will be working with Munro to develop a "UL" for ephedra by sometime in November. Stay tuned on that one, I suspect they'll declare a very low allowable "UL" on ephedra, and if they do, it (along with what has ALREADY happened at CODEX) should serve as a "wake up" call to all consumers and manufacturers world wide. What is the solution to stopping this incremental destruction of our health freedom? First, become educated on the fraudulence of the NAS "risk assessment" paper (and CRN's initiatives in this regard) by reading Dr. Rick Malter's rebuttal to the NAS paper on the IAHF website, then enter into a dialogue with our elected officials about this anti public health, pro pharmaceutical agenda to ban our access to the supplements we need. We must massively spur grass roots opposition world wide, especially in the EU!! Please urge more people to visit the IAHF website at and to sign up for this email distribution list. You can sign up at the website or by sending email to See the discussion below about the regulatory agenda in the EU, which will eventually be used against us world wide due to Codex unless we can stop it.

Date: Thu, 28 Sep 2000 10:12:25 +0100
To: RalphPike
From: Josef Hasslberger
Subject: European Directive - lists and article 5

Dear Ralph,

I have received a copy of your e-mail addressed to some of your associates, where you alert to the danger of the European directive as currently proposed. You are quite correct in saying that the positive lists pose a real danger of leaving a large part of our products to be re-formulated, with less effective mineral formulations than are currently available on the market. Just in these last days I have been analysing the situation with a line of products available in Italy, and the omissions are numerous.

The EHPM (Industry federation) is preparing a list of substances that need to be added to the positive lists, but the preliminary list seems far from complete. I will attach below two lists: 1) the EHPM preliminary list of substances to be added to the lists of the proposed directive, and 2) my additions to that list of substances that I know to be available but that are not contemplated by the directive, and have so far not been contemplated by the EHPM. Note that other vitamin and/or mineral substances would likely be available and would suffer from the implementation of the directive.

For that reason, it would seem much preferable to push for a negative list (a list of prohibited ingredients, because of their known toxicity or other serious drawbacks) instead of the currently contemplated positive list, which is limiting as it precludes the use of anything that is not on the list, and will be turning out to be a real block to product innovation. Result: The health product industry will no longer be able to compete with the pharmaceutical giants, because our ability to innovate will be down close to zero, all substances being prescribed. It will no doubt be immensely difficult to get any innovative substance past the EU Scientific Committee for Foods.

As for Article 5, thanks for attaching the text at the end of your message to remind people of it's content. The second paragraph of article 5 is contradictory to the intention expressed in the first one. Why should the PRI (or RDA) be used as a limit in cases where the safety margin is small?? It would mean that in some cases (where there is a big difference between safety levels and PRI, we tend to use safety levels, and where that difference is small, we should be using the more restrictive interpretation of PRIs as the dosage limit???? Sounds like an extremely dangerous development to me.

Josef Hasslberger

Now here come the lists:


1) EHPM preliminary list of required additions:





Provitamin A cartenoids


Calcium Amino Acid Chelate
Chromium Amino Acid Chelate
Copper Amino Acid Chelate
Iron Amino Acid Chelate
Magnesium Amino Acid Chelate
Molybdenum Amino Acid Chelate
Potassium Amino Acid Chelate
Zinc Amino Acid Chelate
Potassium Aspartame
Vanadium Amino Acid Chelate

Enriched Yeasts:

Selenium Enriched Yeast (rejected by the SCF, 12 May 1999)


Magnesium Orotate
Potassium Orotate Mineral Source Calcium Fluoride
Copper Oxide


Chromium Picolinate (rejected by the SCF, 12 May 1999)
Chromium Polynicotinate
Magnesium Pyruvate
Potassium Pyruvate
Sodium Molybdate
Vanadyl Sulphate
Sodium Caseinate
Nickel Sulphate
Tin Chloride
Zinc Picolinate

2) Additional list of substances contained in Nature's Plus products but
not considered yet.


