The questions asked in the ongoing “Botanicals” Consultation cannot be answered without implicitly accepting the incorrect premises on which this public consultation is based.
It is a category mistake to present, consider, discuss or qualify “botanicals” as a category of medicines.
Those who seek to regulate the use of “botanicals” in foods and, especially, in food supplements, want us to believe that “under current EU rules, it is possible for Member States to classify a product, on a case-by-case basis, either as food or as medicine depending on its presentation and the claimed effect.
In its 2016 General scientific guidance for stakeholders on health claim applications, the European Food Safety Authority’s NDA Panel stated that “the essentiality of a nutrient is determined by knowledge of its unique ability to reverse clinical signs and symptoms of deficiency, and/or by knowledge of its essential mechanistic role in metabolic functions.
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