Codex Guidelines for Vitamin and Mineral Food Supplements:
The Bigger Picture
July 2005 – During the first week of July 2005 the Codex Alimentarius Commission met in Rome, Italy, and, as widely predicted, agreed to adopt the controversial Guidelines for Vitamin and Mineral Food Supplements as a new global standard. However, in its desperation to adopt these guidelines the Commission blatantly ignored its own Procedural Manual rules , and in so doing hammered the final nail into the coffin of its remaining credibility and legitimacy.
Nevertheless, because of the overwhelming public opposition to the Guidelines the text that was agreed in Rome was only a ‘framework' document, and has not yet set any of the more restrictive aspects of the Guideline that the Pharma Cartel would originally liked to have had included. As such it is now clear that the Codex Alimentarius Commission's strategy is to add the most controversial aspects of the vitamin and mineral restrictions one step at a time, in the hope that, if this process continues to proceed slowly enough, consumers will not be roused into any further significant forms of opposition until it is too late.
However, and as we show here, the long-term game plan of the pharmaceutical industry is far more complex than most people realize, and aims to control not only our access to supplemental micronutrients, but also, via the poisoning and patenting of the food supply, our nutrient intake from food itself.
Breaking the rules when it suits them
The legal bases for the Commission's operations and the procedures it is required to follow are published in the Codex Alimentarius Procedural Manual . Codex delegates make frequent reference to this publication, and repeatedly stress the importance of Codex standards and other related texts being drawn up in accordance with its requirements. Nevertheless, their recent meeting in Rome demonstrated once and for all that the Codex Alimentarius Commission (CAC) is quite happy to follow these rules when they suit its aims, but not when they threaten them.
For example, paragraph (b) (page 57) of the Procedural Manual (14 th edition) states that “ all standards and related texts should have a preface containing…..a brief description of the scope and purpose(s) of the standard or related text.” Contrary to this requirement, however, neither the Preamble nor the Scope of the Guidelines for Vitamin and Mineral Food Supplements contain any statement to indicate its purpose.
Similarly, Paragraph 1.3 (Scope) of the Guidelines states that “ These Guidelines apply only in those jurisdictions where products defined in 2.1 are regulated as foods .” In other words, the Guidelines authorize countries to choose between either complying with them or regulating vitamin and mineral supplements as drugs. However, this clause is inconsistent with paragraph 1 of the General Principles of the Codex Alimentarius, as shown on page 31 of the Procedural Manual (14 th edition), which states that “ The publication of the Codex Alimentarius is intended to guide and promote the elaboration and establishment of definitions and requirements for foods to assist in their harmonization and in doing so to facilitate international trade .” Clearly therefore, guidelines that allow countries to regulate vitamin and mineral supplements as drugs cannot be said to be assisting in the harmonization and international trade of these products as foods. As such, paragraph 1.3 of the Guidelines is seemingly contrary to the Commission's own stated principles.
Moreover, it should be noted that paragraph 3.1.1 (Composition) of the Guidelines states that “ Vitamin and mineral food supplements should contain vitamins/provitamins and minerals … whose status as vitamins and minerals is recognized by FAO and WHO .” However, this list of vitamins and minerals is not defined in the Guidelines themselves, and a definitive FAO/WHO document, stating clearly and unambiguously which vitamins and minerals they recognize, does not currently exist. As such the Guidelines should not have been adopted until such time as this anomaly was corrected, as without an official FAO/WHO list there can be no way of knowing which vitamins and minerals are going to be recognized under the new global standard.
Nevertheless, other than the National Health Federation (NHF) , who are the only consistently pro-health freedom non-governmental organization attending Codex, not a single one of the other 161 delegations attending the meeting in Rome, including the official delegations of 121 countries, spoke up to oppose the Guidelines' adoption.
The purpose of the Guidelines revealed
Two days after the close of the Codex Alimentarius Commission's meeting in Rome the United Nations finally came clean on the purpose of the Guidelines, when a press release entitled “ UN commission adopts safety guidelines for vitamin and food supplements” was issued that began with the following statement:
Labeling to stop consumers overdosing on vitamin and mineral food supplements and guidelines to minimize the emergence of potentially deadly drug-resistant microbes were among some 20 new and amended standards announced today by a United Nations commission that is the highest international body on food standards. 
UN commission adopts safety guidelines for vitamin and food supplements
UN News Centre. 11 July, 2005
Clearly, had the preface of the Guidelines admitted that their purpose was to “stop consumers overdosing on vitamin and mineral supplements”, then the resulting outrage and controversy would have ensured that the opposition to their adoption was considerably stronger; perhaps even insurmountably so. As such, the CAC seemingly decided that it had no option but to wait until after the Guidelines were adopted before admitting to their intended purpose. Otherwise, of course, the Commission would have had to prove that consumers are overdosing on vitamin and mineral supplements, a task that would clearly have been impossible .