Vitamin B 7 (Cholin)
PABA (Paraminobenzoic acid)




esterified ascorbic acid


Aminoacid Chelates of
- selenium
- manganese

Aminoacid Complex of
- calcium
- copper
- chromium
- iron
- magnesium
- manganese
- molybdenum
- phosphorus
- potassium
- selenium
- zinc
(Explanation: The number of electrons in the outer orbit of a mineral molecule is represented as the mineral's valence. A mineral must have a valence of at least 2 in order for the amino acids to totally surround the mineral, thereby forming a true aminoacid chelate. Certain minerals, such as for example potassium, cannot be totally surrounded by amino acids, as they have a valence of only 1. However, these minerals can be bound by their single valence to form an aminoacid complex. Although the aminoacids cannot completely surround the mineral, they will still provide a superior form of absorption of these minerals.)

Ascorbates of
- chromium
- iron
- magnesium
- manganese
- molybdenum
- selenium
- zinc

Aspartates of
- boron
- calcium
- iron
- magnesium
- manganese
- potassium
- zinc

Citrates of
- boron
- calcium
- magnesium
- potassium

Glycinates of
- boron
- copper
- manganese

Lysinate of
- calcium
- magnesium

Methionates of
- calcium
- magnesium


Zinc monomethionine

Iron picolinate

Vanadium sulphate

Chromium enriched yeast

Iodine natural source (from algae)

Calcium Pyruvate

-----Original Message-----
From: Ralph A Pike
To: Distribution List
Subject: Food Supplements Directive
Date: 22 September 2000 07:11

Dear Associates,

I have just received a letter from Rosemary Hignett of the Food Standards Agency, who is dealing directly with the EU on the Food Supplements Directive.

As a result I rang to discuss a couple of items, speaking to Corinne Vaughan, and there are two areas of real concern, the first being that only the UK and Italy are raising objections to the incredibly limited positive lists of permitted nutrients. The FSA are concerned that manufacturers are not aware that if a vitamin or mineral form is not present on the lists, then it will become illegal.

If you have any influence in any other EU country, please pressure them to object to the extremely narrow scope of these lists - tried and tested ingredients such as selenomethionine will go - unless they are added now.

Even more importantly, the FSA have received very little industry information on the likely costs of implementation - reformulation, relabelling, initial and ongoing costs are all areas that the FSA must have information about if they are to help our cause with this Directive. The estimates should be based on the Directive as it is currently drafted -which would mean reformulation of probably 70% of your product ranges.

They are genuinely desperate for this information and will guarantee anonymity to the providers of such information. They will even accept a compilation of reports provided by a third party. She suggested that the NAHS might like to do this, but I am loath to get involved in what is essentially a manufacturer issue.

The NAHS will certainly be making additional comments to the FSA about how difficult it will be to sell selenium chloride to a public that has been using selenomethionine for many years, for example. The cost of this is not quantifiable in the same way that industry costs will be, which is why it is so important that your information is provided.

I believe that the first such request for this information was made in a letter from the FSA dated May 16. The deadline for response to this latest one is 13 October. Time is running out - please do this, and do it now!

I am also extremely concerned about Article 5 of this Directive. Only the NAHS and CHC appear to be objecting to this most damaging section of the Directive. Followng a recent meeting with the Working Group of Member States, Rosemary Hignett has circulated comments - the most worrying of which is that there is great pressure from other delegates to give equal weight to USLs and PRIs when the Standing Committee determine maximum levels for supplements.

PRIs have no place in this Directive, and we believe that it is a monumental mistake to accept the wording as it stands, let alone accede to an even more damaging change. For you information, I include the wording of Article 5 (1) at the foot of this message. There is presssure to delete the second half of 5 (1) (b).


Ralph Pike
National Association of Health Stores
PO Box 1455
S7 2YD

Tel/Fax - 00 44 (0)114 249 5345
Tel - 00 44 (0)114 236 3043
Mobile - 07887 594226

Article 5

1. Maximum amounts of vitamins and minerals present in food supplements per daily portion of consumption as recommended by the manufacturer shall be set by taking the following into account:

a) upper safe levels of vitamins and minerals established by scientific risk assessment based on generally acceptable scientific data

b) reference intakes of vitamins and minerals for the population, where these are close to the upper safe levels

c) intakes of vitamins and minerals from other dietary sources