optimismThe Irish Health Trade Association (IHTA) Chair, Phil Costigan, looks at the future with optimism in Health Food Business Trade Magazine – February 2017.

Spring is upon us, here in Ireland, February 1st is called Lá fhéile Bríde (St. Brigid’s day) which officially marks the start of the pagan festival of spring. The season of spring is seen by many as a time of growth, renewal, new life and metaphysically the start of better times. So celebrating this new beginning, the IHTA embraces 2017 with an optimistic and positive outlook and we present our wish list for the forthcoming year.

VAT on food supplements

The IHTA seeks a clear, practical and fair approach by Revenue to the Classification of Food Supplements for VAT Purposes whereby food supplements are considered as foods for VAT classification purposes. To do otherwise would undermine the legitimate aspirations and integrity of the industry and its consumers;


It is vitally important for the national industry sector to maintain unencumbered access to our neighbouring UK market and they to us, media commentators continue to highlight the unacceptability of the introduction of any new border/regulatory controls. It is in all our interests that accommodations can be reached to avoid bureaucratic requirements for certification / customs which would introduce barriers and administrative costs;

National rules versus EU Regulation

Taking account of the European Commission President, Jean-Claude Juncker’s address at the Council of Europe in April 2016, stating the EU were wrong to over-regulate and interfere too much where member states are better placed to take action, we can now see the emergence of national rules being applied by EU Member States.

For example the Belgian government has set its own maximum levels for added nutrients in foods and supplements in a draft decree, in addition, in Sweden a sales ban imposed on vitamin B6 supplements that exceed “EFSA-recommended upper limits” has been overturned by a Swedish court. The court ruled that since maximum permitted levels (MPLs) have not yet been mandated at EU level, an EFSA recommendation is not binding.

The IHTA as a responsible stakeholder, have forged strong consultative links with our regulators and we look forward to continuing in meaningful dialogue regarding regulatory interpretations and implementations at national and European level;

Industry promoting and engaging in best practice

All responsible businesses are regulatory compliant, manufacturing and placing on the market quality and effective products that ensure consumer safety, that said, the Rapid Alert System for Food & Feed (RASFF) 2015 Report recorded over 3,049 alert notifications with 775 serious health risks. Allergen contamination in spices and other food stuffs is a growing problem that needs to be addressed, incidences involving food supplements have decreased over the years and many of these were related to labelling, not safety. The IHTA and its members support and implement the quality guide developed by industry partner the European Federation of Health Products Manufacturers Associations (EHPM), our own national regulators the Food Safety Authority of Ireland (FSAI) acknowledging its usefulness and validity.

Industry led auditing will stimulate a market place where safe and effective health products can be supplied to consumers on the basis of honest accurate and meaningful information, we expect this will foster enterprise and growth in the whole health product sector. To avoid consumer confusion, industry needs to go a step further and work together to establish an online database of products legally placed on the market accessible to consumers allowing them to take on more responsibility for their own health;

Regulatory home for all products

Classification has always been an area where industry and regulators can fail to agree namely on the distinction between medicines and food. It is in everyone’s interest to have workable regulatory frameworks applying to all products on the market. A range of EU regulation together with national interpretation and implementation go a long way towards this but to have a fair workable system, industry expertise on the distinction between health products produced, supplied and used to prevent and treat an illness (e.g. herbal and homeopathic medicine) and health products produced, supplied and used to maintain or enhance health (e.g. whole foods and food supplements) needs to be recognised by the policy makers;


So spring 2017, tá fáilte romhat (welcome), let all key players work together, let us pool our wisdom, expertise and good will, let’s work on the positive, our future can be very bright.