To: Department of Food Safety, Ministry of Health Vietnam Dairy Association should be sent to the Food Safety Department respectful greetings. Currently, when filing announced products with You Bureau, the members of the Vietnam Dairy Association has received official letters from the Chamber of Food product Management - Food Safety Department requires narrowing the declared content of nutrients down to ± 10% of the content on the label. Vietnam Dairy Association has been thoroughly researched and found that this requirement is not feasible and, if applicable, will cause tremendous consequences for the whole of agriculture, livestock, food industry Vietnam's products; as well as companies import and trading of food products in Vietnam. Specifically as follows: 1. About requires ± 10% of the content on the label is not possible, and seriously affect the whole industry production-food business: the nutrient content of the food materials fluctuate greatly seasonality, weather conditions, geographical regions, nurturing mode / fertilization of each farm, the wastage during production, storage, circulation and uncertainties in the process of testing. The fact the food is produced mostly from natural materials, rather than from pure chemicals such as pharmaceuticals, thus controlling the levels of a lot more complicated. 1.1. For protein, sugar, fat: A concrete example: the fat content in the milk of the cow is from 3-4%, ie 30-40g in 1 liter. Thus, if a company produces pasteurized milk products in packaging of 1 liter, the fat content on the label if the average value selected under the guidance of the Codex labeling is 35g / L (eg raw milk Vinamilk) is close enough though always in packaging of 1 liter of milk, 1 liter of milk fat which then provide from batches of material changes from 30-40g, ie 86% to 114% above the amount recorded ring. Compared with the new requirements of the Bureau of Food Product Management, there will be greater risk lots of pure fresh milk products, although packed full 1 liter and 100% raw milk quality assurance, will be unqualified conclusion when tested, and to withdraw huge impact production and business activities of enterprises and of the entire livestock industry. Similarly, for other products from meat, fish, eggs, milk, vegetables, protein, sugar, fat from natural materials also changed a lot, can not meet the level of ± 10% product Management Division Food set. 1.2 . For small levels of nutrients such as vitamins and minerals: concentration of natural ingredients are more powerful oscillation. For example, iodine, a study of the Czech Republic published in the Journal of Animal Health says the average content of iodine in milk from 230.2 ± regions ranged from 133.0 g / l to 702.7 ± 166, 2 g / l (ie difference between the lowest and highest levels of up to 305%, but these levels are completely safe for humans). Even pharmaceutical products using only pure ingredients for the preparation of , not using natural materials from very varied on content, it also allows for some countries very broad tolerances for the product contains multi-vitamins and minerals, as these substances have little difficulty levels preparation, easy loss in the preservation process. for example, US Pharmacopoeia requirements KY3 although very tight, but treatise multivitamin and mineral capsules allow a maximum limit of vitamin A, vitamin D up to 165%, the trace elements such as Chromium, Molybdenum, Iodine and Selenium to 200%, to ensure all the nutrients to the end of the lifespan of the product and covers both the uncertainty in analytical methods (which may spread tens% between the time of the first test sample). 2. Approximately broader content to declare at ± 10% of the production does not mean the product unsafe or affect the interests of consumers: 2.1. For safety: food products if nutrient levels in the range of food in the middle of RNI (recommended intake) and UL (tolerance threshold) are absolutely safe. Report coordinated by the World Health Organization and Food and Agriculture Organization (FAO / WHO Joint Expert Report: Human vitamins & minerals requirements - 2002), stated: Approximately eat between RNI (recommended intake) and UL (threshold of tolerance) is considered adequate to prevent deficiency and eliminate toxicity. the Ministry of Health has issued Circular No. 43 on the management of functional food products, which specifies UL levels of some nutrients, the remaining nutrients without UL's safety because they are very high. Therefore, we recommend that the maximum level of nutrients is under the UL, in accordance with Circular No. 43 of the Department of Health and the conclusions of the FAO / WHO. 2.2. The interests of consumers: As an example of raw milk showed the declaration about nutrient content at a reasonable level is only a matter of practical farming and production, not related to the quality of product or consumer benefits of encapsulation enough
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