American Holistic Health Association (AHHA) - Translation from Spanish of Venezuelan comments regarding Guidelines
Translation from Spanish of Venezuelan comments regarding Guidelines

Since "food supplements" refers only to vitamins, minerals or mixtures of them, Venezuela recommends the following title:

GUIDELINES FOR VITAMIN AND/OR MINERAL SUPPLEMENTS

The expression "and/or" will be maintained throughout the document.

Preamble:

We recommend:

Completing the sentence "balanced diet" with the term "varied", this implies all categories of foods must be present in the diet.

Instead of "vitamins and minerals", it should read: "vitamins and/or minerals".

Deleting the sentence: "...or consumers consider their diet requires supplements".

According to all said above, we propose this wording:

"Most people who have access to a balanced and varied diet usually obtain from their normal diet all the nutrients they need. Since foods contain many substances that promote health, people must be encouraged to chose a balanced and varied diet before considering the possibility of resorting to any vitamin and/or mineral food supplement. In those cases where the nutritional intake from foods is insufficient, vitamin and/or mineral food supplements will be resorted to to complete the daily diet".

2.1 We suggest to replace in the last sentence "from" with "in", being the wording:

"...their aim is to supplement the nutritional intake in the daily diet".

3.2.2 We recommend to include the following point:

c) It must not reach the established therapeutic levels.

- About point 5, labelling, we make the following remarks:

Number 5.3: Replace the words "should" with "must", and indicate, when appropriate, the expression in IU.

The units used must be weight and volume units, so we suggest the following paragraph:

"The amount of vitamins and minerals present in the product must appear in the label in numerical form and its equivalent in IU when appropiate. The units used must be weight and volume units, according to the Codex Guidelines for Nutritional Labelling".

Number 5.6: Replace "should" with "must" and "special conditions" with "particular", as it is understood that they are conditions of consumption and manipulation and, thus, it must read:

"Conditions of use (amount, frequency, particular conditions) must be indicated in the label".

Number 5.7: Replace "shall" with "must" and add "suggested by the manufacturer" at the end of the paragraph, so it reads like this:

"The label must show a recommendation to the consumer of not exceeding the maximum daily amount suggested by the manufacturer".

Number 5.8: Replace "should" with "must", so being the wording:

"It must not be declared or suggested in the label that food supplements can be used to replace meals or a balanced and varied diet".

Number 5.9: Replace "shall" with "must" and delete "young" at the end of the text as, according to the WHO, "young children" are considered those from 1 to 3 years old, and the indication must refer also to children older than these ages so we suggest the following wording:

"The label must carry an indication that the supplement must be kept out of the reach of children".