Regardless however, the regulatory system for vitamin and mineral supplements that the Commission has adopted is clearly aimed at removing substantial numbers of existing products from the market and severely limiting the doses of those products that remain.
Why the Guidelines permit countries to regulate supplements as drugs
As previously stated, the text of the Guidelines authorizes countries to choose between regulating vitamin and mineral supplements as either foods or drugs. At first sight this appears to be a curious line to take for a body concerned with the harmonization of the international trade in food products, especially so given that these two regulatory approaches would on the face of it appear to be somewhat at odds with each other.
However, when one examines the regulatory systems of countries that designate vitamin and mineral supplements as drugs, it can be seen that in many cases the maximum permitted doses of vitamins and minerals in these countries are not actually that different to those that the Guidelines themselves seem likely to authorize.
For example, the Guidelines state that the m aximum amounts of vitamins and minerals in supplements shall be set by taking the following criteria into account:
- upper safe levels of vitamins and mineral established by scientific risk assessment taking into consideration the varying degrees of sensitivity of different consumer groups;
- the daily intake of vitamins and minerals from other dietary sources;
- the reference intake values of vitamins and minerals for the population.
Thus far, the only organization in the world to have carried out vitamin and mineral risk assessment studies based upon these criteria is the Federal Institute for Risk Assessment (BfR) in Germany [6,7]. These studies were led by Dr. Rolf Grossklaus, who as well as being the Institute's Director is also the Chairman of the Codex Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU). The CCNFSDU, of course, was the Codex committee which actually drafted the Guidelines for Vitamin and Mineral Food Supplements in the first place.
Published in 2004, the BfR recommendations for the maximum permitted levels in vitamin and mineral supplements are as follows:
|Vitamin A 800 mcg
Beta carotene 4mg
Vitamin B1 1.3 mg
Vitamin B2 4.3 mg
Niacin (B3) 17 mg
Pantotheic Acid (B5) 18 mg
Vitamin B6 5.4 mg
Folic Acid 400 mcg
Vitamin B12 9 mcg
Biotin 180 mg
Vitamin C 225 mg
Vitamin D 5 mcg
Vitamin E 15 mg
Vitamin K 80 mcg
|Calcium 1200 mg
Chromium 100 mcg
Copper 1.5 mg
Fluoride 3.8 mg
Iodine 200 mg
Iron 15 mg
Magnesium 400 mg
Manganese 5 mg
Molybdenum 100 mcg
Phosphorus 1250 mg
Selenium 70 mcg
Zinc 10 mg
As can be seen, in the majority of cases these numbers correspond very closely to RDA-type values. Given therefore that countries who currently regulate vitamin and mineral supplements as drugs typically restrict their over-the-counter doses to RDA-type levels, it is readily apparent that ultimately there may end up being very little difference between the types of supplement products that can be purchased around the world under either food or drug regulatory regimes. This, then, may well be the reason why the Guidelines for Vitamin and Mineral Food Supplements permit countries to regulate supplements as drugs, in that the types of products that can be purchased under both types of regimes could in time become more or less identical.
The ‘missing' FAO/WHO list of recognized vitamins and minerals
As we have seen, the Guidelines state that vitamin and mineral food supplements should contain vitamins and minerals that are recognized by FAO and WHO. Nevertheless, the Guidelines do not define this list, and a definitive FAO/WHO document, stating clearly and unambiguously which vitamins and minerals they recognize, does not currently exist.
In trying to understand why FAO/WHO were seemingly not prepared to issue a list of the vitamins and minerals that they recognize in advance of the adoption of the Guidelines, it is important to realize that the text and intent of the Guidelines is essentially based upon that of the EU Food Supplements Directive .
Passed by the European Parliament on 13th March 2002, the Food Supplements Directive has two main elements.
Firstly, and like the Guidelines, it requires maximum levels to be set for all vitamins and minerals contained in supplements.
Secondly however, and just as controversially, it limits the types of vitamins and minerals that can be contained in supplements to those contained on a restrictive so-called “positive” list. This list excludes a number of different types of vitamins and minerals, including seven different types of vitamin E ( gamma tocopherol, delta tocopherol, beta tocopherol, gamma tocotrienol, alpha tocotrienol, delta tocotrienol and beta tocotrienol), and minerals such as boron, vanadium, silicon and sulphur.
As such, many people believe that the FAO/WHO list of recognized vitamins and minerals, when eventually published, has the potential to be used (or rather, mis-used) as a “positive” list. In such a situation, therefore, it is quite possible that some types of vitamins and minerals might not be recognized by FAO/WHO, and could end up being prohibited under the Guidelines.
