FOR ACTION

18 May 2015

Request for an exemption for iodized salt

Dear all,
In September 2014, FoodDrinkEurope sent a letter to the Commission requesting to include
iodized salt into the list of foods which are not required to bear a list of
ingredients[1] (FCP/INCO/085/13E-Final). The Commission has not yet sent a formal reply to
FoodDrinkEuropes letter.
Thanks to the pressure made by the respective national federations, the Austrian and
German authorities raised this issue in the last Commission Working Group of 20 March
2015 supporting the industrys request for exempting iodized salt (German letter attached
in Annex 3). Other Member States (e.g. Belgium, The Netherlands, Czech Republic)
supported this request in the meeting. The Commission promised to come back on this by
mail or in the next Commission Working Group meeting, which will take place on 10 June
2015.
As it is important that other Member States support this request, members
(particularly National Federations) are invited to contact their national authorities in
advance of the Commission Working Group of 10 June 2015, asking to raise the issue
of iodized salt in the meeting and for their support to the concept of exempting iodized
salt from the requirement to bear a list of ingredients. In more technical terms, this can
be achieved via a delegated act, according to Article 19(2) and Annex VII, Part E of
Regulation (EU) 1169/2011 as proposed in the German letter under Annex 3. Please find
below further argumentation that can be used.
An overview of current national labelling practices/legislation on iodized salt is available
under Annex 1 - Members that have any additional information to be included in the
overview are invited to send this to the Secretariat. Last updated: 18 May 2015, to include
information from Belgium
Furthermore, an excel table kindly shared by a member concerning the rules on iodized salt
in European countries is available under Annex 2. Please, note that this table refers to the
use of iodized salt in processed foods (not to iodized salt as such intended to the final
consumer).
Thank you for your co-operation.
Kind regards,
The Secretariat
The following main arguments could be used to support this request for an exemption:
According to EU labelling rules, iodized salt may be regarded as a compound ingredient;
hence, the indication iodized salt followed by a list of its ingredients, i.e. [iodized salt (salt,
sodium iodate)]; [iodized salt (salt, potassium iodate)] would be required.

- Such a labelling would confuse consumers, while they are not provided with
any useful information (as sodium/potassium iodate are normally interconvertible in terms of nutritional physiology [2]);

- Food business operators will have to change the labelling every time the
composition of iodized salt is changed by the supplier. In regard to this, the
possibility of labelling [iodized salt (contains sodium iodate and/or potassium
iodate)] foreseen in Annex VII, Part A, point 7 does not solve the issue, as the
labelling would become even longer and more difficult to understand for
consumers.
- This labelling requirement will result in additional burdens for operators in
countries where the use of iodized salt is mandatory (e.g. Austria, Croatia,
Slovenia).
In other countries, food business operators may choose to prefer normal salt
instead of iodized salt, although iodized salt is regarded as important in
preventing iodate deficiency in the general population in many EU Member
States, according to public institutions and recent studies [3].
Additional and more detailed arguments can be found in the FoodDrinkEurope letter sent to
the Commission (FCP/INCO/085/13E-Final) - please, do NOT share the letter as such with
Member States authorities.

[1]

Iodised salt is currently regarded as a compound ingredient and must therefore be followed by a list
of its ingredients, i.e. [iodized salt (salt, sodium iodate)]; [iodized salt (salt, potassium iodate)].
[2]
Although sodium/potassium iodate are normally inter-convertible in terms of nutritional
physiology, for certain groups of consumers, such as consumers with kidney problems/dialysis, it
makes a difference if sodium or potassium is used.
[3]
Institutions such as the German Nutrition Society (DGE) explicitly encourage food manufacturers to
use iodised salt in order to improve the supply situation of the population.
For data concerning the populations iodine status in Europe see: EFSA Scientific Opinion on Dietary
Reference Values for iodine; Iodine deficiency in Europe: A continuing public health problem
(WHO); Global Iodine Status in 2011 and Trends Over the Past Decade.