Industry calls on EU Commission to remove barriers to export into the EU of products containing Vitamin D3

Industry groups including BSNA have joined together to call on the EU Commission to remove barriers to the export into the EU of Vitamin D3 through its classification as a Product of Animal Origin (POAO). Instead, it should be considered a chemical entity, and therefore not be subject to Border Control Checks, Export Health Certification or a private attestation. The industry group, made up of the European Specialist Sports Nutrition Alliance (ESSNA), the UK Council for Responsible Nutrition (CRN UK), the Consumer Healthcare Association (PAGB), Health Food Manufacturers Association (HFMA) and BSNA, has been working with the Department for Environment, Food and Rural Affairs to push for a change in the EU's classification.

Vitamin D3 has been imported into the European Union from third countries for many decades, both as an ingredient and in finished food supplements, formula and other food products. The vitamin D3 ingredient enters the European Union as an organic chemical, and its inclusion in finished food supplements, formula and other food products is the same as that of all the other vitamins and minerals, i.e. it is from a chemical source.

Although the very original starting material might be lanolin extracted from sheep’s wool, the lanolin undergoes a lengthy process of seven complex chemical conversion steps, which includes six stages of purification, in order to produce the pure crystallised vitamin D3 that is used in foods. This finished vitamin D3 is a new chemical entity of high purity.

The complex nature of the chemical steps and the six stages of purification mean that there is no risk of any undesirable elements that may be present in the original animal to be present in the pure crystalline vitamin D3.

• There is no trace of lanolin or other ovine product in the finished vitamin D3 ingredient.

• Any veterinary medicine residues, pesticides or any other chemicals that might be present in the original wool are removed by the numerous and varied purification stages.

• There is no risk of microbial survival following the full range of purification stages particularly as one step includes treatment with ultraviolet light.

Therefore, the presence of vitamin D in food supplements, formula or other food products should not initiate Border Control Checks, Export Health Certification or a private attestation when exported from Great Britain or other third countries to the European Union and Northern Ireland.

BSNA, along with its partners at ESSNA, CRN UK, PAGB, and HFMA will continue to press the EU Commission, with DEFRA, to change the EU's classification and support the appropriate export of products which contain Vitamin D3.