Notice for all those firms engaged in food preparation from Doug Cross.
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