Short but interesting DM article (sorry!) about differing food standards between EU and UK specifically E171 in fairy sprinkles, mayonnaise and sun scream to name a few

[Raspberrymeringue88]

www.dailymail.co.uk/news/article-10629027/Food-colouring-banned-EU-potential-cancer-risks-used-Britain-whitening-agent.html

Sorry about the origin of the article but I thought this was interesting:

(a) because there's the issue of why the UK's view of the science differs from that of the EU in the first place? Is it UK policy to take a more "risky interpretation" of the science or is the EU being overly cautious?

(b) the issue of the science itself - what is the difference between carcinogenic and gentoxic? I have no clue but someone on here might know!

(C) the fact that this has appeared in the DM at all (thought is was pro-Brexit?)

(d) the wider implication for import export of foodstuffs between EU and UK and Northern Ireland, given that this will presumably be just one of thousands of such issues? Will EU manufacturers make poorer quality versions of the same product for UK market? Presumably UK food manufacturers will have no choice but to follow EU legislation if they want to export to EU?

(e) the wider implications for UK food legislation, that is, will it decide to wait until EU makes pronouncements about certain foodstuffs or additives and then make its own decision (as has happened here) and how far are they willing to divert away from EU legislation or it wiil they roughly stay in line with EU?

It's the first specific issue like this that I have seen highlighted in the popular press anyway, given that so much of the Brexit coverage has been obscured by Covid and now the war in Ukraine, and I thought it raised some interesting practical and policy issues for those interested.

Oh well, maybe it's only me who finds it interesting and we are all Brexit-ed out!

It's not like we don't have a food standards agency. And there are lots of differences in recommendations between the EU agency and the USA's FDA which is stricter over some things and laxer over others. But we don't think the FDA is acting incompetently because it disagrees or behaves differently. In fact the FDA prohibits the sale of many suncream in the US that are made in the EU because they don't meet their standards. So are the EU standards too low? Or is the US behind in its science?

I think it's always been the case that the UK FSA has occasionally disagreed with the EFSA but has had to follow EU regs.
But just like the UK MHRA proved itself perfectly able to act give as independent and competent, and ultimately faster, advice as the EMA, I don't see why the FSA can't act be just as competent and informed as the EFSA.

Thanks for that interesting perspective Nightly stroll.

I must admit that I don't have a very informed view of the FDA because all one hears about is hormones in beef and chlorinated chicken so I assumed that FDA food standards were generally lower than that of the EU across the board but I don't claim to be any sort of expert in this area so happy to be corrected!

I don't doubt that the UK FSA is as competent and informed as the EFSA as much as I suppose I worry about the policy governing the use of the scientific data, especially when political decisions are governed by commercial ones.

It’s hard to discuss specific cases as the risk assessments behind them are frequently very convoluted and and difficult to follow. There is usually a broad consensus and countries do ‘sense check’ against each other and compare notes frequently, but each area has different comfort levels when it comes to exposure.

I worked in chemical risk assessment for various UK agencies for most of my career, so gained an understanding of the differences in attitudes globally.

In my specific field, the accepted cancer risk for soil exposure was one of the easiest to explain, so I’ll go with that.

In the US (off the top of my head) the acceptable incidence of cancer from exposure to a substance was 1:10,000. In the UK, it was 1:100,000.

Therefore any US levels used had to be reduced by a factor of ten to even be in the same ballpark.
Some countries use exposure levels, some prefer to look at the sensitivity of the particular population. Some will use both.

Then there’s the maths that’s used to determine probability, different models provide different results, and there each will be preferred by different agencies at different times.
It’s more that the science is interpreted differently by different people rather than it being wrong/right.

In answer to (b) genotoxic substances alter the genetic pattern of the cells, so potentially causing cancer or other illnesses whereas carcinogenic substances cause cancer by a secondary mechanism.

I've given uplooking for whiter mayo [we moved to France last year]. I can now see why my mission was flawed.

That's really interesting DanaBarrett thank you for your expertise!. And for the explanation of genotoxic even though it is somewhat worrying!

Seriously though, I understand your point that the interpretation of the science governing these issues is extremely complex. And even the science itself is sometimes based on different criteria.

And wow wrt the dramatic difference between the USA and UK over accepted cancer risk for soil exposure!

AlisonDonut

I must admit that I don't have a very informed view of the FDA because all one hears about is hormones in beef and chlorinated chicken so I assumed that FDA food standards were generally lower than that of the EU across the board

If you think about the sweetener aspartame, the US FDA banned it in the 1980s over cancer fears after studies on rats. In 2013 after investigations the EFSA cleared it for consumption in the EU. There are plenty of differences between what each body considers an acceptable level of risk/safety.

