EU botanicals mini-Q&A
Is the demographic of botanical buyers changing?
“There is still strong demand for food supplements in many markets, partially because many of the formulations are more complex, include a greater degree of whole plant part components, as compared with extracts. The THMPD (Traditional Herbal Medicinal Products Directive) products are significantly different and as medicines are aimed at people with minor ailments, rather than those who are seeking to maintain a high level of health.”
How has the EU market been impacted five years after the implementation of the THMPD?
“It is unfortunate that some of the THMPD license holders have encouraged regulators to challenge the legal status of food supplements sharing the same ingredients, even if the form and presentation is quite different. These two types of products are rarely substantially equivalent and there’s room in the marketplace for both types of product.”
What impact has the botanical health claim limbo had on the market?
“It has not allowed the benefits of the EU single market to be felt, because different member states are taking very different approaches to their interpretation of the transitional measures under Article 28 of the EU nutrition and health claims regulation (NHCR).”
Is BREXIT a good thing for the UK market? Will it affect other markets?
“This is the 64 million dollar question – because it depends both on how UK regulators respond and on how trade negotiations are worked out. Done well, it will be better, done badly, it will be worse.”
Is the UK PsychoActive Substances Act impacting any botanicals?
“Many food ingredients have psychoactive effects, nutmeg being a good example. We think it’s just a matter of time before over-zealous regulators start to trawl through products selling in stores and online. Companies will do well to have all their ducks in a row before this time with detailed dossiers showing both the long history of food use and the safety profile of their products.”