Because of this it seems very possible that FAO/WHO may have been reluctant to publish a list to clarify which vitamins and minerals they recognize, in case the resulting controversy increased public opposition to the adoption of the Guidelines.
Now that the Guidelines have been adopted, of course, it is clearly more likely that such a list will now eventually materialize.
The growing links between Codex and other international organizations
Close examination of the report of the CAC's meeting in Rome ,and the documents cited in it, reveal a growing number of links with other international organizations and committees. These, of course, are in addition to the links that the Commission already has with its parent bodies; namely the FAO, the WHO, and the United Nations.
The World Trade Organization ( WTO)  for example, uses Codex texts as a means of resolving international trade disputes  and WTO Members are legally obliged to abide by WTO rulings . Despite this however Codex officials generally downplay the relationship between Codex and the WTO, and state that the implementation of Codex texts is not mandatory [13,14].
However, the Codex Secretariat regularly represents the CAC at meetings of the WTO's SPS and TBT committees, and cooperates with the WTO in “training activities” at the regional level . Similarly, representatives of the WTO attend key Codex meetings as observers , and the SPS Committee receives regular updates on the standard-setting activities of Codex .
Moreover, a procedure adopted by the SPS Committee in 1997 to monitor the use of international standards actually invites countries to identify specific trade problems they have experienced due to the use or non-use of international standards, guidelines or recommendations. These problems, once considered by the SPS Committee, are then drawn to the attention of the relevant standard setting body, such as, for example, the Codex Alimentarius Commission . As can be seen therefore, the CAC is, in reality, involved in significant collaborative efforts with the very bodies that police the enforcement of its standards.
The International Atomic Energy Agency  meanwhile is arguably, to the casual observer, one of the more surprising of the regular attendees at meetings of the Codex Alimentarius Commission. However, a Joint FAO/IAEA Division of Nuclear Techniques in Food and Agriculture  has existed since 1964, and is now involved in significant collaborative efforts with Codex committees, such as with the Codex Committee on Food Additives and Contaminants in the elaboration of revised Codex Guidelines for Levels of Radionuclides .
The Joint Division's other current activities include the development of emergency preparedness and response to nuclear emergencies affecting agriculture . These measures include arrangements between FAO and IAEA for notification, information exchange and provision of technical support in relation to food and agriculture, to be enacted in the event of a nuclear or radiological emergency and its aftermath .
The International Organization for Standardization (ISO)  also attends meetings of the Codex Alimentarius Commission, and maintains contacts for information exchange with the Codex Secretariat . An international non-governmental organization, ISO has a strategic partnership with the WTO , and on behalf of the WTO periodically publishes a Directory of standardizing bodies that have accepted the WTO TBT Standards Code . Although its principal activity is the development of technical standards there is a significant degree of overlap with the work of Codex, as ISO is also involved with food safety work .
Other international organizations currently developing closer links to the Codex Alimentarius Commission include the World Organization for Animal Health (OIE) [29,30,31], and the World Intellectual Property Organization [32,33].
As can be seen therefore, the Codex Alimentarius Commission is not an organization acting in isolation, but is instead increasingly one of the central cogs in the hydra-headed beast controlling the global food supply.
The bigger picture
There are currently a total of 27 different active Codex committees and Task Forces ; each one of which is mandated by the Codex Alimentarius Commission to set standards and guidelines for different aspects of the global food trade. For example, Codex committees are currently engaged in the act of setting global standards for foods including fruits and vegetables; fruit and vegetable juices; fats and oils; meat and poultry; fish; cereals, pulses and legumes; milk and milk products; natural mineral waters; sugars; cocoa products and chocolate, amongst others. Similarly there are other Codex committees who are tasked to deal with areas such as food hygiene, food labelling, pesticide residues, residues of veterinary drugs found in foods, food additives, regional coordination work, and so on.
Quite clearly therefore, Codex is not just about dietary supplements. In fact, it is the primary political battlefield where the war is being waged about who will regulate and control the global food supply from farm to fork. This ‘war' is being waged by an increasingly tangled web of global authorities, big business and financial interests [35,36]; and, as such, trade and profit have now become the prime concerns of the CAC, regardless of whether the products under discussion are dietary supplements, ordinary foods or food additives.
Moreover, although it is the work of the Codex Committee on Nutrition and Foods for Special Dietary Uses that has thus far attracted most of the attention from the natural health movement, due to its development of the Guidelines for Vitamin and Mineral Food Supplements, the activities of other controversial Codex committees have hitherto been largely ignored. However , and as we will examine next, the work of one of these committees, the ad hoc Codex Intergovernmental Task Force on Foods Derived from Biotechnology , is to be ignored at our peril, as it already has the potential to profoundly affect the health of not just all human life, but also that of the planet itself - along with its many complex and delicate ecosystems.