As for you worrying about political pressures, that happens in all of the agencies. All governments have an agenda they'd like to see achieved. But just as the UK govt wanted the MHRA and the JCVI to speed up their decision making process, and they refused and did due diligence, there's no reason to believe the UK FSA won't do the same. These are professional bodies with their reputations at stake. Unfortunately, though, if a person believes that EU bodies are more trustworthy and competent that UK bodies, I doubt any reassurances are going to stop them from worrying.

I thought that generally Europeans, including the UK, worked on a precautionary principle, whereas the Americans tended to assume something was safe until proved not.

@Nightlystroll

I must admit that I don't have a very informed view of the FDA because all one hears about is hormones in beef and chlorinated chicken so I assumed that FDA food standards were generally lower than that of the EU across the board

If you think about the sweetener aspartame, the US FDA banned it in the 1980s over cancer fears after studies on rats. In 2013 after investigations the EFSA cleared it for consumption in the EU. There are plenty of differences between what each body considers an acceptable level of risk/safety.

As for you worrying about political pressures, that happens in all of the agencies. All governments have an agenda they'd like to see achieved. But just as the UK govt wanted the MHRA and the JCVI to speed up their decision making process, and they refused and did due diligence, there's no reason to believe the UK FSA won't do the same. These are professional bodies with their reputations at stake. Unfortunately, though, if a person believes that EU bodies are more trustworthy and competent that UK bodies, I doubt any reassurances are going to stop them from worrying.

Again, I appreciate your answer Nightly Stroll.

As a consumer , I do find it strange that there is no common standard of risk but I understand what you are saying.

Do you know what this means for companies making products in the UK to UK standards who then want to sell them in the EU?

@Peregrina

I thought that generally Europeans, including the UK, worked on a precautionary principle, whereas the Americans tended to assume something was safe until proved not.

Peregrina yes that sounds as if it makes sense.

As a consumer , I do find it strange that there is no common standard of risk but I understand what you are saying.

I coukdnt agree more! Its very worrying and confusing for consumers. The reason why I remember about aspartame was because of the hoo-ha when the US banned it and people were worried it hadn't been banned here. I looked up the research and the amount of aspartame they fed to the rats was such a ridiculously large amount that it made the test unreasonable. In my opinion. And obviously the EU thought so too. I think that would go against europe being more precautionary than the US. But it's just one example. And I don't think you can extrapolate much from that so maybe Peregrine is correct.

I think its very difficult for the consumer to read the scientific papers and make a judgement on their own behalf. So then you're reliant on newspaper summaries but, as we've seen during the pandemic, they can be taken out of context and be sensationalised for clickbait.

And I've also learned from covid that far from science being cut and dried true and false, it's very subjective.
I was brought up to think an egg a day was good for you - go to work on an egg. And then we were told that you shouldn't eat more than 3 eggs a week because of the cholesterol. Now the scientists are saying eat away. Eggs are good for you and the cholestrol is not a problem .

It's all very confusing for my small, aspartame-riddled, overly white brain! 😉

It's all very confusing for my small, aspartame-riddled, overly white brain!

You and me both Nightlystroll!

I am interested in how this issue will impact on UK food exports and imports post Brexit though. I just can't see how it is going to work in reality without conformity across the board!

I guess that's why firms such as Lyons are going with the EU ruling because they'll be exporting into the EU and it's easier to use the same ingredients for home and abroad. But a mom and pop store just selling here can carry on without incurring costs to change. Best of both worlds?

@Nightlystroll

I guess that's why firms such as Lyons are going with the EU ruling because they'll be exporting into the EU and it's easier to use the same ingredients for home and abroad. But a mom and pop store just selling here can carry on without incurring costs to change. Best of both worlds?

Sorry for delay in responding Nightlystroll.

I'm not sure it is the best of both worlds tbh! Large businesses often start small and not many companies want to restrict their products to the home market I would imagine. And if you are looking to expand your customer base, I would have thought that it would make sense to align your products to be EU reg compliant.

I cannot personally see the benefit of the uk (66 million potential customers) as a fairly small island compared with the EU (447 million potential customers) diverging very far from EU standards in the food and agriculture sectors anyway! Actually, I am not sure I can see much benefit in any sector, from an import-export point of view,cexcept as you say, your business is so small and niche that it doesn't matter.

But even then, say I was buying some local cake, cheese, or pork product local to a specific area of the UK, I would want to know that the ingredients and methods used to produce it were of a high standard .

if your business is so niche