Currently the European Commission is looking to unify these levels across the board and is due to consult with member states later this year over the next step forward.
An EC discussion paper on the topic was released last June and the first summary of responses were talked over at a conference in Brussels in November. An orientation paper listing possible options for maximum and minimum levels for member states is expected by autumn.
The study by AEGP covers the 27 member states and Iceland, Norway, Switzerland and Croatia, and describes the legal requirements, regulatory practices and national particularities in the countries covered.
The situation across Europe is complex, with countries differing radically on their maximum and minimum levels. For example, the study found in Belgium that the maximum levels varied between 1.5 and three times the recommended daily allowance (RDA) with a minimum level of 1.5 per cent RDA. Denmark, for instance, varied on the maximum level from 1.8 to 1300 times RDA, and a higher minimum level of 30 to 33 per cent of RDA.
The study found some countries had no minimum level, including Estonia, which had a maximum level inline with RDA.
The directive has been an emotive topic as member states have dramatically different ideas about the best way to proceed.
The UK and The Netherlands are traditionally two of the most lenient markets. High dose products account for 12 to 15 per cent of the £220m UK vitamin and mineral market, and the UK industry and would suffer a severe blow if the EU legislation were to proscribe the sale of high dose products.
However, the commission has no deadline for when to complete the harmonization process for food supplements and trade unions are not expecting a proposal until next year.
European Responsible Nutrition Alliance (ERNA) secretary general Patrick Coppens said the alliance is currently working on a revised model which lays out maximum levels based on a safe dosage.
He said: "The model takes into consideration levels set by the European Food Safety Authority (EFSA). Our position is very much that the maximum level should be the safe level.
"I think it is the only scientific model which takes into account a safety assessment of mineral and vitamin levels."
Coppens added that the AESGP study added nothing new to the situation, he said: "The commission is more than aware of the different maximum levels between member states. For now the ball is very much in the commission's court."
The setting of maximum levels is part of the 2002 Food Supplements Directive.
