b'website, which report Michael Zazzio and Iwould only be determined by the EU Com- lowed daily maximum dose for that nutri-wrote: https://www.regeringen.se/4adaf9/ mission or by Sweden on a national level.ent so as to arrive at the permissible intake contentassets/f05608921696441fa02856f- This triggered the Swedish Food Agency tolevel for supplements. They calculate this 20da0a0c0/svenska-naturmedicins- work faster in establishing maximum per- for every nutrient, but with Vitamin D it is ka-sallskapet.pdf. mitted doses nationally. I wrote about thiseven more bizarre. They have concocted a Despitenumerousobstacles,wewereinNHF-SwedensmagazineHlsofrihet,scenariowithenrichedamountsofVita-happy to finally be accepted as a registeredand I also wrote to the Swedish Food Agen- min D in food. Even if they do enrich some bodyconsideringproposedlegislationcy, asking different questions about the ac- foodsinSweden,howcantheyassume toparticipatewiththeSwedishDepart- tions and measures the Agency wanted tothat these foods will be consumed? And to ment of Health in shaping the upcomingundertake. That was when and how I firstadd to this conundrum, this practice is not proposedlegislationaboutalternativeapplied to the Agency to list NHF-Swedeneven implemented yet! The Swedish Food medicineandwehopetheDepartmentas a body considering proposed legisla- Agency assumes that from this enriched will keep their word in the future. The De- tion.Theyrepliedthateveryonecoulddietary intake the average person will ob-partment is now under more pressure tosubmitanswerstoalegislativeproposaltain, via food, about 22.6 g of Vitamin D take into account what we advise as a reg- and refused this request. perday.TheAgencythencalculatesthe istered body than if we had simply madeAs before, I persisted with the Swedishpermissible level as follows: NOAEL of 100 comments on the proposal without beingFood Agency by asking why NHF-Sweden- 22.6 = 77.4 g/day, so that the food sup-a registered body. Moreover, only reportscould not comment as NHF President Scottplements maximum dose is set at only 77.4 fromregisteredbodiesarepublishedonTips speaks at Codex Alimentarius meet- g/day (i.e., 3,096 IUs).the governments website. ings where these matters are settled on aTheregulatorystoryforVitamin-A Becauseofallofthehurdlestobeglobal level, so why not allow NHF-Swedensupplements is similarly a sad tale. For Vi-overcome in being listed by the Swedishto respond nationally about the same legis- tamin-A levels, the Swedish Food Agency Department of Health, I was very happylation? I also noted to the Agency that Scottcites a single study that indicates that some to find out that at least the Swedish FoodTipsisthepresidentofNHF-Swedenaspregnantwomenmightbevulnerableif Agency had finally added NHF-Sweden towell, so this should be considered too. Thatthey were to ingest more than 10,000 IUs theirlistofbodyconsideringproposediswhenNHF-Swedenspersistencepaid(=3,000RE)perday.TheAgencybacks legislation, and that the Agency had alsooff. I was advised that the authorities havethatwithafewstudiesshowingthat kept its word and given us its report on theadded NHF-Sweden as a body consideringpost-menopausalwomencouldperhaps proposedlawforvitaminsandmineralsproposedlegislation.Wemustbedeter- suffer higher rates of hip fractures at that and asked us to comment. Yes, it was a realmined, and we will get what we ask for anddose. So, the Agency would basically let struggle in the beginning for NHF-Swedenwhat is best for our nation and our lives. 110,000 pregnant women in Sweden dictate to even appear on the Agencys list.NHF-SwedenreceivedtheSwedishthe maximum daily level in supplements ThemainchallengeinSwedenarisesFood Agency report on maximum nutri- for the rest of the 10 million people in Swe-from the fact that the Swedish communsent values in vitamin and mineral supple- den! Calculated at 3,0001,574 = 1426 RE/(the regions of citiesmunicipalitiesofments. In our response we will advise themday, this last amount would be the maxi-which there are 290 in number) each hasnot to deprive consumers of their right tomum dose permitted in food supplements. anindividuallegalresponsibilitytoas- optimal health by eliminating supplementsTheregulatorymindsetistrulybizarre sure that no harmful foods are sold locally.with sufficient potency for a physiologicaland incomprehensible sometimes.Therefore, in some communs suppliers ofeffect. In court, the Swedish Food AgencySo,intheend,youcanseethat food supplements were prosecuted for sell- andthecommunsconsider5,000IUsofNHF-Swedens presence is vital at the leg-ing what was presumed to be too high dos- Vitamin D to be too high of a dose, refer- islative table where your health will be im-es of Vitamin D (5,000 IUs). But those samering to EFSA levels.In this Swedish Foodpacted directly, either for good or for bad. products were allowed in all of the otherAgency report they cite EFSA, pointing outWe must all persist and not give in, stand-communs in Sweden. These prosecutionsthat the NOAEL (No Observable Adverseingfirmforwhatweknowisrightand extended also to B-vitamin levels in someEffect Level) dose for Vitamin D is 250 g/ making sure it is implemented.communs.TheSwedishFoodAgency,day, but due to some aberration, EFSA used though, with its regulatory power, ranksa factor of 2.5 so that the NOAEL dose be- 1.LivsmedelsverketSwedish Food Agency, higher in the government hierarchy thancame a mere 100 g/day! This is also thesee: https://www.livsmedelsverket.se/en.the communs. dose the Swedish Food Agency currently2.The Swedish Department of Health is a state Finally, this case went to High Courtconsiderstobethemaximumsafedailydepartment while the Swedish Food Agency is where the communs argued that the Euro- dose. more akin to the American Food and Drug Ad-pean Food Safety Authority (EFSA) guide- Atpresent,theSwedishFoodAgen- ministration (FDA) but with a narrower scope lines supported their harsh position. Butcy estimates daily dietary amounts of vi- that only regulates food. For regulating drugs the communs lost and the Court decidedtaminsandmineralsandthisestimatedand pharmaceuticals, Sweden has the Swedish that the maximum nutrient reference levelsamountisthensubtractedfromtheal- Medical Products Agency.H ealtHF reedomN ews /s priNg2020 33HFN_SPRING-2020_4-29-2020-FINAL.indd 33 4/29/20 10:18 AM'