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Thoughts about Regulation and the future.

Trawling the net is a simple way to confusion. So it seems is the subject of food labelling. As the WHO is asking for standardisation on nutritional labelling; the EU is criticising the UK for its traffic light system; the Food Information regs(FIR) are approaching their first action in December to highlight allergen issues.
The Food Information for Consumers regs are intended to bring general and nutritional labelling together into a single regulation to simplify and consolidate existing regs. As an EU directive it then needs enforcement which is where in the UK one could become confused. According to the FSA, general food labelling is the responsibility of Defra; Nutritional labelling, is the responsibility of the department of health; unless of course you are in Scotland or northern Ireland where regs are administered by the FSA – or in Wales where nutritional labelling falls back onto the Welsh Government.
There are then accusations starting that the FIR will disadvantage artisan cheese and bread makers requiring regular analysis of raw materials with changes being altering labels. Costs of this type of action, both in analysis and labelling add pressure not value to SME’s. Will the consumer benefit if these producers are put under ever more pressure. These regulations are about protecting the consumer, transparency in the supply chain and improving consumer knowledge. But who will pay?
Organic sales in the UK are only just starting to show recovery after a five year low. Consumers are price sensitive and the economic climate is far from buoyant.
We are told that disease prevention through healthy nutrition is a priority in the political agenda. But conversely the political agenda also promotes a cheap food policy. Regulation provides benefit to consumers and demands increased quality control from business. Competition; NPD costs in economically challenging times and fast changing regulation are issues that are just facts of life. As nutrition starts to become more important in food formulation skill, knowledge, technology all become key to innovation. This may seem obvious but to new entrants to the market, developing these resources is essential to success. For new entrant SME’s acquiring these resources either takes patience; funding or can be achieved through partnership. In times past companies grew and evolved. Coco Cola, Ocean Spray are both huge concerns whose early history has comes from individuals with passion, some luck, some opportunism. In a fast moving world it is often easy to go and borrow funding to develop your good idea. But passion is not enough. I have found with growing sea buckthorn in just a few years there are many issues that emerge that need resolution. With a crop, agronomy management is the difference between profit and loss. Some problems cannot be foreseen but need to be flushed out through experience. This takes patience.
Borrowing funding is a means of providing the resource to buy in skill, technology, consultancy, but it is not the route to guaranteed success. It can accelerate opportunity but it adds cost which needs balancing against low risk income. When developing new product in a high risk market a cool head and tempering passion needs to level plans to identify risks. If risks cannot be identified, or their solutions easily delivered then patience has to return. Some would say this lacks confidence. I would reply that it is better to develop and grow than become a slave to the bank.
Partnership between SME’s can link passion. It can pair up resources for mutual benefit. If objectives require specialist resources then a cautious approach to large companies is acceptable, as long as it is a calculated means to an end.

Sea buckthorn is a nutrient resource for the food/drink and natural cosmetic industry. It has all the attributes required within the healthier food market. Multivitamins; essential fatty acids; flavonoids; carotenoids – and a complex of other polyphenols that have potential for innovative NPD. A phase I read this week – ” Holistic link between ingredient innovative product development, consumer testing and regulation” is particularly appropriate to bring sea buckthorn into the current market place. This process is not driven by passion. It is an analytical approach to bringing market and consumer need into balance with the potential that a natural ingredient can provide.
Within this same context as a grower and supplier of sea buckthorn I need to develop my resource to provide efficient production technique; be resource efficient and eco-friendly; and have a policy that secures food safety. Its authenticity is mixed in that my plants are resourced from across Europe and Russia. But these bring with them many decades of development to improve taste; yield; disease resistance; harvestability. Authenticity is a factor of evolution. It has a basis of appreciation of natural and traditional usage. Sea buckthorn is a plant; an ingredient; a nutrient source whose pedigree establishes itself as an Ice Age pioneer plant, through ages of health benefit use across Asia and Europe to becoming a centre of research to define its diverse opportunity offering.

A centre of research is no use however if it does not follow through with clinical trials that deliver definitive results that are accepted by EFSA as providing a health claim. This has been a growing concern over the past few years but it seems that across Europe there are moves to improve the status of botanicals. The French, Italian and Belgian governments are approving parts of the Belfrit list. This is a list of plants considered safe through the experiences of traditional use. Linked to the list is the available scientific evidence that conveys efficacy.
THE Belfrit list came out of a meeting of the Plantlibra project. EU funded this study looks at the levels of intakes of botanicals, their benefits and risk assessments all relative to the use of botanicals in supplements. This international project developed, validated and disseminated data on botanicals and like Belfrit helps to accumulate the evidence necessary to persuade regulators that traditional use plants have a future. The Bacchus project, again EU funded is developing tools to create evidence for use to support the relationship between consumption of bioactive peptides and polyphenols and the beneficial physiological effects relative to cardio vascular disease in humans.
All these projects are a real inspiration that gives confidence that despite the issues with health claim regulations it may well be possible to communicate traditional use of some botanicals without falling foul of regulators.