The ad hoc Codex Intergovernmental Task Force on Foods Derived from Biotechnology
In March 2002 and March 2003 the ad hoc Codex Intergovernmental Task Force on Foods Derived from Biotechnology submitted reports [39,39] to the Codex Alimentarius Commission recommending the adoption of global guidelines for foods derived from biotechnology. Following a meeting of the Codex Alimentarius Commission that subsequently took place in Rome in July 2003 these guidelines then became finalized and adopted as new global standards [40,41,42,43].
The long-term implications of the adoption by Codex of global guidelines on foods derived from biotechnology cannot be understated, as they effectively mean that any WTO member country producing GM foods that conform to them can now file a complaint with the WTO whenever another member country refuses to allow their goods to be imported and sold within its borders. In the process of resolving such a dispute, the WTO Dispute Settlement Body would refer to the texts on biotechnology that have been adopted by the Codex Alimentarius Commission, and would likely find in favour of the country that was acting in conformity with them. Indeed, a case of this type is already underway, as in May 2003, only two months after the ad hoc Codex Intergovernmental Task Force on Foods Derived from Biotechnology had recommended the adoption of the new global guidelines , the United States, Canada and Argentina filed trade complaints at the WTO against the European Union (EU) .
The essence of the United States', Canadian and Argentinean complaints centers around the fact that the EU has essentially applied a moratorium on the approval of biotech products since October 1998, and that this has restricted GM products manufactured in these three countries from being imported into the EU.
If the WTO rules in favor of the United States, Canada and Argentina in this dispute then the EU would be forced to accept GM foods from these countries. If the EU still refused to allow these foods to be imported however it could face heavy punitive fines or WTO-endorsed trade sanctions until such time as it agreed to comply.
The final report from the WTO Panel who are judging these cases is currently expected to be released by the end of October 2005.
Patents equal higher profits
Unlike the seeds for regular foods, the seeds for GM foods can be patented. This, essentially, is the real key to why biotech companies are so desperate for these foods to be forced onto world markets, as the potential long-term profits are so colossal as to compare quite favorably with the market in pharmaceutical drugs. As such, therefore, it should come as no surprise to learn that some of the major players in the pharmaceutical industry, such as Bayer  and BASF , are also major players in the biotech industry.
Furthermore however, the patented chemicals and artificial additives that are also being added to the global food supply – with the blessing of the Codex Committee on Food Additives and Contaminants  – are likewise being manufactured by many of the same pharmaceutical and chemical companies that would like to ban vitamin supplements and put GM foods onto our dinner plates. And, as with pharmaceutical drugs and GM seeds, the main reason why most of these chemicals and artificial additives exist is because they can be patented, and patents equal higher profits.
Once one understands this, the entire Codex picture becomes instantly clearer, and it can easily be seen that s o far as the pharmaceutical industry is concerned the only products that are worth producing are those that are patentable. Because of this, the rise in the popularity of food supplements, natural health practices and even organic food represents a serious threat to the pharmaceutical industry. The financial interest groups behind the Codex Alimentarius Commission know this only too well, of course, and as such are now engaged in a desperate struggle to maintain their monopoly upon the healthcare industry and expand into GM food production.
Current indications suggest that the long-term financial winners in the battle to gain control over the world's food supply are likely to be the pharmaceutical industry; especially so given that the adoption of still further Codex guidelines for foods derived from biotechnology now seems almost inevitable. As a result, our freedom of choice, our future health and the environment itself are all now clearly at risk .
Do we want to see a world where our access to safe, nutritious foods and effective dietary supplements is restricted and controlled by pharmaceutical interests? If not then we must act now, because if we don't, this is where we are headed.
Good nutrition and optimum health threaten the pharmaceutical industry's Business with Disease because they reduce the size of the marketplace for synthetic drugs. However, food that is free of pesticide residues, residues of veterinary drugs, artificial additives and other contaminants can, by definition, only come about as a result of a lower global usage, or ideally the entire elimination, of these chemicals. This, of course, would not be in the financial interests of the pharmaceutical and chemical companies that manufacture such substances, as it would clearly result in lower profits, better health for entire populations, and a consequent reduction in the use of synthetic drugs.
As such, it can therefore be seen that the pharmaceutical industry's long-term game plan is to limit global access to optimal nutrition in all of its forms, both from food and dietary supplements, and to ensure that the permitted levels of pesticide residues, residues of veterinary drugs, artificial additives and chemical contaminants either remain the same or are revised upwards.
We are thus witnessing an attempt by the pharmaceutical industry to assume control over the nutritional intake and health of the entire planet, and, as such, further support for the Foundation's anti-Codex activities and World Health Alphabetization campaign has never been more urgently needed.
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